brentwood.gov.uk

RESPONSE MADE VIA OBJECTIVE CONSULTATION PORTAL TO DUNTON GARDEN SUBURB CONSULTATION

RESPONSE TO CONSULTATION ON DUNTON GARDEN SUBURB STUDY

Herongate and Ingrave Parish Council supports the principles set out in the National Planning Policy Framework for the protection of the Green Belt to prevent urban creep. We strongly oppose inappropriate development in the green belt except in very exceptional circumstances where the benefits clearly outweigh the harm and we also support the view that housing need alone does not constitute exceptional benefit

However, we acknowledge the challenge that the Strategic Housing Allocation numbers present to Brentwood Borough Council. We recognise that without clear locations for the necessary houses identified by the Strategic Housing Allocation, Brentwood Borough Council will be highly unlikely to have a robust Local Development Plan approved. That presents the risk of aggressive speculative developers attempting to obtain planning approval anywhere in the borough and that the appeals system could result in inappropriate and poorly coordinated development taking place.

Thus in the unfortunate circumstance where Green Belt does have to be sacrificed in order to meet the statutory obligations of the Strategic Housing Allocation, it is essential that only the minimum amount of land is sacrificed and that this is done in locations and in such a way that harm and urban creep is kept to an absolute minimum.

The Parish would be seeking an assurance that, in arriving at a robust Local Development Plan, the Green Belt around the villages of Herongate and Ingrave, will be confirmed and protected in the long term, to prevent coalescence with surrounding residential areas.

Whilst we readily understand that the current examination by Brentwood Borough Council is an early study, this Council feels the need to identify and highlight the issues that we can foresee will require more thorough examination and subsequent consultation before progress can be safely made.

The Objectively Assessed Housing Needs study is of fundamental importance to this process. Unfortunately there appear to be several flaws in the published description of the study that suggest that the degree of reliance on the present study may well be misplaced.

The various component data sources have very different degrees of currency
In one case the evaluation trend period is both too short and completely atypical
Where individual approaches produce a range, the highest figure has been chosen
The local housing need is the only item having proven relevance and accuracy
The derived housing need is potentially, at a minimum, double, at worst up to six times the actual level.

If the issue of need is put on one side, infrastructure, community requirements, effects on the environment and ecology would be the most significant areas for careful planning.

Highways: The local main roads (A128, A127) have a very major effect on the life of the residents in Herongate and Ingrave. At present the A128 is very heavily loaded during peak hours. Any holdups on the M25 or the A414 have the effect of compounding these problems. A population increase of some 20,000 in the southern parts of the Borough dependent on the A128 for north/south travel would cause gridlock daily. Utilisation of small greenbelt sites within the villages for development, with associated junctions with the A128, could only exacerbate the problem.

Transportation: C2C have announced that they have no plans to build a new station to service any new housing in Dunton. West Horndonstation car park barely copes with present needs. Cross Rail will therefore attract even more vehicular traffic through our Parish. Public transport improvements, desperately needed currently, would be vital as soon as building begins if a dependence on motor vehicles is not to build.

Education: Secondary education would apparently be dependent on existing schools. This would typically mean yet more, peak time, loading on the A128. However it would, in addition, require much development work on the existing secondary schools which are heavily loaded. Primary schools would need to be built in anticipation of the population of the Suburb; there is very little spare capacity in local Primary schools.

Infrastructure: Energy, water, sewerage and communications all fall outside the normal planning process (the Utilities are supposed to fix this) so always run decades behind the real needs of the community. There must be a better way.
Community Infrastructure: General Practice and Hospital facilities are extremely stretched at present. Health centres might be planned for and finance achieved but it seems highly unlikely that the NHS would be able to respond with hospital coverage, for such major growth in local population, in realistic time scales. Home care facilities are extremely scarce today in this area; how much worse it would be if 6000 more homes were built. More general facilities, such as community halls, entertainment, shops, etc. are also vital to the development of a real community.

Environment: Green spaces for both humans and wildlife are essential elements in building a good place to live. Without a thorough consideration of the needs and welfare of both parties in the equation, and appropriate provision for both, it will not be possible to achieve the desired result.

Sustainability: It is a demonstrable fact that major projects such as this rarely generate the funding that a viable community needs. It is even rarer for the vital facilities for sustainability to be provided in a timely manner. The longer the delay in provision, the less sustainable the community will be. For example, the fewer the public transport facilities the greater the dependence on the car; once the habit is ingrained too late provision of public transport will fail. Only thorough planning, strong contracts with developers and proper consultation between interested parties can produce a satisfactory and sustainable project.