A127 transport route is not capable of sustaining the volume of development proposed and will make life for residents a misery

The two main terminus points of our two main transport corridors (A127 & A127) namely A12 junction w M25 (Brook Street) and A127 junction w M25 are not up to capacity, especially Brook Street. We should not be adding more development (and thereby traffic growth) to Brentwood without improving traffic flows at Brook Street. The bottle neck already exists at peak hours.

Has the proposed Thames Crossing been taken into account?

Thames Crossing

Whilst not specifically mentioned on the plan as far as I could see, I think it needs to be considered now as Brentwood is effectively on the proposed new crossing route via the A128.

Have you considered the impact of the new proposed Thames crossing at all?

As I understand it the preferred route will have a junction to the A128. As you are probably aware, that road works its way north through Brentwood. Has any provision been made for the "mega" extra traffic, especially extra lorry traffic that will no doubt travel up this road as an apparent shortcut north, instead of heading round the M25? Again, has the extra pollution, noise and congestion that this crossing will undoubtedly bring to Brentwood been considered in this plan at all? If not, I think it needs to be.

Apart from the impact this new crossing route will have on the existing local residents, you are possibly planning to build houses very close to one of the possibly affected areas.

Indeed, can provision ( height/width restrictions for example ) be put in place to stop articulated lorries from using the A128 through Brentwood? or even better still, remove the junction with the new crossing altogether to discourage all extra traffic from the new crossing?

If there are problems on the M25 now the A128 can get blocked, but with the apparent proposed new route of this new crossing, that can only get much worse ( areas like Wilsons Corner for example ).

Brentwood has identified an objectively assessed need for housing of at least 330 homes per year. The town of Brentwood is one of the most expensive towns for housing in Essex so there is an urgent need for affordable housing especially for key workers such as nurses and teachers. Almost all its heath care facilities and secondary schools are to be found along the A12 corridor so it is there that the main need arises. Furthermore it is the A12 corridor that is receiving the benefit of transport infrastructure investment such as Crossrail and A12 widening.

In contrast the A127 has very little social infrastructure provided by Brentwood and there are no plans for secondary schools near the A127 in Brentwood. The council claims that the A127 has a better potential for infrastructure improvements but the reality is that there are no funds designated for the purpose and with the present need for austerity it is highly unlikely that any improvements in capacity for the A127 or the nearby rail tracks can be funded for completion within the timescale of this local plan. The emerging local plans of Basildon will already place enormous extra strain on the infrastructure along the A127 no prospect of the necessary widening of the A127. Planning policy requires that adequate infrastructure funding for the next five years must be found before development can proceed. This will not be possible for the A127 corridor.

Transport links between the A127 corridor and the A12 corridor are especially constrained. The only rail links require travelling via Upminster and Romford or Southend with changes between different lines. By road the choice is between the A128, the M25, routes through Billericay or the A130. The M25 and A130 are high quality roads but they often suffer congestions and are considered a long way round. The A128 takes traffic through Ingrave, Herongate and then Brentwood itself. These areas are already congested and the A128 is not a high quality road. Options through Billericay also pass through towns and villages and even use single track roads for quickest travel to places such as Ingatestone. It is therefore hopeless to think that people living near West Horndon or Dunton can conveniently travel to the A12 corridor for work or school.

In the light of these constraints on travel it is completely wrong to try to meet Brentwood's housing need by building most of its new housing South of the A127. It is absolutely certain that when this plan is submitted to the planning expectorate it will be rejected as unsound for this reason. This will require Brentwood to rewrite its plan with much more housing concentrated along the A12 and there will be a need for new regulation 18 consultations. There could be a delay of two years to prepare a new plan during which time Brentwood will be subject to government intervention and or developers able to submit applications anywhere they wish. Brentwood will be unable to defend against this especially in light of its precarious financial situation which will be made worse by the loss of revenue from the New Homes Bonus. In short Brentwood's plan to build south of the A127 instead of along the A12 corridor will be an unmitigated disaster for the Borough. Brentwood council has betrayed the trust of its residents with this horrendous Local Plan which completely fails to meet its housing needs along the A12.

I attended the recent consultation meetings and agree with the proposals of housing and development of the Dunton Garden village and A12/127 corridor.
Glad to see that the majority of smaller villages have not been for major changes. Change needs to be near where work/transport links are available, especially with regards to housing.

5:22 - 1% is still a lot of green belt land to destroy. What about the wildlife that live in that 1%?? For them this is literally a matter of life and death.
You also do not give any actual sizable figures - for simple people, 1% doesn't seem very much (hence why you've specified it that way no doubt) but if people knew you were actually talking about 50 square miles (for example) then they might think differently.

Part b: ANY impact on green belt land is significant for the wildlife in that area.

Whilst we support elements of the spatial strategy as set out in policy 5.1, we do not believe that this strategy has been carried through into the allocations and detailed policies. We do not support other elements of the strategy. Specifically the reliance on a new settlement to deliver a significant proportion of the Borough's needs and the decision not to release any Green Belt sites adjacent to Larger Villages in the A12 corridor.
We support the strategy to focus development within the transport corridors with Brentwood and Shenfield being the main focus, however, we do not support the reliance two strategic allocations in the A127 corridor to deliver the Borough's needs.
Whilst the spatial strategy suggests Brentwood and Shenfield will be the main focus for development, urban area site allocations total only 1,266 dwellings. This is significantly lower than the so called "supporting" strategic allocation of 2,500 new dwellings, which comprises 35% of the Borough's housing requirement. Other Greenfield urban extensions account for a further 1,292 dwellings and Green Belt brownfield 97 dwellings. It is clear from the numbers alone that the focus of development is not, as stated in the spatial strategy, Brentwood and Shenfield, but Dunton Hills Garden Village in the A127 corridor.
Dunton Hills Garden Village does not support the strategy, it underpins it and the strategy relies upon it. Elsewhere in consultation document Dunton Hills Garden Village is described as delivering a "significant proportion" of need and being "critical to delivering the Plan's key development objectives".
We strongly object to the strategy to rely on a new settlement to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. Instead we suggest greater variation in the portfolio of land available for residential development and in particular a greater number of smaller site allocations.
Smaller allocations increase the flexibility that is in supply, attract smaller house building companies who will not be present upon larger strategic sites, ensure that there is variation in the timescales over which sites can be delivered and provide the consumer (i.e. the future resident) with choice about where they live.
Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have less complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take an average of five years to deliver, from submission of a planning application.
As such, we support the release of smaller Green Belt sites within the transport corridors to meet local needs fully and provide development quickly. We also support the strategy for limited development in villages. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. It is also logical to allocate a range of site types and sizes as opposed to rely on larger strategic sites only.
We object to the decision not to allocate any sites surrounding Larger Villages, specifically at Mountnessing.
Mountnessing lies within the A12 corridor, which the spatial strategy claims to be the focus for development. It is also a sustainable settlement, being served by a local shopping parade and primary school.
However, no sites have been allocated save for existing permissions. Conversely, allocations have been made in Brentwood, Shenfield and Ingatestone, which are also in the A12 corridor.
The explanation for this departure from the spatial strategy appears to be due to Mountnessing occupying a lower position in the settlement hierarchy and/or the existence of recently granted planning permissions. However, to exclude allocations based on the settlement hierarchy is inconsistent compared to treatment of other settlements in this category and in the A12 corridor. Furthermore, the recently granted consents do not serve the needs of Mountnessing.
Mountnessing has been categorised as a "Larger Village" where, according to paragraph 5.33, no Green Belt alterations are proposed "in order to retain the character of the Borough in line with the spatial strategy".
Other Larger Villages are Blackmore, Doddinghurst, Herongate, Ingrave, Kelvedon Hatch and West Horndon.
Blackmore, Doddinghurst and Kelvedon Hatch are in the Rural North where the spatial strategy does not claim to focus development. It allows for only limited infilling at a level commensurate with services and facilities available. To exclude allocations from these settlements is consistent with the spatial strategy.
Similarly, Herongate and Ingrave are in the rural south where the same strategy exists and are therefore also logical exclusions.
The only other Larger Village within a transport corridor, where the spatial strategy seeks to focus development, is West Horndon in the A127 corridor. Whilst no Green Belt boundary change is made, the existing industrial estate is allocated for redevelopment, to deliver 500 new dwellings.
Ingatestone has sites within the urban area, plus both greenfield and brownfield sites outside of the urban area, proposed for delivery of 128 dwellings. Ingatestone, as Mountnessing, lies in the A12 corridor focus for growth area.
Ingatestone has been categorised as a "Village Service Centre" as the Borough's largest village. However, we question whether it occupies a higher category than Mountnessing and the other Larger Villages as a means of setting it apart in order to justify alterations to the Green Belt boundary. Whilst it is larger than the other Larger Villages and benefits from a greater service provision, it stands alone as the only settlement currently within this category. Whilst Dunton Garden Village and West Horndon are proposed to be included later in the Plan period, this is as a result of the development proposed through this Plan.
It is our strong opinion that being a sustainable settlement in the A12 corridor Mountnessing should be treated in the same way as Ingatestone and West Horndon and allocations for a modest level of development should be made. This would be consistent with the spatial strategy to focus development in the Borough's transport corridors and ensure that both the local and Borough's needs are met in the early years of the Plan. With no brownfield redevelopment opportunities, this would necessitate Green Belt release to comply with the spatial strategy to focus development in the transport corridors.
Paragraph 5.19 and figure 5.7 provide an explanation as to why no sites have been allocated at Mountnessing; that planning permission has already been granted for 172 new homes. Paragraph 5.19 states that these will "make a significant contribution to the Borough's needs" and figure 5.7 that they "will contribute to village life".
However, we object to the reliance on these sites; they do not make a "significant" contribution to the Borough's needs and they do not serve the needs of Mountnessing due to their physical separation from the settlement and lack of affordable housing provision.
The Borough's housing need for the Plan period is 7,240 dwellings. At only 2.4% of the Borough needs, 172 homes cannot be said to be a "significant" contribution.
Thoby Priory (15/00527/OUT) lies approximately 1km to the north of the Mountnessing village boundary, in open countryside. Whilst the highways support is subject to a condition to provide a new cycle and footway linking the site to Mountnessing, this does not change the physical separation of the site or guarantee sustainable movements between the site and the village.
The second site is the former scrap yard (14/01446/EIA) which lies approximately 700m to the south west of the Mountnessing village boundary, adjacent to the A12 junction. The highways condition for this consent also requires construction of a new cycle and footway.
Thoby Priory does not have planning consent; it is still subject to a resolution to grant. Whilst it is appreciated that this doesn't necessarily render the site undeliverable, it does raise questions, particularly since the delay in signing the section 106 agreement is due to viability testing in relation to affordable housing provision.
The proposal which went before the committee was for 87 market dwellings and no affordable housing. This was subject to a satisfactory Viability Assessment in support of this. A recent telephone conversation with the case officer confirmed that the Viability Assessment has not yet been agreed and nor has any Extension of Time. As such, there is no certainty of timescales for granting of consent or delivery of the site. Indeed, the case officer indicated that should no agreement be reached regarding the Viability Assessment, the application would have to be returned to committee.
Assuming that agreement can be reached and the permission granted as per the committee report, the site will deliver no affordable housing and no commuted sum for off-site provision. As such, it will not deliver local needs.
The former scrap yard site has planning permission granted for 85 residential units with a section 106 agreement to provide 24 of these dwellings as affordable dwellings on-site plus a financial contribution to provide a further 8 affordable dwellings off-site. It is not clear whether a specific site for the off-site provision has been identified and we are not aware of any sites for this purpose in Mountnessing.
Combined, these two sites provide less than half of the required level of affordable housing so fail to meet the localised affordability needs of Mountnessing and those of the Borough.

