Comment

Representation ID: 12833

Received: 30/04/2015

Respondent: Crest Nicholson

Agent: Bidwells

Of the five suggested alternative growth options put forward in the Interim SA, three are within the A12 corridor; Option 3 - south-east of Brentwood-Shenfield, Option 4 - Pilgrims Hatch, and Option 5 - numerous smaller extensions. Development at Nag's Head Lane qualifies under this assessment as falling within Option 5, but we consider that each option should not be considered in isolation through assessment against each other. Options 3 and 4 would have significantly more damaging Green Belt impacts than development at Nag's Head Lane, but so would Option 1 in its totality (refer to section 3 below). It may therefore be the case that a combination of, or the most favourable components from the options are considered, but the SA as drafted does not appreciate that some Option 5 sites are inherently better placed to take a proportion of the Borough's housing requirement than other Option 5 sites. Our Design Development Framework's assessment of the other available sites on the edge of the Brentwood urban area (on pages 8 and 9) indicates that the land east of Nag's Head Lane performs better in terms of landscape and Green Belt impacts, impact upon infrastructure, it is more sustainable, and could be delivered quicker than many of the other sites.

Comment

Representation ID: 12834

Received: 30/04/2015

Respondent: Crest Nicholson

Agent: Bidwells

We agree that "an overall transport strategy" is required "particularly with regard to the potential strategic development impacts on the A127 and beyond" (para 6.6). In respect of Dunton Garden Suburb, we would question whether its impact on the operation of the A127 Dunton Interchange could be fully mitigated in order to realise the allocation of this land based on the proposed quantum in its totality.Significant queues have been observed at this junction at peak times, which suggests that this already operates beyond its capacity. In this respect, we acknowledge and welcome that "Brentwood Borough Council are carrying out further transport modelling to inform this strategy" (para 6.6) and we would expect this to be coordinated with Basildon Borough.

Comment

Representation ID: 12835

Received: 30/04/2015

Respondent: Crest Nicholson

Agent: Bidwells

The potential for a new rail station on the Essex Thameside line has been identified to serve the Garden Suburb site and this appears key to support sustainable residential development in this location. The viability of a new rail station would be dependent upon its impact on journey times and line capacity, and its delivery is therefore questionable in lieu of an assessment being undertaken by Network Rail and c2c. Should this prove unviable, the land within Brentwood Borough would be some 3.5km 'as the crow flies' from the closest accessible rail station at Laindon; this compares to a 2km distance between land east of Nag's Head Lane and Brentwood rail station.

Object

Representation ID: 12836

Received: 30/04/2015

Respondent: Crest Nicholson

Agent: Bidwells

We generally welcome the consideration of the release of Green Belt land as necessitated by the Council's OAN evidence and recent case law (see 2.3 above), but we object to the proposed quantum of the Garden Suburb in its totality (6,000 units).
An allocation with this size in this location would be of such a scale that it would push the built development so far to the west of the Green Belt's current boundary with the urban area of Basildon, giving rise to a significant and very real perception of coalescence with West Horndon, contrary to Framework advice. Having regard to the Borough's Green Belt housing requirement of 3,000, an allocation of this size runs the very serious risk of unduly depriving the remainder of Brentwood Borough of the growth it needs to development sustainably throughout the Plan period.

Comment

Representation ID: 12837

Received: 30/04/2015

Respondent: Crest Nicholson

Agent: Bidwells

The Interim SA for the Local Plan considers the Garden Suburb proposal against the other alternative growth options in the Borough. Why, therefore, does the Garden Suburb SA document not do the same? We are concerned with this key omission from the SA/HRA because it is currently not yet understood what sustainability implications a proposal of this size, in this location, would have upon the growth prospects of the rest of Brentwood Borough. Furthermore, we are concerned that a Garden Suburb proposal could form part of a Submission Local Plan, generally considered as an advanced stage in the process, the next stage in Brentwood Borough Council's Local Plan process (Interim SA para 15.1.1), without having previously been tested or consulted upon. We would therefore welcome the publication of a revised SA/HRA for the Garden Suburb proposals