Covering Letter

We act on behalf of Asphaltic Developments Ltd and write in respect of the above consultation, to
which we are instructed to submit representations.

As you are aware, our client has an interest in the Brentwood Leisure Park, in Warley, Brentwood, which is detailed on the enclosed site location plan (drawing ref: 159/30/3_SLP01). We previously submitted representations on the Preferred Options Local Plan consultation document in October 2013, to promote Brentwood Leisure Park's opportunity for housing development to be considered in the emerging Local Plan for the Borough.

Brentford Leisure Park is identified as one of the A12 corridor housing site options (site ref: 141) in the current consultation document. We consider that the Leisure Park site is a suitable and appropriate site for residential development in order to meet the Council's objectively assessed housing needs, which have increased to 5,500 homes in the plan period. As such, we request that the site's suitability and potential for housing development is recognised in the Local Plan through an allocation, as set out in the enclosed Consultation Questionnaire.

We request that our response to the "Consultation Questionnaire" is taken into account as part of the consultation exercise.

We respectfully request that the Council considers the representations in full and that those considerations will be reflected in the next stage of the document's preparation. We request that we are kept informed and updated of the forthcoming stages of the preparation of the Brentwood Borough Local Plan.

We will be pleased to provide further information or explanation on these representations should it assist. In the meantime, we look forward to receiving written confirmation that these representations have been received and duly made as part of this consultation excercise, marked for the attention of Wakako Hirose at this office.

Consultation Questionnaire

Q1 - With regard to the growth options, we agree that brownfield land should be utilised efficiently as part of future growth options for the Borough, and that there are brownfield development opportunities adjoining/surrounding the urban areas within the Green Belt.

We consider that in order to meet the Borough's objectively assessed housing needs, available brownfield land within the Green Belt should be utilised, which in turn would minimise the pressure on development of greenfield and undeveloped Green Belt sites. We therefore agree that brownfield development opportunities within the Green Belt should be actively promoted and utilised as part of the Borough's growth.

The Sustainability Appraisal ('SA') of the Brentwood Borough Local Plan (Interim SA Report January 2015) considers 5 options for growth, which include strategic sites on greenfield and agricultural land, as well as urban extensions (option 5). It states that it is appropriate to appraise Option 5, which would involve dispersing growth between a number of smaller sites, within or on the edge of existing urban areas, and more work would need to be undertaken to determine precisely which sites are best performing and should be developed, if it did transpire that the Council's preferred approach is Option 5. We consider that non-strategic brownfield sites which are connected to, or close to urban areas, thereby providing sustainable urban extensions, should be considered as one of the preferred options for the delivery of the Council's housing requirement. This is necessary to ensure a flexible and responsive supply of land, and to prioritise the re-use of previously developed land in line with national policy.

Q3 - Site Reference: 141: Brentwood Leisure Park

Brentwood Leisure Park is brownfield land within the Metropolitan Green Belt, in Warley, south of Brentwood. The site extends to 7.825ha in total (with that area of the site excluding the wooded area) extending to approximately 5.6ha. That part of the site, comprising the existing leisure park, including dry ski-slope, driving range, outdoor karting centre, a restaurant, a vacant indoor leisure centre and car park, represents brownfield land.

As advised in our previous representations, the Leisure Park site could come forward for redevelopment in the short to medium term, should the existing uses become vacant or unviable in terms of their ongoing operation. The site represents an available location for redevelopment and is a suitable (previously developed) site for residential use, at such a time when the existing uses become vacant or unviable.

The site offers a number of benefits, which lends it suitably for future residential development. These are as follows:

- The site can sustainably accommodate residential development, supporting the borough's objectively assessed housing needs;
- The site is considered suitable for removal from the boundary of the Metropolitan Green Belt, on the basis that its characteristics do not fulfil the purposes of including land within the Green Belt;
- The site is well placed in relation to the existing built form, and constitutes previously developed land, and is therefore a suitable location for growth as an extension of the urban area; and
- The site currently contains dry-ski slope, driving range, and go-kart track, which do not contribute to the characteristics of Green Belts, and housing redevelopment has the potential to facilitate the provision of appropriate landscaping, which would contribute to the landscape value and the characteristics of the Green Belt in the surrounding area.

