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Draft Local Plan

Chapter 1. Introduction

Representation ID: 14404

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Pattern Book & Other Documents

Representation ID: 14406

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand.
Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

All Development

Representation ID: 14407

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

Paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Settlement Category 4: Smaller Villages

Representation ID: 14408

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Figure 7.5: Gypsy & Traveller Sites With Temporary Permission (January 2016)

Representation ID: 14409

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Policy 5.2: Housing Growth

Representation ID: 14410

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

there are a large number of dwellings that are to be provided under the "windfall" allowance. Concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those areas listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council recommend that the non allocated site list is refined, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Policy 9.9: New Development, Extension and Replacement of Buildings in Green Belt

Representation ID: 14411

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Policy 9.12: Site Allocations in Green Belt

Representation ID: 14419

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

Para7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and Para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages

With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Policy 7.5: Affordable Housing

Representation ID: 14420

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

Comment

Draft Local Plan

Policy 6.2: Managing Growth

Representation ID: 14423

Received: 18/04/2016

Respondent: Doddinghurst Parish Council

Representation Summary:

Is there anything that can be done in the LDP to close these loopholes that are regularly exploited?
(i) The "Agricultural Business". Is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g. a stable. An application will be lodged for some form of building where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) Large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.

Full text:

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

Attachments:

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