REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.

REPRESENTATION IN RELATION TO SITE 073 LAND ADJACENT MOUNTNESSING PRIMARY SCHOOL

Introduction

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 073 (SHLAA site G093), Land Adjacent to Mountnessing Primary School, which is being promoted by Crest Nicholson.

A Design Development Framework has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth Options Consultation document.

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

No.

Brentwood Borough Council (BBC) recognise that in order to address the Borough's significant housing shortfall against Objectively Assessed Need (OAN), Green Belt land release is required to accommodate an additional 3,000 homes during the next 15 years.

We support 'Growth Option B' which promotes growth along the A12 corridor. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. Sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth).

Mountnessing is illustrated on figure 6b of the Strategic Growth Options Consultation document which identifies the key settlements along the corridor.

Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).

As the consultation document acknowledges "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in villages to ensure the viability and vitality of local shops and services.

We acknowledge that these villages (such as Mountnessing) have a rural setting so it is also imperative that suitable sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes. Crest Nicholson is the current National Housebuilder of the Year and is locally-based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.


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

We agree with the Council's consideration of Green Belt release because there is insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as
Mountnessing, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village with the capacity to meet settlement specific needs in the short to medium term (for example site 073). As mentioned previously, this is crucial to maintain the viability/vitality of village shops and services.

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

This document specifically supports the site at Land adjacent to Mountnessing Primary School (site 073 / SHLAA site G093) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements of Mountnessing.

A Local Housing Requirements Study prepared by Barton Wilmore concludes that the projected household growth for Mountnessing will generate a need for circa 6 dwellings per year.

The Land adjacent to Mountenessing Primary school is the most sustainable housing option
at Mountnessing to meet this local housing need in the short to medium term.

The appended Design Development Framework demonstrates how the Site could be sensitively developed to provide a sustainable, high quality, low density scheme. A design led approach has resulted in a latest indicative proposal of 15-18 units (reduced further from the initial 25 unit scheme shown in previous representations).

The site has a number of planning benefits:

* It is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact from the proposals.
* It would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary.
* It does not serve any of the purposes of the Green Belt in accordance with the NPPF.
* No environmental or ecological constraints have been identified that would prevent its development for residential use.
* Highways have confirmed that access off Crossby Close is acceptable in principle (shared surface upgrades are currently being examined).
* The proposals would lead to the short term delivery of much needed, high quality, generously landscaped, private and affordable homes delivered by the National Housebuilder of the Year.
* The proposals would result in a number of significant socio-economic and community benefits (see page 15 of the Design Development Framework).

The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan
period.

Within the SHLAA and Site Assessment "Land Adjacent to Mountnessing Primary School, Mountnessing" is identified as the only suitable residential site at Mountnessing. BBC states that the site is capable of delivering circa 35 dwellings within the first five years of the Plan period. BBC further states in the Assessment that the site is:

"Suitable: Comprises ploughed agricultural land with no buildings on site. Site is bound by residential properties and Primary School and therefore impact on the open countryside would be minimal. The site would be suitable for development as it is on the edge of the village with associated amenities;
Available: The site is available for residential development; and
Achievable: Development at this site would be within an attractive area. Due to the location it is recommended that only low density housing would be appropriate. Contamination issues are unknown at present. Connection to infrastructure and services would be relatively low cost as the site is adjacent to existing residential development. Development would be brought forward by a medium size developer."

Land adjacent to Mountnessing Primary School is considered to be the only suitable site at Mountnessing to accommodate settlement specific housing needs in the short term. SHLAA Sites 094,105 and 136 only have the capacity to accommodate 1-3 dwellings whilst sites 095, 106 and 128 are entirely inappropriate in terms of scale and coalescence with Ingatestone.

Subsequently, Land adjacent to Mountnessing Primary School should be allocated for residential use in the next iteration of the Local Plan.

Crest Nicholson have been meeting with both Mountnessing Parish Council and Mountnessing Primary School (Headteacher and Governors) regarding the potential to develop the site for housing. There is a general recognition that the proposals would bring substantial positive benefits to the village including maintaining the future of the existing primary school, assisting to meet local housing (including affordable) needs and ensuring the short and longer term viability of local shops and services. The positive quotes below have been provided by the Primary School and Parish Council.

"With the assurance that the proposed site is well screened and secured the school has no objections in principle to the proposed development. The potential increase in pupil numbers arising from the proposed housing development is welcomed. The prospect of extending the provision of the unique education provided by Mountnessing Primary school to more children is both challenging and exciting. However, an increasing number of pupils within the present school is utilizing the school buildings and infrastructure to the full and additional facilities would be essential to accommodate an increase in roll. We would welcome a study to be undertaken by the Local Education Authority to consider our future requirements and the details of the study to be included for consideration in the Section 106 notice."

