Comments Regarding
Brentwood Draft Local Development Plan - Issued Jan 2016

1)Introduction

I am pleased to have the opportunity to respond to the Brentwood Borough Draft Local Development Plan.
The Plan and the attachments and appendices are voluminous (hundreds of pages). Reviewing the documents had to be done on line as printing was impractical. The volume, copious use of abbreviations and jargon made reviewing it extremely difficult particularly when it came to cross referencing. I had hoped that visiting the drop in display at the Town Hall would have been of help. For example, I was unable to find details in the Plan on the future population and demographics of Brentwood. On approaching a council representative I was advised this was in an attachment however they were unable to find it. It has not been an easy task reviewing the Plan.
As a resident, in North Brentwood I have seen many changes over the years as the area's population has grown.
I particularly value the open countryside (Green Belt) and strongly support its protection. I regularly walk both Weald and Thorndon Park and use the extensive public right of ways which cross the district. Although I walk into town it is not a particularly pleasant experience due to the high volume of traffic which generate high levels of noise and pollutants. Until recently I frequently cycled, however the dangerous state of the roads ( e. g pot holes) and the high volume of traffic, which is often unsympathetic to the cyclist, has restricted this activity. As a motorist I experience the usual lengthy traffic jams and hold ups which clog up Brentwood during peak times and school term. The bus service to and from town is good however it is often late due to adverse traffic conditions.

2)Population Growth and Demographics

This whole plan is has been drafted to show how Brentwood District Council intends to cater for a 15% rise in population over an 18 year period to 2030.
The population growth primarily arises through inward migration, much of which will be from London. The Plan states that the Brentwood's present population is over 73,500 with a significant level of retires - an ageing population trend projected to continue. There are over 32000 properties 76% owner occupied, 63% being detached or semi detached; 58% being 3 or 4 bedroomed, 25% 2 bedroomed.
The only forecast I could find regarding population increases were in PBA Objectively Assessed Housing Needs, Appendix B SNPP 2012 Migration. This stated ' ---- the population of Brentwood is projected to increase from 74.0k in 2012 to 85.2k in 2030'. This is an increase of 15% (11,200 people), however 7200 dwellings are to be built giving an average occupancy rate of 1.6 people per dwelling. If this correct how does this reconcile with Figure 7.1 in the Plan?
Of the projected 7200 dwellings to be built figure 7.1, states that 65% will be 1 or 2 bedroomed. Clearly this implies a dramatic change in Brentwood's environment and demographic mix however the Plan is silent on the implications for infrastructure (e. g. highways, schools, surgeries). As stated in AECOM Sustainability report, some of these are already at capacity.
The plan is also silent on the social and economic effects of this population growth on existing and 'new' residents.







3)Highway Infrastructure

Looking specifically at Ongar Road; over the years traffic volumes have vastly increased as residential properties have been build both close to the town and in the outlying villages. There has been no major structural improvements to accommodate this increased volume save for the installation of mini roundabouts and bollards - which regularly get knocked over and do not get repaired for months. This situation is typical of Brentwood district; Shenfield Road, Ingrave Road, Doddinghurst Road, London Road and other highways all have similar issues.
The Highway Modelling exercise undertaken by PBA confirms that Brentwood roads have insufficient capacity to handle today's traffic volumes. (See section 11 Summary of Junction Outputs) I believe this modelling exercise understates the true size of the problem. Two periods were analysed, 0800 to 0900 and 1700 to 1800, no account has been taken of the effect of the school term when students exit between 1500 and 1600. Why not? During that time traffic in Brentwood centre comes to a stand still, even the paths have insufficient capacity to handle pedestrians. I also note no analysis was undertaken of the M25 junction 28. From experience there are frequent, long queues of vehicles waiting to gain access to the round about.
The Sustainability Appraisal by AECOM also identifies air quality/pollution issues in North Brentwood and Brentwood centre and raised concerns regarding Shenfield.
In short - the investment in public highway infrastructure, namely roads, cycle lanes and footpaths has been totally inadequate. As more dwellings get built the situation gets worse. The district has grown significantly but the highway infrastructure has largely remained as it was over 50 years ago.
The Plan states its policies regarding sustainability however it fails to identify any significant initiatives regarding highway infrastructure which address problems associated with traffic congestion and pollution, cycling or walking. Building more dwellings without properly addressing these issues first will be to the detriment of residents well being and employment prospects in Brentwood.