The SA undertook a sustainability appraisal of Option 5, as a whole, rather than individual sites. In order to inform the allocation of sites for housing development, sustainability of each sites considered under Option 5 would need to be assessed individually. Brentwood Leisure Park is a sustainable site, when assessed against sustainability criteria, and does not have many of the constraints as identified in the SA Site Specific Baseline Issues for Option 5, as follows:

- There is no Air Quality Monitoring Area in the surrounding area and road
network.

- The nearest station is less than 1.5 miles away (c. 1.2 miles). Additionally, the nearest bus stop, which provides bus serves to Brentwood Railway Station and the town centres, is within easy walking distance of the site (0.3 mile). Therefore, the site is accessible in terms of public transport provision.

- The site is accessible in terms of local facilities - the nearest local centre, including Post Office, and General Practice are approximately 1.1 miles and 0.9 mile from the site.

- The site is not within or adjoins Flood Zones 2 or 3.

- The site is previously developed land.

Accordingly, the site is considered to be more sustainable as a housing site than other sites under Option 5 or other strategic sites on greenfield and agricultural land.

As the site is very close to the existing urban area, it is considered suitable for removal from the boundary of the Metropolitan Green Belt, on the basis that its characteristics do not fulfil the purposes of including land within the Green Belt, as set out in the National Planning Policy Framework (NPPF). Accordingly, the removal of the site from the Green Belt boundaries would not alter the position in terms of:

i) Checking unrestricted sprawl;
ii) Preventing neighbouring towns from merging;
iii) Assisting in safeguarding the countryside from encroachment;
iv) Preserving the setting and special character of historic town in the locality, and
v) Assisting urban regeneration.

We therefore consider that Brentwood Leisure Park is an appropriate, suitable and sustainable site for housing development to deliver the Council's housing requirements, without undermining the fundamental aim of the Green Belt policy for the borough through preventing urban sprawl and encroachment to the openness of the Green Belt.

Q5 - Yes. As commented under Question 1, we consider that the A12 corridor area, which has the majority of the existing towns and urban areas, should be the focus for growth to meet the Council's housing needs. This should be realised through the release of sustainable sites on edge of urban areas, including appropriate brownfield sites within Green Belt, such as Brentwood Leisure Park (as detailed in our comments under Question 3). It is considered that sustainable urban extensions are in line with national policy, through prioritising the utilisation of previously developed and are necessary to ensure a flexible and sufficient supply of land.

Covering Letter

We act on behalf of Asphaltic Developments Ltd and write in respect of the above consultation, to
which we are instructed to submit representations.

As you are aware, our client has an interest in the Brentwood Leisure Park, in Warley, Brentwood, which is detailed on the enclosed site location plan (drawing ref: 159/30/3_SLP01). We previously submitted representations on the Preferred Options Local Plan consultation document in October 2013, to promote Brentwood Leisure Park's opportunity for housing development to be considered in the emerging Local Plan for the Borough.

Brentford Leisure Park is identified as one of the A12 corridor housing site options (site ref: 141) in the current consultation document. We consider that the Leisure Park site is a suitable and appropriate site for residential development in order to meet the Council's objectively assessed housing needs, which have increased to 5,500 homes in the plan period. As such, we request that the site's suitability and potential for housing development is recognised in the Local Plan through an allocation, as set out in the enclosed Consultation Questionnaire.

We request that our response to the "Consultation Questionnaire" is taken into account as part of the consultation exercise.

We respectfully request that the Council considers the representations in full and that those considerations will be reflected in the next stage of the document's preparation. We request that we are kept informed and updated of the forthcoming stages of the preparation of the Brentwood Borough Local Plan.

We will be pleased to provide further information or explanation on these representations should it assist. In the meantime, we look forward to receiving written confirmation that these representations have been received and duly made as part of this consultation excercise, marked for the attention of Wakako Hirose at this office.