Paragraph 7.9 of the Draft Plan is unequivocal that there is a "significant need for additional affordable housing" in the Borough. This is evidenced by the SHMA.
Policy 7.2 requires residential development proposals to "provide an appropriate mix of dwelling types, sizes, tenures and specialist accommodator to meet the specific needs of existing and future households in the Borough"
Policy 7.5 requires a minimum of 35% of affordable housing on sites of 11 or more dwellings to be provided on-site, with only fractions being provided through a financial contribution. This allows for situations where the full affordable requirement cannot be provided and requires the developer to provide evidence as to why it is unviable and negotiate a level of affordable housing provision which is achievable.
Under this emerging policy, of the combined total of 172 dwellings with permission/resolution to grant in Mountnessing, 60 would be required to be affordable housing. However, these sites provide only 24 on-site affordable dwellings, or 14%. This falls considerably short the 35% required. Even if the additional 8 dwellings are included (which it is assumed will not be provided in Mountnessing since no amendments to the village boundary are proposed), the provision would be only 19%.
Whilst it is appreciated that as brownfield sites, the reduction in affordable housing may well be justified on viability grounds, this does not change the fact that there is an under provision of affordable housing for Mountnessing under the Draft Plan.
Mountnessing Parish Council objected to the Thoby application on the basis of a lack of affordable housing, confirming that the development, "...will not address the current situation where even small houses are unaffordable for many people especially the younger generation."
This underprovision of affordable housing is an unsound approach since it fails to meet the policy tests within the NPPF (which requires the needs identified in the SHMA to be met) and those of the draft Plan itself. As such, additional greenfield land must be released adjacent to Mountnessing, which will be able to deliver this affordable need.
Allocation of additional land for housing at Mountnessing would not only meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services. Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, including high vacancy rates in the three retail units within the village and led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).
One such suitable site is Land Adjacent to Mountnessing Primary School, (site 073 under the Strategic Growth Options Consultation and SHLAA site G093). Previously promoted by Crest Nicholson under an option agreement, it is now being promoted directly by the Landowner with Sworders acting as Planning Consultants on the Landowner's behalf.
This site could be sensitively developed to provide short term delivery of much needed private and affordable homes of up to 18 units.
The site is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact, it would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary. It is situated close to the existing retail units and is thus more likely to support these than the two recently applied for developments at Thoby Priory and Mountnessing Roundabout, which are some distance from the village. Occupants of these two new developments are far more likely to drive directly to higher order facilities in other towns than residents who live within easy walking distance of existing village facilities.
The site adjacent to Mountnessing Primary School does not serve any of the purposes of the Green Belt in accordance with the NPPF and no constraints have been identified that would prevent its development for residential use.
The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan period. This site is identified as the only suitable residential site at Mountnessing.
As such, Land adjacent to Mountnessing Primary School should be allocated for residential use to serve the needs of Mountnessing and contribute towards the Borough's needs.

Policy 5.1 Spatial Strategy

Since these submissions were made (February 2015) Historic England have issued its own Advice Note 3 'The Historic Environment and Site Allocations in Local Plan' (issued October 2015).

This guidance establishes a five stage site selection methodology for site selection which includes,

* Step One - Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
* Step Two - Assess the contribution of the site to the significance of heritage assets on or within its vicinity
* Step Three - Identify the potential impacts of development upon the significance of heritage asset
* Step Four - Consider how any harm might be removed or reduced, including reasonable alternatives sites. This also involves consideration as to how any enhancements could be achieved and maximised
* Step Five - Determine whether the proposed site allocation is appropriate in light of the NPPF test of soundness.

Historic England drew attention to this methodology in the January 2015 consultation response and can now confirm it has been formally published.

This Advice Note can be accessed at

https://content.historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans.pdf/

I do not consider ANY release of green belt necessary. As previously described, a policy of requiring all new developments to be high-density, and not imposing a needlessly high target (the NPPF makes clear that the green belt is adequate defence against meeting an 'objectively assessed' target), would obviate the need for a single square metre of green belt to be lost.

For example, building a few skyscrapers on top of the car parks at Shenfield station would go a long way towards meeting development needs, and would not unreasonably overload infrastructure, given the exceptionally good connections from Shenfield station.

These are some of the objections I uphold on the proposed development around Dunton. It's very nature as Green Belt in an area South of the A127 which has very limited Green Belt, makes it value as such much higher than that in areas of lots of Green Belt, such as the more Northern parts of the Borough. Any development around the Dunton area foisters Brentwood's problems onto the people of Basildon, as the development would be isolated from the rest of the Borough by the major barriers of the A127 and the A128, and possibly also a new Lower Thames Crossing. Green Belt doesn't have a value because of it's leafy green views, it has a value based on its benefit to the health and mental wellbeing of surrounding areas, and its ability to stop the spread of urban sprawl. In an area already very over developed, such as the south of the A127 around Basildon towards Southend, and Upminster towards London, the small patch of Green Belt may be a drop in the ocean of the large amount of Brentwood's Green Belt (almost twice that of Basildon), but its rarity in that particular location stops everything south of the A127 becoming the London Borough of South Essex.
The development is not only bad for the existing surrounding population, but the new residents would suffer as they wouldn't have access to amenities. It would be in breach of rules on placing traveller sites within areas of easy access to medical and educational facilities. The wildlife of the area would be destroyed, as it is in the middle of the corridor between the Essex Wildlife Trust and Thorndon Park. That much concrete being built would increase the risk of flooding in an area already prone to surface water flooding. The increased pollution levels in the area from the cars from 2,500 homes in such a confined area, as well as the number of vehicles required during any building process, would be bad for the health (asthma, COPD, etc) of existing and new tenants, as well as any wildlife.
Chapter 4 - Strategic Objectives
Representation
SO7 - You claim you want to 'Optimise the social and economic benefits that arise from Crossrail for the benefit of residents, businesses and visitors to the Borough', yet you dump most of housing needs that would benefit from Crossrail south of the A127, where there are numerous problems with the C2C line, the houses would not be near a station anyway, as the A128 would create a barrier which requires residents to drive and park at either Laindon or West Horndon. A quick check on the C2C twitter and Facebook pages would tell you how many problems they have. The 2,500 houses planned for Dunton, and the 500 houses planned for West Horndon would be cut off from good transport needs, with or without the proposed Lower Thames Crossing Option C Route 4 being built, which will only add to their isolation if it went ahead.
SO8 - You claim will 'Promote and support a prosperous rural economy' yet you propose to build half of your housing allocation on Green Belt agricultural land, South of the A127.
SO9 - You claim you will 'Safeguard the Green Belt from inappropriate development and enhance its beneficial use', yet you propose a massive inappropriate development of the very limited supply of Green Belt South of the A127. It has greater value as there is less of it. The National Planning and Policy Framework states that that Green Belt is there to check unrestricted sprawl, and to prevent neighbouring towns from merging. The limited supply of Green Belt land in the area between Brentwood and Basildon South of the A127 is very limited, and both councils propose building up to the boundaries, thereby creating unrestricted sprawl, as well as merging neighbouring towns. South of the A127 there will be virtually no Green Belt separating the London Borough of Havering all the way to Southend. The Green Belt is also supposed to be there to assist in in safeguarding the countryside from encroachment, and preserving the setting and special character of historic towns, yet you propose to build on the only bit of countryside South of the A127, when there is plenty across the rest of the borough. On a Supply and Demand basis, the Green Belt has a far higher value South of the A127 because of its rarity. Also, it preserves the character of Domesday Book villages like Dunton, West Horndon, Herongate and Ingrave, by preventing the development of the small amount of remaining Green Belt in that part of the Borough.