4)Green Travel Route

This Plan advocates adding public transport to the already congested A127 and A128.
The A128 is a very busy, narrow trunk road carrying passenger and commercial vehicles. At present, when stopping for passengers, buses cause hold ups particularly during school times and where there are no lay-bys. Adding more buses will slow traffic and create more noise and pollution for residents close to the road.
People do cycle along the A128 however it is a dangerous exercise as drivers have difficulty in overtaking and can become impatient. A cycle path would improve the situation.
Installing a 'Green Travel Route' would be a retrograde step, adding to the existing congestion and pollution and should not be actioned.


5)Public Rights of Way (PROW)

The Plan needs to actively consider the opportunity to open up access to the surrounding countryside and parks by investing in upgrading and creating footpaths and bridleways for non vehicular use. At present access routes to both Weald and Thorndon Parks encourages the use of cars at the expense of walking and cycling. Paths which cross the A12 and A127 are dangerous and recently there has been serious accidents involving pedestrians; public are reluctant to use them. The Ordnance Survey shows 6 PROWs crossing the A127 between the M25 and the Dunton intersection. Similarly there are 4 PROWs crossing the A12 between the M25 and Ingatestone.
To the North of the A127 footpaths provide access to open spaces and in particular Thorndon Park. Access to these areas from the south (Horndon and Basildon) is only practical using a vehicle. This is not satisfactory; building bridges over the A127 that connect the footpaths would enable none vehicular traffic to safely gain access to this wonderful amenity. Likewise a bridge over the A12 would enable people to move safely between Brentwood and Shenfield and outlying communities such as Pilgrims Hatch, Kelvedon Hatch and Doddinghurst. The paths would need upgrading to take cycles.
Weald Park is only 1 -2 kilometres from Brentwood centre yet walking or cycling to it using Weald Road and Weald Park Way is dangerous as the footpaths are not continuous, the traffic volumes high and the roads are narrow and winding. The paths should be upgraded and lengthened to enable pedestrians and cyclists safe access. The same could be said for Sand Pit Lane - a footpath is sorely needed.


6)Financial

Where are the financial figures that support this Plan? How can a plan be issued proposing such massive changes without some supporting financials e.g. infrastructure investment costs, impact on the tax payer.

7)Conclusion

The expansion of Brentwood District by over 20% through building 7200 new dwellings while increasing the population by over 15% (11,200 people) will have a dramatic effect on all aspects of life in Brentwood - social, environmental, commercial. It will change the nature and character of the area. Little demographic information is provided on who the new comers are and what their needs will be in addition to housing. It is hard to determine what benefit, if any, this expansion will have to present residents.
The draft plan is describes the proposed location of houses and the build schedule however I have major concerns over the need to upgrade Brentwood's infrastructure. My fear is the investment will not be forthcoming and policies relating to 'sustainability' will not be achieved. If that happens Brentwood will be a poorer place to live and work.

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.
Regards
Darren Williams

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:
* http://en.wikipedia.org/wiki/Dunton_Wayletts
* http://webdefence.global.blackspider.com/urlwrap/?q=AXicJcqxDsIgEIDhM77P0dTENk4OTq4OjgShoUR6h0CLrA4-hquvaRP_7Uv-zRa-L4DPGyD6umsUprjgpJzXTDmyR80TzO3pfB0el2bf9X0HwSsiRxYDe6fr8RYHyoXZoOUF5zuMOYeDEKUU9MqRYRpdyhwrcrTrILTKg10tnZGybVCl8IR_Px-9MQg&Z

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.


b) Drainage

* 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.


c) Wildlife

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 Bats
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 Adder
o Significant fungus and toadstools - I'm no expert, but I counted twenty types in one area of woodland on the site alone
o Hoverfly
o Large Garden Bumblebee
o Crimson Underwing Moth
o Field Cricket
o Brown Diving Beetle
o Cinnabar Moth
o Hedgehog

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) -
https://www.gov.uk/protected-species-and-sites-how-to-review-planning-proposals


d) Recreation

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
* Shooting
* Walking / Rambling
* Horse Riding
* Fishing
* Birdwatching
* Photography




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