Consultation Questionnaire

Q1 - With regard to the growth options, we agree that brownfield land should be utilised efficiently as part of future growth options for the Borough, and that there are brownfield development opportunities adjoining/surrounding the urban areas within the Green Belt.

We consider that in order to meet the Borough's objectively assessed housing needs, available brownfield land within the Green Belt should be utilised, which in turn would minimise the pressure on development of greenfield and undeveloped Green Belt sites. We therefore agree that brownfield development opportunities within the Green Belt should be actively promoted and utilised as part of the Borough's growth.

The Sustainability Appraisal ('SA') of the Brentwood Borough Local Plan (Interim SA Report January 2015) considers 5 options for growth, which include strategic sites on greenfield and agricultural land, as well as urban extensions (option 5). It states that it is appropriate to appraise Option 5, which would involve dispersing growth between a number of smaller sites, within or on the edge of existing urban areas, and more work would need to be undertaken to determine precisely which sites are best performing and should be developed, if it did transpire that the Council's preferred approach is Option 5. We consider that non-strategic brownfield sites which are connected to, or close to urban areas, thereby providing sustainable urban extensions, should be considered as one of the preferred options for the delivery of the Council's housing requirement. This is necessary to ensure a flexible and responsive supply of land, and to prioritise the re-use of previously developed land in line with national policy.

Q3 - Site Reference: 141: Brentwood Leisure Park

Brentwood Leisure Park is brownfield land within the Metropolitan Green Belt, in Warley, south of Brentwood. The site extends to 7.825ha in total (with that area of the site excluding the wooded area) extending to approximately 5.6ha. That part of the site, comprising the existing leisure park, including dry ski-slope, driving range, outdoor karting centre, a restaurant, a vacant indoor leisure centre and car park, represents brownfield land.

As advised in our previous representations, the Leisure Park site could come forward for redevelopment in the short to medium term, should the existing uses become vacant or unviable in terms of their ongoing operation. The site represents an available location for redevelopment and is a suitable (previously developed) site for residential use, at such a time when the existing uses become vacant or unviable.

The site offers a number of benefits, which lends it suitably for future residential development. These are as follows:

- The site can sustainably accommodate residential development, supporting the borough's objectively assessed housing needs;
- The site is considered suitable for removal from the boundary of the Metropolitan Green Belt, on the basis that its characteristics do not fulfil the purposes of including land within the Green Belt;
- The site is well placed in relation to the existing built form, and constitutes previously developed land, and is therefore a suitable location for growth as an extension of the urban area; and
- The site currently contains dry-ski slope, driving range, and go-kart track, which do not contribute to the characteristics of Green Belts, and housing redevelopment has the potential to facilitate the provision of appropriate landscaping, which would contribute to the landscape value and the characteristics of the Green Belt in the surrounding area.

The SA undertook a sustainability appraisal of Option 5, as a whole, rather than individual sites. In order to inform the allocation of sites for housing development, sustainability of each sites considered under Option 5 would need to be assessed individually. Brentwood Leisure Park is a sustainable site, when assessed against sustainability criteria, and does not have many of the constraints as identified in the SA Site Specific Baseline Issues for Option 5, as follows:

- There is no Air Quality Monitoring Area in the surrounding area and road
network.

- The nearest station is less than 1.5 miles away (c. 1.2 miles). Additionally, the nearest bus stop, which provides bus serves to Brentwood Railway Station and the town centres, is within easy walking distance of the site (0.3 mile). Therefore, the site is accessible in terms of public transport provision.

- The site is accessible in terms of local facilities - the nearest local centre, including Post Office, and General Practice are approximately 1.1 miles and 0.9 mile from the site.

- The site is not within or adjoins Flood Zones 2 or 3.

- The site is previously developed land.

Accordingly, the site is considered to be more sustainable as a housing site than other sites under Option 5 or other strategic sites on greenfield and agricultural land.