Chapter 5 - Spatial Strategy
Evolution of spatial strategy
Representation
You still fail to show a true picture of Herongate being directly affected by the A127 because of its very close proximity, therefore making it part of the A127 corridor. The A127 has excessive congestion on the road, and the C2C line has transformed from a good service to its original title of the Misery Line in a matter of months. it does not have the capacity for any additional customers at West Horndon, which is the only station within Brentwood Borough on the C2C line. National Rail had already confirmed last year that they had no intention of adding an extra station in any new development, so all residents of developments around the Dunton area would be solely reliant on their cars on the heavily congested A127. If the proposed Option C Route 4 gets the go ahead then the development would also be underneath a four to six lane carriageway in one direction, and an eight to ten lane carriageway in the other direction, completely cutting the development off from any Brentwood services. This means that Brentwood residents would be completely reliant on their Basildon neighbour's facilities, which are already stretched beyond capacity. You propose development around the A127 because you claim the Brentwood Urban area and North of the Borough has congestion, a lack of primary schools, GP facilities, and a higher landscape value. In actual fact, the A127 and South of the Borough suffers severely from congestion, not only on the A127 and local roads around West Horndon, but also on the Herongate and Ingrave area, that has been fighting a Twenty's Plenty campaign to improve safety on the heavily congested roads. There are no more services in the South of the Borough than the North, and a new development won't deliver new GPs and schools until well into any development, putting a strain on surrounding areas, particularly Basildon, as the natural boundaries of the A127 and A128 will prevent any residents from the Dunton area even getting to West Horndon, let alone the rest of the borough. The claim that there is a higher landscape value elsewhere is ludicrous, as quantity doesn't equate to quality. The sheer lack of Green Belt and green spaces around the A127 corridor increases the value to the residents spiritual and physical well being

Draft Plan Spatial Strategy
Representation
You still fail to show a true picture of Herongate being directly affected by the A127 because of its very close proximity, therefore making it part of the A127 corridor. The A127 has excessive congestion on the road, and the C2C line has transformed from a good service to its original title of the Misery Line in a matter of months. it does not have the capacity for any additional customers at West Horndon, which is the only station within Brentwood Borough on the C2C line. National Rail had already confirmed last year that they had no intention of adding an extra station in any new development, so all residents of developments around the Dunton area would be solely reliant on their cars on the heavily congested A127. If the proposed Option C Route 4 gets the go ahead then the development would also be underneath a four to six lane carriageway in one direction, and an eight to ten lane carriageway in the other direction, completely cutting the development off from any Brentwood services. This means that Brentwood residents would be completely reliant on their Basildon neighbour's facilities, which are already stretched beyond capacity. You propose development around the A127 because you claim the Brentwood Urban area and North of the Borough has congestion, a lack of primary schools, GP facilities, and a higher landscape value. In actual fact, the A127 and South of the Borough suffers severely from congestion, not only on the A127 and local roads around West Horndon, but also on the Herongate and Ingrave area, that has been fighting a Twenty's Plenty campaign to improve safety on the heavily congested roads. There are no more services in the South of the Borough than the North, and a new development won't deliver new GPs and schools until well into any development, putting a strain on surrounding areas, particularly Basildon, as the natural boundaries of the A127 and A128 will prevent any residents from the Dunton area even getting to West Horndon, let alone the rest of the borough. The claim that there is a higher landscape value elsewhere is ludicrous, as quantity doesn't equate to quality. The sheer lack of Green Belt and green spaces around the A127 corridor increases the value to the residents spiritual and physical well being

Housing
Representation
Re: Dunton area. This is an area of Green Belt, and there is not enough evidence put forward to show why over 1/3 of the Borough's allowance should be dumped where it goes against the rules of Green Belt, preventing Urban Sprawl, etc. Developing there, and the 500 homes planned for West Horndon, together with the unspecified number of traveller sites, etc, means that there will be virtually no Green Belt left between the London Borough of Havering and Southend. The case has not been shown that adequate facilities would be put in place for any development, prior to people living there, so they would rely heavily on the neighbouring borough of Basildon. This means that there is no more supply of facilities than anywhere else across the borough, and it is probably easier to add one extra GP to an existing surgery, etc, than to build a new surgery before anyone lives in a location. The natural barriers of the A127 and A128 means that residents would be denied medical and school facilities until a long time after they had moved in, if they are ever provided in sufficient numbers. There is no guarantee the age or health of residents, and the site does not even have any existing public transport to take residents to facilities further afield.

5.10 Strategic Green Belt
As stated previously. Use of this area of Green Belt around Dunton is in breach of the NPPF rules on Green Belt. By building on it Brentwood will be encouraging urban sprawl and inappropriate development, as the Green Belt South of the A127 is in very short supply, therefore of higher value than the abundant Green Belt in other areas of the Borough. Building on it will mean that there is developments almost entirely from the London Borough of Havering to Southend, which is in direct contravention of Green Belt policy.

Green field Green Belt
If these areas of Greenfield are within the Green Belt south of the A127 then they will exacerbate the breach of Green Belt rules, by increasing the urban sprawl from the London Borough of Havering to Southend.

Job Growth and Employment land
5.57 Development at Dunton Hills Garden Village, and around West Horndon, will not be able to provide for new employment land, any more than housing, at building there is in strict contravention of the NPPF for Green Belt, as it would create urban sprawl spreading from the London Borough of Havering to Southend. The so called strategic highway network is the heavily congested A127, and poor C2C service, which hasn't had the investment like the A12 and Crossrail have had, so transport infrastructure for employment is better North of the Borough.

Sustainable development
The NPPF for Green Belt shows that the proposed development of 2500 properties, plus employment and traveller sites on Green Belt at Dunton is not sustainable, as a loss of the very limited areas of Green Belt South of the A127 virtually links the areas of the London Borough of Havering through to Southend, so the LDP doesn't prevent neighbouring towns merging with one another. Green Belt is not decided on because of its high landscape value, or even if it is all accessible to the public, but because of the limited supply in this area.

Managing Development Growth
It is disingenuous to say 'some' Green Belt land will be used, when you are proposing to build on virtually all the Green Belt in the Dunton area. Losing it will result in the merging of more than one town, almost entirely from the London Borough of Havering to Southend. Breaching NPPF Green Belt guidlines, without sufficient benefit, as the Dunton community will be isolated from the rest of Brentwood by the major road boundaries, and lack of connective public transport systems, together with the congested road and rail system in the area.

General Development Criteria
a. Developing Dunton will have a massive unacceptable effect on visual amenity, as well as the character appearance of the surrounding area;
b.The site is isolate from the Brentwood Borough, in an area not currently serviced by public transport or roads, so it fails to provide satisfactory means of access to the site for vehicles, cyclists and pedestrians and parking and servicing arrangements;
c.There is no public transport at the Dunton site, and no spare capacity on the C2C at either Laindon or West Horndon, and the C2C service doesn't link to the rest of the Brentwood Borough, so they would be isolated. The A127 is already heavily congested, and hasn't benefitted from the massive investments of the Crossrail and A12, which would be better suited to the addition numbers of users. People trying to cross the busy A127 have frequently lost their lives, and the isolation of this development would force people into crossing the A127 and the A128 to get to the rest of the Brentwood Borough. Highways England have proposed a Lower Thames Crossing, which may come up through the middle of the proposed Dunton site, adding increased risk to health and safety from vehicles and pollution, and creating another physical barrier for the residents, as there is currently no road system in that area.
d.A development of 2500 homes, plus employment and travellers sites, will definitely have an unacceptable effect on health, because of the high levels of pollution created. The loss of GreenBelt is an unacceptable effect on the environment, particularly as the concrete, and increased vehicle use through the years of development and forever after, etc, will release pollutants to land, water or air (light, noise pollution, vibration, odour, smoke, ash, dust and grit);
e.As there is currently no access to this site, it will cause unacceptable effects to the surrounding areas of Basildon and West Horndon, and their already congested road system, through excessive noise, activity and vehicle movements; There will be a loss of the Green Belt views, and the wildlife that they would have previously contained;
f.It is doubtfull that it will take full account of opportunities to incorporate biodiversity in developments, as too much development is being planned in a small space;
g.The development shouldn't go ahead, as greater weight should be given to the existing assets conservation and enhancement;
h.As it is Green Belt, there is limited residential units to lose, but this doesn't make the development acceptable.
i.As any new development would be required to mitigate its impact on local services and community infrastructure, and there is currently no services and community infrastructure in the area, it would be essential that absolutely all of that was in place before anyone moved in, otherwise BBC are forcing new tenants, employers/ees, travellers, etc, into surviving in isolation, or using the services of nearby Basildon, which are already stretched beyond capacity.