Governors of Mountnessing Primary School - Date: 12th February 2015-03-12

Following discussions with the Parish Council and a more detailed design-led assessment of the site, there has been a reduction in the number of residential properties proposed. The Parish Council do not object to the principle of residential development on the site.

'Following ongoing consultation with Crest Nicholson, we can confirm that Mountnessing
Parish Council do not object to the principle of residential development on the land
adjacent to Mountnessing Primary School. Whilst we have concerns over the Crossby
Close access we acknowledge that the reduction in the proposed number of dwellings
and sensitive treatment of the access road scheme will be helpful.'

Mountnessing Parish Council

Date: 13th February 2015

Crest Nicholson will continue to develop the plans in consultation with the Parish Council, Mountnessing Primary School and the local community.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, as referred to the response to Questions 1-3.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Mountnessing). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs. Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and local social infrastructure.

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

We consider that education should be a priority especially in relation to extending the provision of education provided by Mountnessing Primary school.

REPRESENTATION IN RELATION TO SITE 076 LAND SOUTH OF REDROSE LANE

These planning representations have been prepared by Savills UK on behalf of Crest Nicholson Eastern in response to Brentwood Borough Council's Strategic Growth Options Consultation. The representations specifically relate to site 076 (SHLAA site G070A), Land South of Redrose Lane, Blackmore.

A Vision Statement has been prepared which identifies the benefits and opportunities for the site which is enclosed as Appendix 1.

We set out below responses to the relevant questions as out in the Strategic Growth
Options Consultation document.

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

No.

We acknowledge that 'Growth Option B' (A12 Corridor) warrants consideration, particularly around Brentwood, at the top of the Borough's settlement hierarchy. However, sites within this corridor need to be well contained by defensive, permanent boundaries and represent an appropriate scale in relation to the settlement they adjoin (supported by localised ONS data on household growth). The ability to mitigate development in transport impact terms will also need to be demonstrated.

'Growth Option A' which supports the growth of villages in the north of the Borough should be given priority. As the consultation document acknowledges, "it is important to consider allowing villages to grow in order to provide for local need". This approach not only seeks to meet local, settlement specific housing needs to address localised affordability issues but it is also necessary to retain the working age population in the village to ensure the viability and vitality of local shops and services. As such, support is given to the development of the most sustainable Green Belt site/sites on the edge of villages with the capacity to meet settlement-specific housing needs. We acknowledge that the villages have a rural setting so it is also imperative that these sites can be delivered in the short term by a housebuilder with a proven track record of delivering high quality, low density, well-landscaped schemes.

Crest Nicholson is the current National Housebuilder of the Year and is a local company based in Brentwood.

We object to the quantum of 4-6,000 homes that has been proposed at the Dunton Garden Suburb (Growth Option C) on the periphery of the Borough, which would not assist in meeting the existing settlement specific housing and socio-economic needs within Brentwood and especially the villages throughout the Borough.

The principle of an urban extension to the settlement of Basildon is not objected to but the quantum of cross-boundary development suggested is not logical, nor justified by any meaningful evidence. The area within the administrative boundary of Brentwood has a number of environmental constraints and the quantum proposed will require a significant upgrade to strategic infrastructure. The time frames for the delivery of such an extensive development will not address the acute local housing shortage within Brentwood that exists now. It is considered that reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations.

It is further considered that the only viable, appropriate and logical area for housing within the Dunton Garden Suburb area is immediately adjacent to the settlement boundary of Basildon Town.

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

We agree with paragraph 2.15 of the Strategic Growth Options Consultation Document where it is stated that in order to provide for local need, villages should be allowed to grow, and the edge of villages could be released from the Green Belt to enable this.

We agree with the Council's consideration of Green Belt release because there is
insufficient brownfield land to meet its objectively assessed need (OAN) (as indicated at paragraph 1.4 of the consultation document). We would reassure the Council that Hundal v South Buckinghamshire (DC 2012) demonstrates that housing need is capable of justifying a change in the Green Belt boundaries. Taking this point into practice, St Albans City and District Council (another Metropolitan Green Belt authority) is preparing its Local Plan to meet full OAN with Green Belt release on the basis that 'exceptional circumstances' do exist because there is insufficient brownfield capacity and no alternative locations beyond the Green Belt. This situation is materially the same as can be observed in Brentwood Borough and we subsequently support the consideration of Green Belt release. Therefore, where there are suitable, sustainably located Green Belt sites adjoining villages such as Blackmore, they should be released for residential development.

Whilst the document refers to meeting local housing need through the release of land within the Green Belt at each village, clarification is required on how this is defined. It is essential that the most appropriate site is allocated at each village which has the capacity to meet settlement specific needs over the next 10 years (for example site 076). As mentioned previously, this is crucial to maintain the viability/vitality of village services.