As the site is very close to the existing urban area, it is considered suitable for removal from the boundary of the Metropolitan Green Belt, on the basis that its characteristics do not fulfil the purposes of including land within the Green Belt, as set out in the National Planning Policy Framework (NPPF). Accordingly, the removal of the site from the Green Belt boundaries would not alter the position in terms of:

i) Checking unrestricted sprawl;
ii) Preventing neighbouring towns from merging;
iii) Assisting in safeguarding the countryside from encroachment;
iv) Preserving the setting and special character of historic town in the locality, and
v) Assisting urban regeneration.

We therefore consider that Brentwood Leisure Park is an appropriate, suitable and sustainable site for housing development to deliver the Council's housing requirements, without undermining the fundamental aim of the Green Belt policy for the borough through preventing urban sprawl and encroachment to the openness of the Green Belt.

Q5 - Yes. As commented under Question 1, we consider that the A12 corridor area, which has the majority of the existing towns and urban areas, should be the focus for growth to meet the Council's housing needs. This should be realised through the release of sustainable sites on edge of urban areas, including appropriate brownfield sites within Green Belt, such as Brentwood Leisure Park (as detailed in our comments under Question 3). It is considered that sustainable urban extensions are in line with national policy, through prioritising the utilisation of previously developed and are necessary to ensure a flexible and sufficient supply of land.

Covering Letter

We act on behalf of Asphaltic Developments Ltd and write in respect of the above consultation, to
which we are instructed to submit representations.

As you are aware, our client has an interest in the Brentwood Leisure Park, in Warley, Brentwood, which is detailed on the enclosed site location plan (drawing ref: 159/30/3_SLP01). We previously submitted representations on the Preferred Options Local Plan consultation document in October 2013, to promote Brentwood Leisure Park's opportunity for housing development to be considered in the emerging Local Plan for the Borough.

Brentford Leisure Park is identified as one of the A12 corridor housing site options (site ref: 141) in the current consultation document. We consider that the Leisure Park site is a suitable and appropriate site for residential development in order to meet the Council's objectively assessed housing needs, which have increased to 5,500 homes in the plan period. As such, we request that the site's suitability and potential for housing development is recognised in the Local Plan through an allocation, as set out in the enclosed Consultation Questionnaire.

We request that our response to the "Consultation Questionnaire" is taken into account as part of the consultation exercise.

We respectfully request that the Council considers the representations in full and that those considerations will be reflected in the next stage of the document's preparation. We request that we are kept informed and updated of the forthcoming stages of the preparation of the Brentwood Borough Local Plan.

We will be pleased to provide further information or explanation on these representations should it assist. In the meantime, we look forward to receiving written confirmation that these representations have been received and duly made as part of this consultation excercise, marked for the attention of Wakako Hirose at this office.

Consultation Questionnaire

Q1 - With regard to the growth options, we agree that brownfield land should be utilised efficiently as part of future growth options for the Borough, and that there are brownfield development opportunities adjoining/surrounding the urban areas within the Green Belt.

We consider that in order to meet the Borough's objectively assessed housing needs, available brownfield land within the Green Belt should be utilised, which in turn would minimise the pressure on development of greenfield and undeveloped Green Belt sites. We therefore agree that brownfield development opportunities within the Green Belt should be actively promoted and utilised as part of the Borough's growth.

The Sustainability Appraisal ('SA') of the Brentwood Borough Local Plan (Interim SA Report January 2015) considers 5 options for growth, which include strategic sites on greenfield and agricultural land, as well as urban extensions (option 5). It states that it is appropriate to appraise Option 5, which would involve dispersing growth between a number of smaller sites, within or on the edge of existing urban areas, and more work would need to be undertaken to determine precisely which sites are best performing and should be developed, if it did transpire that the Council's preferred approach is Option 5. We consider that non-strategic brownfield sites which are connected to, or close to urban areas, thereby providing sustainable urban extensions, should be considered as one of the preferred options for the delivery of the Council's housing requirement. This is necessary to ensure a flexible and responsive supply of land, and to prioritise the re-use of previously developed land in line with national policy.