7.1 Dunton Hills Garden Village
Representation
7.5 is wrong to state that DHGV will be linked with Brentwood and other Borough Villages, as it will be divided from them by at least two busy roads, the A127 and the A128. Also, there is no physical route directly onto the A127, and if the Lower Thames Crossing Route C4 goes ahead this will be even worse. As the only available access will be going across Basildon land, this takes residents away from the Brentwood area, and places the burden on all of Basildon services.
7.6 This claim is entirely false, as development of this site encourages urban sprawl, particularly when taken alongside the development proposed on the Basildon Draft Local Plan as well. This will remove virtually the only remaining Green Belt between the London Borough of Havering and Southend. Brentwood has twice the amount of Green Belt as Basildon, yet it is choosing to destroy the small remaining green space to the West of Basildon, which completely goes against Green Belt policy. The losses far outweigh any benefits of developing this piece of Green Belt land.
For 7.7 see 7.6 There can be no Green Belt boundaries created when the small patch of Green Belt in this area is all being proposed for development, by Brentwood and Basildon, and it will directly affect the urban sprawl, by making The London Borough of South Essex a distinct possibility for anyone living south of the A127.
7.8 It is the A12 that has the distinct possibility for growth, as that is where the improved A12 and Crossrail are, so that is where people want to live and work. The A127 has houses built up to its boundaries, not allowing for expansion, and the C2C line is worse than terrible, having regained its old title of the Misery Line. Nobody would choose gridlock on the roads or standing on a train as the ideal location to move their home or business to, particularly as infrastructure of local roads, doctors, schools, etc, would not be in place until well into any construction period, and residents would be cut off from existing Brentwood services by the busy A127 and A128, which have already proved lethal so far this year.
7.9 completely contradicts your points on 7.7, as any Duty of Cooperation to build over the entire area of Green Belt at Dunton would remove any boundary to urban sprawl, guaranteeing that there would be a London Borough of South Essex. A small corridor of Green Belt, west of the Mardyke tributary on the land, would not constitute enough Green Belt as being possible to retain the title, and it could well be buried under concrete if the Lower Thames Crossing C4 goes ahead.

Rep made against: Policy 7.10: Gypsy and Traveller Provision
Representation
Placing at least 20 sites in the 'strategic' location of Dunton is unfair on local residents in the surrounding area. This is as far away as it is possible to be from the rest of the Brentwood Borough, bordering as it does the Basildon Borough, which already has to place far in excess of any traveller pitches than anywhere else, not only in Essex but most of the country. The Basildon area has had to pay for the fiasco resulting in the removal of the illegal pitches at Dale Farm, and is now being told to not only provide Green Belt space for all of those illegal residents, but also account for any population growth that may occur from them, plus extra provision for all legal travellers. To dump Brentwood's allocation so close to the high numbers of travellers in this area sound too much like a ghetto situation is being created, which is not good for the travelling community or the neighbouring non-travelling community. The travelling community has to have easy access to adequate medical and educational needs. This will not be provided in an environment like Dunton, where it is isolated from the rest of the Brentwood borough by the busy A127 and A128. As proved recently when a traveller child died crossing the A127 in Basildon, it is unsafe for them to isolated from other amenities.

9.2 Wildlife and conservation
I object to any development at Dunton, as this will adversely affect the wildlife in this area, that is extremely close to the Essex Wildlife Trust site at Langdon Hills, and provides a wildlife corridor to the Thorndon Park, which would be lost if this development went ahead.
9.3 as above


9.8 If Development within the Green Belt will only be permitted if it maintains the Green Belt's openness and does not conflict with the purposes of the Green Belt or harm its visual amenities, then the development at Dunton should definitely not go ahead as this conflicts with the purposes of green belt by loss of some of the limited visual green space in the area south of the A127, and it is going to encourage urban sprawl by removing one of the main sections separating the London borough of Havering from Southend.

I object to any development at Dunton for the attached reasons.

These are some of the objections I uphold on the proposed development around Dunton. It's very nature as Green Belt in an area South of the A127 which has very limited Green Belt, makes it value as such much higher than that in areas of lots of Green Belt, such as the more Northern parts of the Borough. Any development around the Dunton area foisters Brentwood's problems onto the people of Basildon, as the development would be isolated from the rest of the Borough by the major barriers of the A127 and the A128, and possibly also a new Lower Thames Crossing. Green Belt doesn't have a value because of it's leafy green views, it has a value based on its benefit to the health and mental wellbeing of surrounding areas, and its ability to stop the spread of urban sprawl. In an area already very over developed, such as the south of the A127 around Basildon towards Southend, and Upminster towards London, the small patch of Green Belt may be a drop in the ocean of the large amount of Brentwood's Green Belt (almost twice that of Basildon), but its rarity in that particular location stops everything south of the A127 becoming the London Borough of South Essex.
The development is not only bad for the existing surrounding population, but the new residents would suffer as they wouldn't have access to amenities. It would be in breach of rules on placing traveller sites within areas of easy access to medical and educational facilities. The wildlife of the area would be destroyed, as it is in the middle of the corridor between the Essex Wildlife Trust and Thorndon Park. That much concrete being built would increase the risk of flooding in an area already prone to surface water flooding. The increased pollution levels in the area from the cars from 2,500 homes in such a confined area, as well as the number of vehicles required during any building process, would be bad for the health (asthma, COPD, etc) of existing and new tenants, as well as any wildlife.
Chapter 4 - Strategic Objectives
Representation
SO7 - You claim you want to 'Optimise the social and economic benefits that arise from Crossrail for the benefit of residents, businesses and visitors to the Borough', yet you dump most of housing needs that would benefit from Crossrail south of the A127, where there are numerous problems with the C2C line, the houses would not be near a station anyway, as the A128 would create a barrier which requires residents to drive and park at either Laindon or West Horndon. A quick check on the C2C twitter and Facebook pages would tell you how many problems they have. The 2,500 houses planned for Dunton, and the 500 houses planned for West Horndon would be cut off from good transport needs, with or without the proposed Lower Thames Crossing Option C Route 4 being built, which will only add to their isolation if it went ahead.
SO8 - You claim will 'Promote and support a prosperous rural economy' yet you propose to build half of your housing allocation on Green Belt agricultural land, South of the A127.
SO9 - You claim you will 'Safeguard the Green Belt from inappropriate development and enhance its beneficial use', yet you propose a massive inappropriate development of the very limited supply of Green Belt South of the A127. It has greater value as there is less of it. The National Planning and Policy Framework states that that Green Belt is there to check unrestricted sprawl, and to prevent neighbouring towns from merging. The limited supply of Green Belt land in the area between Brentwood and Basildon South of the A127 is very limited, and both councils propose building up to the boundaries, thereby creating unrestricted sprawl, as well as merging neighbouring towns. South of the A127 there will be virtually no Green Belt separating the London Borough of Havering all the way to Southend. The Green Belt is also supposed to be there to assist in in safeguarding the countryside from encroachment, and preserving the setting and special character of historic towns, yet you propose to build on the only bit of countryside South of the A127, when there is plenty across the rest of the borough. On a Supply and Demand basis, the Green Belt has a far higher value South of the A127 because of its rarity. Also, it preserves the character of Domesday Book villages like Dunton, West Horndon, Herongate and Ingrave, by preventing the development of the small amount of remaining Green Belt in that part of the Borough.

Chapter 5 - Spatial Strategy
Evolution of spatial strategy
Representation
You still fail to show a true picture of Herongate being directly affected by the A127 because of its very close proximity, therefore making it part of the A127 corridor. The A127 has excessive congestion on the road, and the C2C line has transformed from a good service to its original title of the Misery Line in a matter of months. it does not have the capacity for any additional customers at West Horndon, which is the only station within Brentwood Borough on the C2C line. National Rail had already confirmed last year that they had no intention of adding an extra station in any new development, so all residents of developments around the Dunton area would be solely reliant on their cars on the heavily congested A127. If the proposed Option C Route 4 gets the go ahead then the development would also be underneath a four to six lane carriageway in one direction, and an eight to ten lane carriageway in the other direction, completely cutting the development off from any Brentwood services. This means that Brentwood residents would be completely reliant on their Basildon neighbour's facilities, which are already stretched beyond capacity. You propose development around the A127 because you claim the Brentwood Urban area and North of the Borough has congestion, a lack of primary schools, GP facilities, and a higher landscape value. In actual fact, the A127 and South of the Borough suffers severely from congestion, not only on the A127 and local roads around West Horndon, but also on the Herongate and Ingrave area, that has been fighting a Twenty's Plenty campaign to improve safety on the heavily congested roads. There are no more services in the South of the Borough than the North, and a new development won't deliver new GPs and schools until well into any development, putting a strain on surrounding areas, particularly Basildon, as the natural boundaries of the A127 and A128 will prevent any residents from the Dunton area even getting to West Horndon, let alone the rest of the borough. The claim that there is a higher landscape value elsewhere is ludicrous, as quantity doesn't equate to quality. The sheer lack of Green Belt and green spaces around the A127 corridor increases the value to the residents spiritual and physical well being

