brentwood.gov.uk

The consultation document proposes a large number of possible sites for the development of residential and business properties. The supporting evidence on critical strategic infrastructure is poor; indeed they are described as "interim" and leave many issues not assessed. Of these the flood risk assessment for the area of West Horndon is a key missing assessment. West Horndon is recovered fen land and as such has poor natural drainage which was made much worse when in the 1800s the railway line was constructed. Subsequent industrial and residential development has only made matters even worse. Over many years there have been a number of significant incidents with properties being seriously flooded. Following floods in the early 1980s surface water drainage was improved but the risk is still significant and during the winters of both 2012 and 2013 properties were once again flooded. The NPPF is very clear (paragraphs 94 & 100 - 103) that any development must take full account of flood risk before development is considered. Given the lack of detailed flood risk assessment it is impossible for anyone to come to a view on the use of any of the sites in the West Horndon area because they cannot understand the flood risk. Thus, I question if this consultation is valid given the public are being asked to comment on something that no one can take an informed view of because of the lack of supporting evidence. The spatial strategy identifies the A127 corridor as an appropriate location for the development of new homes and business and employment opportunities. At first sight this is a reasonable approach, however there is no supporting evidence that infrastructure in the corridor could cope with the additional load such development would create. Currently the A127 is at or over capacity much of the time as is the C2C railway line. Given that other local authorities are proposing development that would need to be supported by the transport infrastructure of the A127 corridor there is no clear evidence that it will be possible to upgrade the current road and rail systems to cope with the additional housing/business development being proposed in this consultation document. I should point out that the rail line is only two tracks and Fenchurch Street station only has 4 platforms. It is hard to conceive that a significant increase in capacity can be created as there is no physical room for more platforms at Fenchurch Street and the line west of Upminster runs through dense residential development and thus the opportunity for upgrade must be minimal. Similarly, the A127 (which is only two lanes in each direction) west of Upminster also runs through residential areas thus increasing the number of lanes to increase capacity must be questionable. While I recognise the upgrade of strategic transport infrastructure is not within the remit of BBC, developing a Local Development Plan (LDP) in the absence of information about the critical infrastructure is a nonsense. The LDP should make it clear that any proposal is totally dependent on appropriate infrastructure upgrades being planned and implemented concurrently with the proposed development. I also point out that the trains from Brentwood and Shenfield are on the new Cross-Rail line and thus the capacity is significantly improved. There are plans to upgrade much of the A12 to three lanes in each direction - so with respect to transport infrastructure corridors it is the A12 corridor that would seem most appropriate to consider for residential and business development opportunities than the A127 corridor. This site, south of the Grade 2 listed East Horndon Hall is being proposed for development as an industrial site. This land is Green Belt and thus any development is inappropriate. The NPPF clearly states that for development to take place in the Green Belt very exceptional circumstances need to be demonstrated. None are. This land is also subject to flooding - it regularly has standing surface water and acts as a storage buffer which prevents flooding of the surrounding land including residential areas. The planning application 17/01597/EIASO which first proposed this site for development as a business park includes a surface water flood assessment which only looks at a superficial level at the site itself. This is contrary to the NPPF (paragraph 102) which requires a flood risk assessment that demonstrates that any such development does not increase flood risk elsewhere. Given the history of flooding in this area (properties were flooded, and the main road blocked in December 2012) this site is clearly inappropriate for any development. These now aging industrial sites are appropriate for redevelopment and redevelopment to residential (or part residential) use is appropriate for this brown field land. In broad outline I support these sites being redeveloped. However, there are a number of concerns that must be taken into account. 1. Access - the current access arrangement date back to the late 1930s when the site was first built. The amount of traffic in those days was significantly lower than today. The current land use means that much of the traffic is large HGV lorries which are large and easy to see. Redevelopment to mixed residential and business use will increase the number of cars and light van traffic which will increase the risk of accidents. There already a large number of small shunt accidents in the vicinity of the entrance to this site. Thus, it is imperative that before any redevelopment takes place vehicle and pedestrian access is properly resolved; 2. West Horndon is a rural community and the development must be sympathetic to this. This site is quoted as being 17.06ha. Given that rural residential development should be at about 30 properties per hectare the 580 quoted seems to be very much at the top end of the appropriate number; 3. Although West Horndon is identified as a transport hub on account of the Railway Station, access is only east/west so most residents will definitely need cars. It is imperative that the design of the site is such that car parking is at a higher level than is normal for transport hub locations. West Horndon already has significant residential parking problems and this redevelopment must not make that worse. Thus, the design and number of properties must be able accommodate sufficient parking. Design is for the normal planning process, but I would suggest that for the strategic purposes of the LDP the number of properties should not exceed 500 - reduced as necessary according to how much of the site remains in business employment usage. Broadly I support the development of these sites for employment. They are situated close to the M25 as a major transport link and their use especially for enterprises which use large amounts of HGV traffic would be welcomed as that would reduce HGV traffic through residential areas like the village of West Horndon. There are potential issues about access to these sites for staff working there, there is at present no public transport access. This detail will need to be dealt with at the full planning application stage. This area is Green Belt and thus development seems inappropriate. However, I do recognise that Brentwood is ~89% greenbelt and that opportunities for non-green belt development are limited. Given the strategic housing allocation central Government is imposing on BBC this area probably needs to be considered as an option. I point out that green belt to the north of the Borough is open and that development in such areas could be undertaken to make an isolated village(s). The Dunton Hills site is almost the last green belt gap between Upminster (London) and Southend thus the development of this site would basically create continuous development between London and Southend. This would seem to be contrary to the principles set out in the NPPF. I also question the ability to construct sufficient transport infrastructure to support the development, but I can find no assessments examining this situation in appropriate detail. However, given the situation BBC finds its self in Dunton Hills Garden Village (DHGV) may be the least worst option to meet the strategic housing allocation. If this is to proceed it must be done in such a way that the impact on the surrounding area and communities is limited to a minimum. To this end the western side of the site needs to be restricted and turned into a buffer zone e.g. by creating a woodland. This would have the effect of visual separation between the two villages and would also mitigate some of the potential flood risk that the development would create. It would also make future attempts to expand the development and join the two villages much more difficult. This approach is consistent with the guidance in the NPPF for change of use of green belt land. I suggest that the site map is modified to make it clear that there must be a buffer zone between the DHGV and the A128. If this development does proceed it will generate traffic between it and the railway station in West Horndon. Parking is already a problem in the village of West Horndon and it is essential that means to minimise and manage this are sought and incorporated at the very outset of planning. The current plan suggest that the required G&T site are developed and located adjacent to new residential developments as they are constructed. My understanding from the results previous consultations is that G&T communities prefer sites to be away from business and residential areas. Indeed, one G&T site situated just north of the A127/A128 junction has to my knowledge not been used in over 30 years. I understand this is because it is too close to other developments. This aspect of the site plan allocation needs a total rethink.