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

This document specifically supports the site at Land South of Redrose Lane, Blackmore (076) which we consider should be released from the Green Belt, in order to meet the existing and future housing and socio-economic requirements within Blackmore.

A Local Housing Requirements Study for Blackmore, prepared by Barton Wilmore (August 2013) concludes that projected household growth at Blackmore will generate a need for between circa 81- 98 dwellings over the next 20 years (or approximately 60-75 though the proposed Plan Period 2015-2030). It is considered that the Land south of Redrose Lane is the only sustainable housing option within Blackmore to meet this need in the short-to medium term.

The Vision Statement at Appendix 1 demonstrates how the Site could be sensitively developed to provide a sustainable, high quality scheme in the region of 40 residential units.

The site is suitable for a number of reasons:

The site is well screened, with defensible boundaries on four sides, ensuring that visual impact from the proposals will be minimal, and considerably less than other promoted sites;

* The site does not result in any symptoms of coalescence and is located within an area of established residential character, that presents itself as a logical extension to the existing settlement boundary;
* The site does not perform the function of preserving the setting and special character of
a historic town or any assets of historic value;
* No environmental or ecological constraints have been identified on the site that would
prevent its development for residential use; and
* The proposals would result in a number of significant socio-economic community
benefits.

Access to the site is achievable from Red Rose Lane which has been agreed in principle with Highway Officers. Pedestrian access is possible from the north-west corner of the site via a new footpath link connecting to a short section of new footway on the south side of Red Rose Lane. The new footway extends south to the existing footway that currently terminates opposite Orchard Piece, from which point existing footways facilitate walk trips to the village centre.

Within BBC's SHLAA (2011) and "Draft Site Assessment" (July 2013) which supports the Local Plan, "Land South of Redrose Lane, Blackmore (ref G070A)" is identified as appropriate for housing development for 89 units. It should be noted that a design-led approach has resulted in a lower-density scheme of approximately 40 residential units. The Vision Statement enclosed at Appendix 1 identifies the benefits and opportunities for the site.

BBC states in their SHLAA that the site is:
* Suitable: The site is located adjacent to the settlement boundary and contained by Redrose Lane ,Fingrith Hall Lane and Chelmsford Road. The site comprises land used for grazing. The site is bounded on one side by residential properties. Development in this location would help to support the viability and vitality of existing services and potentially provide new services
* Available: The site is available for residential development; and
* Achievable: Residential development on this site would be achievable due to its
location within an attractive area. Due to its size this site would be brought forward by a medium sized developer.

A total of 7 sites (not including the subject site) are considered in the SHLAA. Two of the sites are on brownfield land and can only achieve approximately 1 dwelling (B140 and B141). The remaining 5 sites are located on greenfield land. Three of these sites are discounted due to the unacceptable intrusion into the countryside G041, G044 south and G044 west). One other site can only achieve one dwelling (G146).

The remaining Green Belt site G070 lies to the west of the subject site. This site has many similarities due to its close proximity to the subject site. However it is more open in nature, does not have clear defensible boundaries on all sides and development would have a greater impact on existing residential properties. The site also lies to the north west of Blackmore which represents an important green gateway into the village, characterised by open space either side of Nine Ashes Road (including Blackmore Millenium Park). The north eastern part of Blackmore is distinctly different in character due to its more enclosed nature and the existing residential development along Chelmsford Road.

As such it is considered that the subject site is the only suitable site around Blackmore.

Land South of Redrose Lane (076) is being promoted by Crest Nicholson who are National Housebuilder of the Year and are fully committed to delivering a high quality, low density, well-landscaped scheme.

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?

As above in queston Q3, none are appropriate in this area on the periphery of the Borough.

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

Yes, some growth is understandable given the supporting road infrastructure.

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 the Green Belt)?

It is considered that the release of Greenfield sites on the edge of villages is the preferred approach. The development of Greenfield sites avoids village cramming in areas where urban capacity is already non-existent (for example in Blackmore). This would not be a sustainable solution to the delivery new homes as it is anticipated that only a small number of homes would be built and therefore would not meet objectively assessed needs.

Furthermore, small scale urban development (under 10 units) would not deliver much needed affordable housing provision.

The delivery of Greenfield sites allows for higher quality, lower density, well landscaped housing development. The delivery of larger scale development will also provide planning benefits including financial contributions to local services.

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

Greater reference is required to maintaining village services and social infrastructure.

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

We consider that education should be a priority.

Commissioning school places in Essex 2013/18 (2014) confirms that Blackmore Primary School currently has capacity to accommodate an additional 17 pupils. The provision of family housing on Land at Redrose Lane would be beneficial in terms of ensuring sufficient numbers on roll to meet this capacity. This would have a positive impact on the existing school and wider community with more children given access to extend learning opportunities. It will also ensure that the village has a wider age diversity which will enable the retention of a working age population in future years and secure the long term viability of shops and services.