Draft Local Plan
Representation ID: 15083
Respondent: Mr Darren Williams
The portal is confusing to find the online form and only allows 100 words.
Firstly, let me give feedback on just how confusing your portal is. It took me ages to find the online form to provide my response, and then it only lets me input 100 words. How ridiculous! If you get far fewer responses than you are expecting, I suggest it is because most people have given up!
Please find my full representation below.
I would like clearly state my opposition to the proposed plan.
Especially the proposal for the bulk of the development of 2500 houses in the proposed Dunton Hills Garden Village.
The issues associated with such a development are numerous and complex, requiring significant infrastructure and investment and I have outlined these in detail below.
I would also like to confirm that I attended the West Horndon Consultation workshop on the 7th March and have also stated by objections in person to the many planning officers in attendance.
It is clear that this consultation has been promoted to the residents of Brentwood Borough and yet has made no consideration at all to the residents of Dunton village and who will be directly affected by such a large scale development.
Whilst a separate study, it is clear from the Dunton Garden Suburb consultation that there is little desire for such a development with 84% of respondents objecting including strong opposition from Essex CC, Essex Wildlife Trust and Ford Motor Company amongst others. With 2500 houses proposed on the same site by Brentwood, and 2000 houses proposed by Basildon, then the area is Dunton Garden Suburb in all but name, so the strength of opinion I the DGS study should definitely be taken into account.
Brentwood Local Plan Specific Proposal Points
* Dunton Hills Garden Village (DHGV) is situated away from the majority of Brentwood infrastructure with poor access to Brentwood hospitals, shops restaurants & supermarkets, police, fire and sports & leisure facilities. Residents are naturally more likely to use Basildon amenities placing further burden on the Basildon area. The Local Plan vision is that the community will be self-sustaining but is by its nature isolated from Brentwood facilities.
* The Basildon local plan gives detail of how and where they will update road infrastructure to ease the congestion in their district. The Brentwood Local Plan fails to provide any detail leaving little confidence that it has a robust plan. In order to access Brentwood, DHGV will be forced to use the A128 which is already gridlocked most days with two severe pinch points at Hanging Hill Lane and Wilson's Corner.
* Further there are very few footpaths, cycleways and bridges spanning the A127 and A128 which would be needed to allow DHGV residents to access Brentwood district in the North and West.
* The Thames crossing route 4 proposes to use the same land for road links. This risk is not even considered as part of the local plan document
* To build 2000 houses on the proposed area would lead to significant density of housing which is completely at odds with the vision of a wide avenue, open space Garden Suburb
* Policy S09 states that Brentwood would look to safeguard greenbelt from inappropriate development and enhance its beneficial use, yet DHGV and the enterprise parks along the A127 would significantly reduce Green Belt at one of its narrowest point around London. The proposal may only reduce the Green Belt of Brentwood district by 1%, but it is doing so in an area where it will have huge implications for urban sprawl.
* There is opportunity to build in the land in the North of the A12 and create a new village away from existing villages to minimise impact on existing residents. Many of the reasons given for not building in this area - inadequate roads, lack of schools, GP facilities, landscape value, local character etc. also apply to the proposed area - impacting on views from Langdon Hills CP and Thorndon CP and impacting the character of Dunton Wayletts village.
* Development in the proposed DHGV area does not help in any way to make use of the new Crossrail link being extremely difficult to access due to poor and congested transport links. Concentration of development along the North-East corridor would make much more sense in this regard.
1) Green Belt
The proposed site is Green Belt land. According to the National Planning Policy Framework (March 2012), there are five stated purposes of including land within the green belt:
* To check the unrestricted sprawl of large built-up areas
* To prevent neighbouring towns from merging into one another
* To assist in safeguarding the countryside from encroachment
* To preserve the setting and special character of historic towns
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land
The remaining green belt along the A127 corridor is one of the narrowest bands around London already. The proposed enterprise development and the proposed housing developments would effectively remove the green belt, merging the sprawl from London through Brentwood and into Basildon.
Paragraph 89 of the National Planning Policy Framework states that a Local Planning Authority shall regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are (amongst others) buildings for agriculture and forestry."
Dunton Hills Garden Village proposal is clearly on Green Belt Land, is clearly not for agricultural or forestry use and therefore must be deemed as inappropriate construction as clearly stated in the ruling above.