Q3 - Site Reference: 141: Brentwood Leisure Park

Brentwood Leisure Park is brownfield land within the Metropolitan Green Belt, in Warley, south of Brentwood. The site extends to 7.825ha in total (with that area of the site excluding the wooded area) extending to approximately 5.6ha. That part of the site, comprising the existing leisure park, including dry ski-slope, driving range, outdoor karting centre, a restaurant, a vacant indoor leisure centre and car park, represents brownfield land.

As advised in our previous representations, the Leisure Park site could come forward for redevelopment in the short to medium term, should the existing uses become vacant or unviable in terms of their ongoing operation. The site represents an available location for redevelopment and is a suitable (previously developed) site for residential use, at such a time when the existing uses become vacant or unviable.

The site offers a number of benefits, which lends it suitably for future residential development. These are as follows:

- The site can sustainably accommodate residential development, supporting the borough's objectively assessed housing needs;
- The site is considered suitable for removal from the boundary of the Metropolitan Green Belt, on the basis that its characteristics do not fulfil the purposes of including land within the Green Belt;
- The site is well placed in relation to the existing built form, and constitutes previously developed land, and is therefore a suitable location for growth as an extension of the urban area; and
- The site currently contains dry-ski slope, driving range, and go-kart track, which do not contribute to the characteristics of Green Belts, and housing redevelopment has the potential to facilitate the provision of appropriate landscaping, which would contribute to the landscape value and the characteristics of the Green Belt in the surrounding area.

The SA undertook a sustainability appraisal of Option 5, as a whole, rather than individual sites. In order to inform the allocation of sites for housing development, sustainability of each sites considered under Option 5 would need to be assessed individually. Brentwood Leisure Park is a sustainable site, when assessed against sustainability criteria, and does not have many of the constraints as identified in the SA Site Specific Baseline Issues for Option 5, as follows:

- There is no Air Quality Monitoring Area in the surrounding area and road
network.

- The nearest station is less than 1.5 miles away (c. 1.2 miles). Additionally, the nearest bus stop, which provides bus serves to Brentwood Railway Station and the town centres, is within easy walking distance of the site (0.3 mile). Therefore, the site is accessible in terms of public transport provision.

- The site is accessible in terms of local facilities - the nearest local centre, including Post Office, and General Practice are approximately 1.1 miles and 0.9 mile from the site.

- The site is not within or adjoins Flood Zones 2 or 3.

- The site is previously developed land.

Accordingly, the site is considered to be more sustainable as a housing site than other sites under Option 5 or other strategic sites on greenfield and agricultural land.

As the site is very close to the existing urban area, it is considered suitable for removal from the boundary of the Metropolitan Green Belt, on the basis that its characteristics do not fulfil the purposes of including land within the Green Belt, as set out in the National Planning Policy Framework (NPPF). Accordingly, the removal of the site from the Green Belt boundaries would not alter the position in terms of:

i) Checking unrestricted sprawl;
ii) Preventing neighbouring towns from merging;
iii) Assisting in safeguarding the countryside from encroachment;
iv) Preserving the setting and special character of historic town in the locality, and
v) Assisting urban regeneration.

We therefore consider that Brentwood Leisure Park is an appropriate, suitable and sustainable site for housing development to deliver the Council's housing requirements, without undermining the fundamental aim of the Green Belt policy for the borough through preventing urban sprawl and encroachment to the openness of the Green Belt.

Q5 - Yes. As commented under Question 1, we consider that the A12 corridor area, which has the majority of the existing towns and urban areas, should be the focus for growth to meet the Council's housing needs. This should be realised through the release of sustainable sites on edge of urban areas, including appropriate brownfield sites within Green Belt, such as Brentwood Leisure Park (as detailed in our comments under Question 3). It is considered that sustainable urban extensions are in line with national policy, through prioritising the utilisation of previously developed and are necessary to ensure a flexible and sufficient supply of land.