Draft Plan Spatial Strategy
Representation
You still fail to show a true picture of Herongate being directly affected by the A127 because of its very close proximity, therefore making it part of the A127 corridor. The A127 has excessive congestion on the road, and the C2C line has transformed from a good service to its original title of the Misery Line in a matter of months. it does not have the capacity for any additional customers at West Horndon, which is the only station within Brentwood Borough on the C2C line. National Rail had already confirmed last year that they had no intention of adding an extra station in any new development, so all residents of developments around the Dunton area would be solely reliant on their cars on the heavily congested A127. If the proposed Option C Route 4 gets the go ahead then the development would also be underneath a four to six lane carriageway in one direction, and an eight to ten lane carriageway in the other direction, completely cutting the development off from any Brentwood services. This means that Brentwood residents would be completely reliant on their Basildon neighbour's facilities, which are already stretched beyond capacity. You propose development around the A127 because you claim the Brentwood Urban area and North of the Borough has congestion, a lack of primary schools, GP facilities, and a higher landscape value. In actual fact, the A127 and South of the Borough suffers severely from congestion, not only on the A127 and local roads around West Horndon, but also on the Herongate and Ingrave area, that has been fighting a Twenty's Plenty campaign to improve safety on the heavily congested roads. There are no more services in the South of the Borough than the North, and a new development won't deliver new GPs and schools until well into any development, putting a strain on surrounding areas, particularly Basildon, as the natural boundaries of the A127 and A128 will prevent any residents from the Dunton area even getting to West Horndon, let alone the rest of the borough. The claim that there is a higher landscape value elsewhere is ludicrous, as quantity doesn't equate to quality. The sheer lack of Green Belt and green spaces around the A127 corridor increases the value to the residents spiritual and physical well being

Housing
Representation
Re: Dunton area. This is an area of Green Belt, and there is not enough evidence put forward to show why over 1/3 of the Borough's allowance should be dumped where it goes against the rules of Green Belt, preventing Urban Sprawl, etc. Developing there, and the 500 homes planned for West Horndon, together with the unspecified number of traveller sites, etc, means that there will be virtually no Green Belt left between the London Borough of Havering and Southend. The case has not been shown that adequate facilities would be put in place for any development, prior to people living there, so they would rely heavily on the neighbouring borough of Basildon. This means that there is no more supply of facilities than anywhere else across the borough, and it is probably easier to add one extra GP to an existing surgery, etc, than to build a new surgery before anyone lives in a location. The natural barriers of the A127 and A128 means that residents would be denied medical and school facilities until a long time after they had moved in, if they are ever provided in sufficient numbers. There is no guarantee the age or health of residents, and the site does not even have any existing public transport to take residents to facilities further afield.

5.10 Strategic Green Belt
As stated previously. Use of this area of Green Belt around Dunton is in breach of the NPPF rules on Green Belt. By building on it Brentwood will be encouraging urban sprawl and inappropriate development, as the Green Belt South of the A127 is in very short supply, therefore of higher value than the abundant Green Belt in other areas of the Borough. Building on it will mean that there is developments almost entirely from the London Borough of Havering to Southend, which is in direct contravention of Green Belt policy.

Green field Green Belt
If these areas of Greenfield are within the Green Belt south of the A127 then they will exacerbate the breach of Green Belt rules, by increasing the urban sprawl from the London Borough of Havering to Southend.

Job Growth and Employment land
5.57 Development at Dunton Hills Garden Village, and around West Horndon, will not be able to provide for new employment land, any more than housing, at building there is in strict contravention of the NPPF for Green Belt, as it would create urban sprawl spreading from the London Borough of Havering to Southend. The so called strategic highway network is the heavily congested A127, and poor C2C service, which hasn't had the investment like the A12 and Crossrail have had, so transport infrastructure for employment is better North of the Borough.

Sustainable development
The NPPF for Green Belt shows that the proposed development of 2500 properties, plus employment and traveller sites on Green Belt at Dunton is not sustainable, as a loss of the very limited areas of Green Belt South of the A127 virtually links the areas of the London Borough of Havering through to Southend, so the LDP doesn't prevent neighbouring towns merging with one another. Green Belt is not decided on because of its high landscape value, or even if it is all accessible to the public, but because of the limited supply in this area.

Managing Development Growth
It is disingenuous to say 'some' Green Belt land will be used, when you are proposing to build on virtually all the Green Belt in the Dunton area. Losing it will result in the merging of more than one town, almost entirely from the London Borough of Havering to Southend. Breaching NPPF Green Belt guidlines, without sufficient benefit, as the Dunton community will be isolated from the rest of Brentwood by the major road boundaries, and lack of connective public transport systems, together with the congested road and rail system in the area.

General Development Criteria
a. Developing Dunton will have a massive unacceptable effect on visual amenity, as well as the character appearance of the surrounding area;
b.The site is isolate from the Brentwood Borough, in an area not currently serviced by public transport or roads, so it fails to provide satisfactory means of access to the site for vehicles, cyclists and pedestrians and parking and servicing arrangements;
c.There is no public transport at the Dunton site, and no spare capacity on the C2C at either Laindon or West Horndon, and the C2C service doesn't link to the rest of the Brentwood Borough, so they would be isolated. The A127 is already heavily congested, and hasn't benefitted from the massive investments of the Crossrail and A12, which would be better suited to the addition numbers of users. People trying to cross the busy A127 have frequently lost their lives, and the isolation of this development would force people into crossing the A127 and the A128 to get to the rest of the Brentwood Borough. Highways England have proposed a Lower Thames Crossing, which may come up through the middle of the proposed Dunton site, adding increased risk to health and safety from vehicles and pollution, and creating another physical barrier for the residents, as there is currently no road system in that area.
d.A development of 2500 homes, plus employment and travellers sites, will definitely have an unacceptable effect on health, because of the high levels of pollution created. The loss of GreenBelt is an unacceptable effect on the environment, particularly as the concrete, and increased vehicle use through the years of development and forever after, etc, will release pollutants to land, water or air (light, noise pollution, vibration, odour, smoke, ash, dust and grit);
e.As there is currently no access to this site, it will cause unacceptable effects to the surrounding areas of Basildon and West Horndon, and their already congested road system, through excessive noise, activity and vehicle movements; There will be a loss of the Green Belt views, and the wildlife that they would have previously contained;
f.It is doubtfull that it will take full account of opportunities to incorporate biodiversity in developments, as too much development is being planned in a small space;
g.The development shouldn't go ahead, as greater weight should be given to the existing assets conservation and enhancement;
h.As it is Green Belt, there is limited residential units to lose, but this doesn't make the development acceptable.
i.As any new development would be required to mitigate its impact on local services and community infrastructure, and there is currently no services and community infrastructure in the area, it would be essential that absolutely all of that was in place before anyone moved in, otherwise BBC are forcing new tenants, employers/ees, travellers, etc, into surviving in isolation, or using the services of nearby Basildon, which are already stretched beyond capacity.

7.1 Dunton Hills Garden Village
Representation
7.5 is wrong to state that DHGV will be linked with Brentwood and other Borough Villages, as it will be divided from them by at least two busy roads, the A127 and the A128. Also, there is no physical route directly onto the A127, and if the Lower Thames Crossing Route C4 goes ahead this will be even worse. As the only available access will be going across Basildon land, this takes residents away from the Brentwood area, and places the burden on all of Basildon services.
7.6 This claim is entirely false, as development of this site encourages urban sprawl, particularly when taken alongside the development proposed on the Basildon Draft Local Plan as well. This will remove virtually the only remaining Green Belt between the London Borough of Havering and Southend. Brentwood has twice the amount of Green Belt as Basildon, yet it is choosing to destroy the small remaining green space to the West of Basildon, which completely goes against Green Belt policy. The losses far outweigh any benefits of developing this piece of Green Belt land.
For 7.7 see 7.6 There can be no Green Belt boundaries created when the small patch of Green Belt in this area is all being proposed for development, by Brentwood and Basildon, and it will directly affect the urban sprawl, by making The London Borough of South Essex a distinct possibility for anyone living south of the A127.
7.8 It is the A12 that has the distinct possibility for growth, as that is where the improved A12 and Crossrail are, so that is where people want to live and work. The A127 has houses built up to its boundaries, not allowing for expansion, and the C2C line is worse than terrible, having regained its old title of the Misery Line. Nobody would choose gridlock on the roads or standing on a train as the ideal location to move their home or business to, particularly as infrastructure of local roads, doctors, schools, etc, would not be in place until well into any construction period, and residents would be cut off from existing Brentwood services by the busy A127 and A128, which have already proved lethal so far this year.
7.9 completely contradicts your points on 7.7, as any Duty of Cooperation to build over the entire area of Green Belt at Dunton would remove any boundary to urban sprawl, guaranteeing that there would be a London Borough of South Essex. A small corridor of Green Belt, west of the Mardyke tributary on the land, would not constitute enough Green Belt as being possible to retain the title, and it could well be buried under concrete if the Lower Thames Crossing C4 goes ahead.