2) Dunton Village Character
Dunton village has a longstanding history dating back to the doomsday book. It has significant history including the Colony, St. Mary's Church, Plotlands as detailed in these links:
Dunton has a village feel with many character properties including businesses located within the village that rely on a rural setting.
* The Old Rectory - relies on scenic nature and rural location for entertainment licence and for marriage ceremonies
* Friern Manor - another character property relying on the rural aspects of Dunton
* Dunton Park - mobile home park with mainly senior residents who value the peaceful setting and secure envronment
* Dunton Hills Family Golf Centre
* A number of farms including Dukes Farm and Sheddings Farm
Development would ruin the character of the village and the ability of these businesses to operate.
Development would also ruin the views that can be seen looking West and North West from Langdon Hills Country Park across Dunton to London and to Thorndon Park.
Dunton is already absorbing nearly 1000 homes in the Radford Park /Dunton Fields development. The intensity of the new development will place a significant burden on the resources and infrastructure of the area, and will lead to significant issues of integration with the existing community.
3) Significant Barriers to Proposed Development
a) Road and Pavement Infrastructure
It is clear from the draft plan that insufficient thought has been given to improving transportation support around the A127 / A128 and linking to Brentwood town centre. When I pressed your planning officers on this, they really had no tangible ideas of what could be done. They cited Essex County Council as being responsible, which may be true, but by the same token, Basildon have some very clear ideas about what road widening schemes and junction improvements are needed. Your planning officers also hinted that any new development would help to pay for improved infrastructure but admitted it was likely to come after the development itself. Given the near gridlock state we already find ourselves in, this seems an infeasible plan.
* The A127 cannot cope with traffic today. It is near gridlocked at morning and evening peak times every day. Widening is an absolute must and removal of bottlenecks at both the M25 junction westbound and the Fortune of War roundabout eastbound is required to aid traffic flow in the immediate area
* The A128 cannot cope with traffic between the A127 and Brentwood. Dunton Hills would significantly add to this traffic which would also impact the villages of Herongate and Ingrave. A new link would be needed to avoid isolation of residents in the new development.
* Dunton Roundabout also cannot cope with today's traffic. The business of the A127 causes traffic to queue back onto the roundabout. In periods of heavy rain both the westbound exit and entrance ramps become flooded which exacerbates the problem. In addition there is additional traffic from the Ford works in the morning and evening. The Ford morning traffic now queues onto the roundabout due to the new road layout to incorporate the Dunton Fields link road. The Link Road is not yet open but once completed will add significant further traffic to the roundabout.
* Dunton Roundabout issue is not limited to weekdays; when Dunton Boot sale is operating from Spring to Autumn traffic not only blocks the roundabout it also queues back onto the A127.
* Lower Dunton Road is a narrow road, not designed to take high traffic loads. There are areas so narrow that if a Lorry is coming the other way, it is extremely difficult to pass. The road currently has a 7.5 tonne limit, but the limit is not adhered to by HGVs today. Lower Dunton Road would be further used as a rat run if traffic congestion increases further. The addition of the container port at the southern end will increase the traffic flowing Northward and Lower Dunton Lane being a direct route to the A127 will take some of this burden.
* The existing Lower Dunton Road railway bridge is narrow and would need to be re-built and widened to allow anything larger than cars to travel down the route.
* The poor design of Lower Dunton Road Junction means that traffic wishing to travel towards Laindon has to go around the Dunton roundabout, adding further traffic volume to the roundabout. This junction would need to be re-designed with another roundabout to deal with the increased volume of traffic.
* Flooding - there are significant areas of Flooding on the roads in the area including:
o A127 sliproads - entry and exit
o Lower Dunton Road - Friern Manor
o Lower Dunton Road - opposite Church Road and into Church Road (very dangerous when icy)
o Lower Dunton Road - south of railway bridge
o Lower Dunton Road - at junction with Doesgate lane
* Footpaths and Cycleways - there are no footpaths or cycle ways linking Brentwood to the proposed development area. The current A128 and Dunton roundabouts are so busy they are completely unsafe for pedestrians and cyclists.
* Road crossings - there are no bridges to allow safe crossing of the A127 and the A128 in order to access Brentwood district to the North and the West.
* Footpaths - there are areas of Lower Dunton Road with no pavements. In order for residents to access the country park, pavements would need to be added as currently area from Dunton Park south to the Country Park entrance is extremely hazardous to walk along, with little or no protection for pedestrians.
* The proposed site is prone to surface flooding and waterlogging as it is Essex clay with no run-off. The only way for the water to dissipate is to eventually be absorbed back into the ground
* Building houses and reducing the amount of soak-away land will cause severe drainage problems in the area and with the wet winters we are having will cause extreme problems for new residents.
* Investment will be needed to develop a suitable drainage structure that can cope with the significant water levels experience on the site. There is no evidence in the local plan that the Environment agency has surveyed the area and deemed the area viable.
There is significant Biodiversity in the area.
* There are many mature Oak trees on the site in both coppices and marking boundaries for the fields. These should have preservation orders attached and in themselves provide a bio-system for Wildlife.
* I have evidence of the Great Crested Newt protected species in the area of the proposed development.
* Additionally, In accordance with the UK BAP (Bio-Diversity Action Report) I have seen the following priority species whilst living in the area:-
o Sky Lark
o Herring Gull
o Yellow Wagtail
o House Sparrow
o Hedge Accentor (Dunnock)
o Spotted Woodpecker
o Wood Warbler
o Common Starling
o Song Thrush
o Common Toad
o Significant fungus and toadstools - I'm no expert, but I counted twenty types in one area of woodland on the site alone
o Large Garden Bumblebee
o Crimson Underwing Moth
o Field Cricket
o Brown Diving Beetle
o Cinnabar Moth
There is no evidence in the local plan document that the following Natural England planning advice has been adhered to (i.e. that significant study has taken place to ensure the correct consideration has been given to wildlife in the area) -
There is significant recreational activity that takes place in and around the proposed development area.
* Particularly road cycling, which has attracted more interest since the 2012 Olympics / 2013 Tour De France. Lower Dunton Lane, Doesgate lane and the surrounding area provide scenic, rural, relatively low intensity traffic corridors for cyclists to use as a link between, Brentwood, Billericay, Bulphan, Orsett and the Horndons. The proposed development would add significant traffic to the area and make the roads less safe to cycle on.
Additional recreation in the area includes (but is not limited to):-
* Mountain Biking
* Walking / Rambling
* Horse Riding
e) Other Infrastructure
The resources in the area are not sufficient to sustain the significant increase in houses and people that development would bring.
* Secondary School - there is already a shortage of quality school places in the immediate area as Langdon Hills and Laindon West has no secondary school. Children from the area would have to migrate North to Brentwood County High or St. Martin's adding to the burden of school places and increasing traffic at peak times.
* Primary School - Further primary school places would be needed with West Horndon, Langdon Hills and Ingrave being the closest schools
* Nursery Care - given that the proposed development is designed to help with the Government housing framework to help cater for the shortage of homes in London, I would imagine that there will be many working mums who will need good Nursery care provision.
* Police - a suburb of the size and scale with significant affordable housing and gypsy provision will need visible policing to maintain security. As the suburb is being placed on the edge of Basildon and far from the centre of Brentwood, it is by definition further from police resource than many other estates in the area. Consideration should be given to adding police presence to the area and response times to emergency situations
* Ambulance and Fire. - Many of the above arguments in regard to response times for Ambulances and Fire Engines. Being removed from the main Basildon and Brentwood hubs will significantly increase risk to the proposed Dunton Hills site
o Basildon and Brentwood NHS are already failing most months to meet the 75% of responses within 8 min red calls in 2014 http://www.eastamb.nhs.uk/Performance/performance.htm
* Healthcare - In addition to additional doctor provision, new A&E capacity will need to be added to cope with the large increase in population. With Basildon Hospital to the South of the town and Brentwood Community Hospital to the North-East the residents of Dunton Garden Village will not easily be able to access emergency Healthcare.
* Internet - there is no high speed broadband in the area - which will need additional investment to install
* Electricity - is mainly by overhead lines and as a resident I can confirm voltage fluctuations and occasional black-outs. Significant investment is needed to install a new electric grid in the area.
o The existing pylons that run across the site would be both an eyesore and a health risk for residents, and again are not in keeping with the image of a Garden village
* Water and Sewage - 2000 homes will require significant additional capacity for water and sewage infrastructure and again significant investment is required.
f) Proposed Traveller Pitches
Whilst it is understood that the subject of developing new Traveller sites must be raised with any sizeable new development,
* The proposal of Traveller sites is not consistent with promoting a garden village atmosphere with an integrated community
* Better to site the pitches separately to reduce tensions - e.g. closer to the proposed enterprise areas