Rep made against: Policy 7.10: Gypsy and Traveller Provision
Representation
Placing at least 20 sites in the 'strategic' location of Dunton is unfair on local residents in the surrounding area. This is as far away as it is possible to be from the rest of the Brentwood Borough, bordering as it does the Basildon Borough, which already has to place far in excess of any traveller pitches than anywhere else, not only in Essex but most of the country. The Basildon area has had to pay for the fiasco resulting in the removal of the illegal pitches at Dale Farm, and is now being told to not only provide Green Belt space for all of those illegal residents, but also account for any population growth that may occur from them, plus extra provision for all legal travellers. To dump Brentwood's allocation so close to the high numbers of travellers in this area sound too much like a ghetto situation is being created, which is not good for the travelling community or the neighbouring non-travelling community. The travelling community has to have easy access to adequate medical and educational needs. This will not be provided in an environment like Dunton, where it is isolated from the rest of the Brentwood borough by the busy A127 and A128. As proved recently when a traveller child died crossing the A127 in Basildon, it is unsafe for them to isolated from other amenities.

9.2 Wildlife and conservation
I object to any development at Dunton, as this will adversely affect the wildlife in this area, that is extremely close to the Essex Wildlife Trust site at Langdon Hills, and provides a wildlife corridor to the Thorndon Park, which would be lost if this development went ahead.
9.3 as above


9.8 If Development within the Green Belt will only be permitted if it maintains the Green Belt's openness and does not conflict with the purposes of the Green Belt or harm its visual amenities, then the development at Dunton should definitely not go ahead as this conflicts with the purposes of green belt by loss of some of the limited visual green space in the area south of the A127, and it is going to encourage urban sprawl by removing one of the main sections separating the London borough of Havering from Southend.

We fully support the proposed local development plan. Creating a new community in Dunton/West Horndon seems the most logical choice as these residents will have access to main line routs to London and elsewhere. In addition there is easy access to the A127 and A13 and then onto the M25. Services such as schools, sewage, water etc. can also be put in place more easily.

These are some of the objections I uphold on the proposed development around Dunton. It's very nature as Green Belt in an area South of the A127 which has very limited Green Belt, makes it value as such much higher than that in areas of lots of Green Belt, such as the more Northern parts of the Borough. Any development around the Dunton area foisters Brentwood's problems onto the people of Basildon, as the development would be isolated from the rest of the Borough by the major barriers of the A127 and the A128, and possibly also a new Lower Thames Crossing. Green Belt doesn't have a value because of it's leafy green views, it has a value based on its benefit to the health and mental wellbeing of surrounding areas, and its ability to stop the spread of urban sprawl. In an area already very over developed, such as the south of the A127 around Basildon towards Southend, and Upminster towards London, the small patch of Green Belt may be a drop in the ocean of the large amount of Brentwood's Green Belt (almost twice that of Basildon), but its rarity in that particular location stops everything south of the A127 becoming the London Borough of South Essex.
The development is not only bad for the existing surrounding population, but the new residents would suffer as they wouldn't have access to amenities. It would be in breach of rules on placing traveller sites within areas of easy access to medical and educational facilities. The wildlife of the area would be destroyed, as it is in the middle of the corridor between the Essex Wildlife Trust and Thorndon Park. That much concrete being built would increase the risk of flooding in an area already prone to surface water flooding. The increased pollution levels in the area from the cars from 2,500 homes in such a confined area, as well as the number of vehicles required during any building process, would be bad for the health (asthma, COPD, etc) of existing and new tenants, as well as any wildlife.
Chapter 4 - Strategic Objectives
Representation
SO7 - You claim you want to 'Optimise the social and economic benefits that arise from Crossrail for the benefit of residents, businesses and visitors to the Borough', yet you dump most of housing needs that would benefit from Crossrail south of the A127, where there are numerous problems with the C2C line, the houses would not be near a station anyway, as the A128 would create a barrier which requires residents to drive and park at either Laindon or West Horndon. A quick check on the C2C twitter and Facebook pages would tell you how many problems they have. The 2,500 houses planned for Dunton, and the 500 houses planned for West Horndon would be cut off from good transport needs, with or without the proposed Lower Thames Crossing Option C Route 4 being built, which will only add to their isolation if it went ahead.
SO8 - You claim will 'Promote and support a prosperous rural economy' yet you propose to build half of your housing allocation on Green Belt agricultural land, South of the A127.
SO9 - You claim you will 'Safeguard the Green Belt from inappropriate development and enhance its beneficial use', yet you propose a massive inappropriate development of the very limited supply of Green Belt South of the A127. It has greater value as there is less of it. The National Planning and Policy Framework states that that Green Belt is there to check unrestricted sprawl, and to prevent neighbouring towns from merging. The limited supply of Green Belt land in the area between Brentwood and Basildon South of the A127 is very limited, and both councils propose building up to the boundaries, thereby creating unrestricted sprawl, as well as merging neighbouring towns. South of the A127 there will be virtually no Green Belt separating the London Borough of Havering all the way to Southend. The Green Belt is also supposed to be there to assist in in safeguarding the countryside from encroachment, and preserving the setting and special character of historic towns, yet you propose to build on the only bit of countryside South of the A127, when there is plenty across the rest of the borough. On a Supply and Demand basis, the Green Belt has a far higher value South of the A127 because of its rarity. Also, it preserves the character of Domesday Book villages like Dunton, West Horndon, Herongate and Ingrave, by preventing the development of the small amount of remaining Green Belt in that part of the Borough.

Chapter 5 - Spatial Strategy
Evolution of spatial strategy
Representation
You still fail to show a true picture of Herongate being directly affected by the A127 because of its very close proximity, therefore making it part of the A127 corridor. The A127 has excessive congestion on the road, and the C2C line has transformed from a good service to its original title of the Misery Line in a matter of months. it does not have the capacity for any additional customers at West Horndon, which is the only station within Brentwood Borough on the C2C line. National Rail had already confirmed last year that they had no intention of adding an extra station in any new development, so all residents of developments around the Dunton area would be solely reliant on their cars on the heavily congested A127. If the proposed Option C Route 4 gets the go ahead then the development would also be underneath a four to six lane carriageway in one direction, and an eight to ten lane carriageway in the other direction, completely cutting the development off from any Brentwood services. This means that Brentwood residents would be completely reliant on their Basildon neighbour's facilities, which are already stretched beyond capacity. You propose development around the A127 because you claim the Brentwood Urban area and North of the Borough has congestion, a lack of primary schools, GP facilities, and a higher landscape value. In actual fact, the A127 and South of the Borough suffers severely from congestion, not only on the A127 and local roads around West Horndon, but also on the Herongate and Ingrave area, that has been fighting a Twenty's Plenty campaign to improve safety on the heavily congested roads. There are no more services in the South of the Borough than the North, and a new development won't deliver new GPs and schools until well into any development, putting a strain on surrounding areas, particularly Basildon, as the natural boundaries of the A127 and A128 will prevent any residents from the Dunton area even getting to West Horndon, let alone the rest of the borough. The claim that there is a higher landscape value elsewhere is ludicrous, as quantity doesn't equate to quality. The sheer lack of Green Belt and green spaces around the A127 corridor increases the value to the residents spiritual and physical well being

Draft Plan Spatial Strategy
Representation
You still fail to show a true picture of Herongate being directly affected by the A127 because of its very close proximity, therefore making it part of the A127 corridor. The A127 has excessive congestion on the road, and the C2C line has transformed from a good service to its original title of the Misery Line in a matter of months. it does not have the capacity for any additional customers at West Horndon, which is the only station within Brentwood Borough on the C2C line. National Rail had already confirmed last year that they had no intention of adding an extra station in any new development, so all residents of developments around the Dunton area would be solely reliant on their cars on the heavily congested A127. If the proposed Option C Route 4 gets the go ahead then the development would also be underneath a four to six lane carriageway in one direction, and an eight to ten lane carriageway in the other direction, completely cutting the development off from any Brentwood services. This means that Brentwood residents would be completely reliant on their Basildon neighbour's facilities, which are already stretched beyond capacity. You propose development around the A127 because you claim the Brentwood Urban area and North of the Borough has congestion, a lack of primary schools, GP facilities, and a higher landscape value. In actual fact, the A127 and South of the Borough suffers severely from congestion, not only on the A127 and local roads around West Horndon, but also on the Herongate and Ingrave area, that has been fighting a Twenty's Plenty campaign to improve safety on the heavily congested roads. There are no more services in the South of the Borough than the North, and a new development won't deliver new GPs and schools until well into any development, putting a strain on surrounding areas, particularly Basildon, as the natural boundaries of the A127 and A128 will prevent any residents from the Dunton area even getting to West Horndon, let alone the rest of the borough. The claim that there is a higher landscape value elsewhere is ludicrous, as quantity doesn't equate to quality. The sheer lack of Green Belt and green spaces around the A127 corridor increases the value to the residents spiritual and physical well being

Housing
Representation
Re: Dunton area. This is an area of Green Belt, and there is not enough evidence put forward to show why over 1/3 of the Borough's allowance should be dumped where it goes against the rules of Green Belt, preventing Urban Sprawl, etc. Developing there, and the 500 homes planned for West Horndon, together with the unspecified number of traveller sites, etc, means that there will be virtually no Green Belt left between the London Borough of Havering and Southend. The case has not been shown that adequate facilities would be put in place for any development, prior to people living there, so they would rely heavily on the neighbouring borough of Basildon. This means that there is no more supply of facilities than anywhere else across the borough, and it is probably easier to add one extra GP to an existing surgery, etc, than to build a new surgery before anyone lives in a location. The natural barriers of the A127 and A128 means that residents would be denied medical and school facilities until a long time after they had moved in, if they are ever provided in sufficient numbers. There is no guarantee the age or health of residents, and the site does not even have any existing public transport to take residents to facilities further afield.

5.10 Strategic Green Belt
As stated previously. Use of this area of Green Belt around Dunton is in breach of the NPPF rules on Green Belt. By building on it Brentwood will be encouraging urban sprawl and inappropriate development, as the Green Belt South of the A127 is in very short supply, therefore of higher value than the abundant Green Belt in other areas of the Borough. Building on it will mean that there is developments almost entirely from the London Borough of Havering to Southend, which is in direct contravention of Green Belt policy.

Green field Green Belt
If these areas of Greenfield are within the Green Belt south of the A127 then they will exacerbate the breach of Green Belt rules, by increasing the urban sprawl from the London Borough of Havering to Southend.

Job Growth and Employment land
5.57 Development at Dunton Hills Garden Village, and around West Horndon, will not be able to provide for new employment land, any more than housing, at building there is in strict contravention of the NPPF for Green Belt, as it would create urban sprawl spreading from the London Borough of Havering to Southend. The so called strategic highway network is the heavily congested A127, and poor C2C service, which hasn't had the investment like the A12 and Crossrail have had, so transport infrastructure for employment is better North of the Borough.

Sustainable development
The NPPF for Green Belt shows that the proposed development of 2500 properties, plus employment and traveller sites on Green Belt at Dunton is not sustainable, as a loss of the very limited areas of Green Belt South of the A127 virtually links the areas of the London Borough of Havering through to Southend, so the LDP doesn't prevent neighbouring towns merging with one another. Green Belt is not decided on because of its high landscape value, or even if it is all accessible to the public, but because of the limited supply in this area.

Managing Development Growth
It is disingenuous to say 'some' Green Belt land will be used, when you are proposing to build on virtually all the Green Belt in the Dunton area. Losing it will result in the merging of more than one town, almost entirely from the London Borough of Havering to Southend. Breaching NPPF Green Belt guidlines, without sufficient benefit, as the Dunton community will be isolated from the rest of Brentwood by the major road boundaries, and lack of connective public transport systems, together with the congested road and rail system in the area.

General Development Criteria
a. Developing Dunton will have a massive unacceptable effect on visual amenity, as well as the character appearance of the surrounding area;
b.The site is isolate from the Brentwood Borough, in an area not currently serviced by public transport or roads, so it fails to provide satisfactory means of access to the site for vehicles, cyclists and pedestrians and parking and servicing arrangements;
c.There is no public transport at the Dunton site, and no spare capacity on the C2C at either Laindon or West Horndon, and the C2C service doesn't link to the rest of the Brentwood Borough, so they would be isolated. The A127 is already heavily congested, and hasn't benefitted from the massive investments of the Crossrail and A12, which would be better suited to the addition numbers of users. People trying to cross the busy A127 have frequently lost their lives, and the isolation of this development would force people into crossing the A127 and the A128 to get to the rest of the Brentwood Borough. Highways England have proposed a Lower Thames Crossing, which may come up through the middle of the proposed Dunton site, adding increased risk to health and safety from vehicles and pollution, and creating another physical barrier for the residents, as there is currently no road system in that area.
d.A development of 2500 homes, plus employment and travellers sites, will definitely have an unacceptable effect on health, because of the high levels of pollution created. The loss of GreenBelt is an unacceptable effect on the environment, particularly as the concrete, and increased vehicle use through the years of development and forever after, etc, will release pollutants to land, water or air (light, noise pollution, vibration, odour, smoke, ash, dust and grit);
e.As there is currently no access to this site, it will cause unacceptable effects to the surrounding areas of Basildon and West Horndon, and their already congested road system, through excessive noise, activity and vehicle movements; There will be a loss of the Green Belt views, and the wildlife that they would have previously contained;
f.It is doubtfull that it will take full account of opportunities to incorporate biodiversity in developments, as too much development is being planned in a small space;
g.The development shouldn't go ahead, as greater weight should be given to the existing assets conservation and enhancement;
h.As it is Green Belt, there is limited residential units to lose, but this doesn't make the development acceptable.
i.As any new development would be required to mitigate its impact on local services and community infrastructure, and there is currently no services and community infrastructure in the area, it would be essential that absolutely all of that was in place before anyone moved in, otherwise BBC are forcing new tenants, employers/ees, travellers, etc, into surviving in isolation, or using the services of nearby Basildon, which are already stretched beyond capacity.

7.1 Dunton Hills Garden Village
Representation
7.5 is wrong to state that DHGV will be linked with Brentwood and other Borough Villages, as it will be divided from them by at least two busy roads, the A127 and the A128. Also, there is no physical route directly onto the A127, and if the Lower Thames Crossing Route C4 goes ahead this will be even worse. As the only available access will be going across Basildon land, this takes residents away from the Brentwood area, and places the burden on all of Basildon services.
7.6 This claim is entirely false, as development of this site encourages urban sprawl, particularly when taken alongside the development proposed on the Basildon Draft Local Plan as well. This will remove virtually the only remaining Green Belt between the London Borough of Havering and Southend. Brentwood has twice the amount of Green Belt as Basildon, yet it is choosing to destroy the small remaining green space to the West of Basildon, which completely goes against Green Belt policy. The losses far outweigh any benefits of developing this piece of Green Belt land.
For 7.7 see 7.6 There can be no Green Belt boundaries created when the small patch of Green Belt in this area is all being proposed for development, by Brentwood and Basildon, and it will directly affect the urban sprawl, by making The London Borough of South Essex a distinct possibility for anyone living south of the A127.
7.8 It is the A12 that has the distinct possibility for growth, as that is where the improved A12 and Crossrail are, so that is where people want to live and work. The A127 has houses built up to its boundaries, not allowing for expansion, and the C2C line is worse than terrible, having regained its old title of the Misery Line. Nobody would choose gridlock on the roads or standing on a train as the ideal location to move their home or business to, particularly as infrastructure of local roads, doctors, schools, etc, would not be in place until well into any construction period, and residents would be cut off from existing Brentwood services by the busy A127 and A128, which have already proved lethal so far this year.
7.9 completely contradicts your points on 7.7, as any Duty of Cooperation to build over the entire area of Green Belt at Dunton would remove any boundary to urban sprawl, guaranteeing that there would be a London Borough of South Essex. A small corridor of Green Belt, west of the Mardyke tributary on the land, would not constitute enough Green Belt as being possible to retain the title, and it could well be buried under concrete if the Lower Thames Crossing C4 goes ahead.

Rep made against: Policy 7.10: Gypsy and Traveller Provision
Representation
Placing at least 20 sites in the 'strategic' location of Dunton is unfair on local residents in the surrounding area. This is as far away as it is possible to be from the rest of the Brentwood Borough, bordering as it does the Basildon Borough, which already has to place far in excess of any traveller pitches than anywhere else, not only in Essex but most of the country. The Basildon area has had to pay for the fiasco resulting in the removal of the illegal pitches at Dale Farm, and is now being told to not only provide Green Belt space for all of those illegal residents, but also account for any population growth that may occur from them, plus extra provision for all legal travellers. To dump Brentwood's allocation so close to the high numbers of travellers in this area sound too much like a ghetto situation is being created, which is not good for the travelling community or the neighbouring non-travelling community. The travelling community has to have easy access to adequate medical and educational needs. This will not be provided in an environment like Dunton, where it is isolated from the rest of the Brentwood borough by the busy A127 and A128. As proved recently when a traveller child died crossing the A127 in Basildon, it is unsafe for them to isolated from other amenities.

9.2 Wildlife and conservation
I object to any development at Dunton, as this will adversely affect the wildlife in this area, that is extremely close to the Essex Wildlife Trust site at Langdon Hills, and provides a wildlife corridor to the Thorndon Park, which would be lost if this development went ahead.
9.3 as above


9.8 If Development within the Green Belt will only be permitted if it maintains the Green Belt's openness and does not conflict with the purposes of the Green Belt or harm its visual amenities, then the development at Dunton should definitely not go ahead as this conflicts with the purposes of green belt by loss of some of the limited visual green space in the area south of the A127, and it is going to encourage urban sprawl by removing one of the main sections separating the London borough of Havering from Southend.

Whilst we support elements of the spatial strategy as set out in policy 5.1, we do not believe that this strategy has been carried through into the allocations and detailed policies. We do not support other elements of the strategy. Specifically the reliance on a new settlement to deliver a significant proportion of the Borough's needs and the decision not to release any Green Belt sites adjacent to Larger Villages in the A12 corridor.
We support the strategy to focus development within the transport corridors with Brentwood and Shenfield being the main focus, however, we do not support the reliance two strategic allocations in the A127 corridor to deliver the Borough's needs.
Whilst the spatial strategy suggests Brentwood and Shenfield will be the main focus for development, urban area site allocations total only 1,266 dwellings. This is significantly lower than the so called "supporting" strategic allocation of 2,500 new dwellings, which comprises 35% of the Borough's housing requirement. Other Greenfield urban extensions account for a further 1,292 dwellings and Green Belt brownfield 97 dwellings. It is clear from the numbers alone that the focus of development is not, as stated in the spatial strategy, Brentwood and Shenfield, but Dunton Hills Garden Village in the A127 corridor.
Dunton Hills Garden Village does not support the strategy, it underpins it and the strategy relies upon it. Elsewhere in consultation document Dunton Hills Garden Village is described as delivering a "significant proportion" of need and being "critical to delivering the Plan's key development objectives".
We strongly object to the strategy to rely on a new settlement to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. Instead we suggest greater variation in the portfolio of land available for residential development and in particular a greater number of smaller site allocations.
Smaller allocations increase the flexibility that is in supply, attract smaller house building companies who will not be present upon larger strategic sites, ensure that there is variation in the timescales over which sites can be delivered and provide the consumer (i.e. the future resident) with choice about where they live.
Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have less complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take an average of five years to deliver, from submission of a planning application.
As such, we support the release of smaller Green Belt sites within the transport corridors to meet local needs fully and provide development quickly. We also support the strategy for limited development in villages. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. It is also logical to allocate a range of site types and sizes as opposed to rely on larger strategic sites only.
We object to the decision not to allocate any sites surrounding Larger Villages, specifically at Mountnessing.
Mountnessing lies within the A12 corridor, which the spatial strategy claims to be the focus for development. It is also a sustainable settlement, being served by a local shopping parade and primary school.
However, no sites have been allocated save for existing permissions. Conversely, allocations have been made in Brentwood, Shenfield and Ingatestone, which are also in the A12 corridor.
The explanation for this departure from the spatial strategy appears to be due to Mountnessing occupying a lower position in the settlement hierarchy and/or the existence of recently granted planning permissions. However, to exclude allocations based on the settlement hierarchy is inconsistent compared to treatment of other settlements in this category and in the A12 corridor. Furthermore, the recently granted consents do not serve the needs of Mountnessing.
Mountnessing has been categorised as a "Larger Village" where, according to paragraph 5.33, no Green Belt alterations are proposed "in order to retain the character of the Borough in line with the spatial strategy".
Other Larger Villages are Blackmore, Doddinghurst, Herongate, Ingrave, Kelvedon Hatch and West Horndon.
Blackmore, Doddinghurst and Kelvedon Hatch are in the Rural North where the spatial strategy does not claim to focus development. It allows for only limited infilling at a level commensurate with services and facilities available. To exclude allocations from these settlements is consistent with the spatial strategy.
Similarly, Herongate and Ingrave are in the rural south where the same strategy exists and are therefore also logical exclusions.
The only other Larger Village within a transport corridor, where the spatial strategy seeks to focus development, is West Horndon in the A127 corridor. Whilst no Green Belt boundary change is made, the existing industrial estate is allocated for redevelopment, to deliver 500 new dwellings.
Ingatestone has sites within the urban area, plus both greenfield and brownfield sites outside of the urban area, proposed for delivery of 128 dwellings. Ingatestone, as Mountnessing, lies in the A12 corridor focus for growth area.
Ingatestone has been categorised as a "Village Service Centre" as the Borough's largest village. However, we question whether it occupies a higher category than Mountnessing and the other Larger Villages as a means of setting it apart in order to justify alterations to the Green Belt boundary. Whilst it is larger than the other Larger Villages and benefits from a greater service provision, it stands alone as the only settlement currently within this category. Whilst Dunton Garden Village and West Horndon are proposed to be included later in the Plan period, this is as a result of the development proposed through this Plan.
It is our strong opinion that being a sustainable settlement in the A12 corridor Mountnessing should be treated in the same way as Ingatestone and West Horndon and allocations for a modest level of development should be made. This would be consistent with the spatial strategy to focus development in the Borough's transport corridors and ensure that both the local and Borough's needs are met in the early years of the Plan. With no brownfield redevelopment opportunities, this would necessitate Green Belt release to comply with the spatial strategy to focus development in the transport corridors.
Paragraph 5.19 and figure 5.7 provide an explanation as to why no sites have been allocated at Mountnessing; that planning permission has already been granted for 172 new homes. Paragraph 5.19 states that these will "make a significant contribution to the Borough's needs" and figure 5.7 that they "will contribute to village life".
However, we object to the reliance on these sites; they do not make a "significant" contribution to the Borough's needs and they do not serve the needs of Mountnessing due to their physical separation from the settlement and lack of affordable housing provision.
The Borough's housing need for the Plan period is 7,240 dwellings. At only 2.4% of the Borough needs, 172 homes cannot be said to be a "significant" contribution.
Thoby Priory (15/00527/OUT) lies approximately 1km to the north of the Mountnessing village boundary, in open countryside. Whilst the highways support is subject to a condition to provide a new cycle and footway linking the site to Mountnessing, this does not change the physical separation of the site or guarantee sustainable movements between the site and the village.
The second site is the former scrap yard (14/01446/EIA) which lies approximately 700m to the south west of the Mountnessing village boundary, adjacent to the A12 junction. The highways condition for this consent also requires construction of a new cycle and footway.
Thoby Priory does not have planning consent; it is still subject to a resolution to grant. Whilst it is appreciated that this doesn't necessarily render the site undeliverable, it does raise questions, particularly since the delay in signing the section 106 agreement is due to viability testing in relation to affordable housing provision.
The proposal which went before the committee was for 87 market dwellings and no affordable housing. This was subject to a satisfactory Viability Assessment in support of this. A recent telephone conversation with the case officer confirmed that the Viability Assessment has not yet been agreed and nor has any Extension of Time. As such, there is no certainty of timescales for granting of consent or delivery of the site. Indeed, the case officer indicated that should no agreement be reached regarding the Viability Assessment, the application would have to be returned to committee.
Assuming that agreement can be reached and the permission granted as per the committee report, the site will deliver no affordable housing and no commuted sum for off-site provision. As such, it will not deliver local needs.
The former scrap yard site has planning permission granted for 85 residential units with a section 106 agreement to provide 24 of these dwellings as affordable dwellings on-site plus a financial contribution to provide a further 8 affordable dwellings off-site. It is not clear whether a specific site for the off-site provision has been identified and we are not aware of any sites for this purpose in Mountnessing.
Combined, these two sites provide less than half of the required level of affordable housing so fail to meet the localised affordability needs of Mountnessing and those of the Borough.

Paragraph 7.9 of the Draft Plan is unequivocal that there is a "significant need for additional affordable housing" in the Borough. This is evidenced by the SHMA.
Policy 7.2 requires residential development proposals to "provide an appropriate mix of dwelling types, sizes, tenures and specialist accommodator to meet the specific needs of existing and future households in the Borough"
Policy 7.5 requires a minimum of 35% of affordable housing on sites of 11 or more dwellings to be provided on-site, with only fractions being provided through a financial contribution. This allows for situations where the full affordable requirement cannot be provided and requires the developer to provide evidence as to why it is unviable and negotiate a level of affordable housing provision which is achievable.
Under this emerging policy, of the combined total of 172 dwellings with permission/resolution to grant in Mountnessing, 60 would be required to be affordable housing. However, these sites provide only 24 on-site affordable dwellings, or 14%. This falls considerably short the 35% required. Even if the additional 8 dwellings are included (which it is assumed will not be provided in Mountnessing since no amendments to the village boundary are proposed), the provision would be only 19%.
Whilst it is appreciated that as brownfield sites, the reduction in affordable housing may well be justified on viability grounds, this does not change the fact that there is an under provision of affordable housing for Mountnessing under the Draft Plan.
Mountnessing Parish Council objected to the Thoby application on the basis of a lack of affordable housing, confirming that the development, "...will not address the current situation where even small houses are unaffordable for many people especially the younger generation."
This underprovision of affordable housing is an unsound approach since it fails to meet the policy tests within the NPPF (which requires the needs identified in the SHMA to be met) and those of the draft Plan itself. As such, additional greenfield land must be released adjacent to Mountnessing, which will be able to deliver this affordable need.
Allocation of additional land for housing at Mountnessing would not only meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services. Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, including high vacancy rates in the three retail units within the village and led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).
One such suitable site is Land Adjacent to Mountnessing Primary School, (site 073 under the Strategic Growth Options Consultation and SHLAA site G093). Previously promoted by Crest Nicholson under an option agreement, it is now being promoted directly by the Landowner with Sworders acting as Planning Consultants on the Landowner's behalf.
This site could be sensitively developed to provide short term delivery of much needed private and affordable homes of up to 18 units.
The site is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact, it would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary. It is situated close to the existing retail units and is thus more likely to support these than the two recently applied for developments at Thoby Priory and Mountnessing Roundabout, which are some distance from the village. Occupants of these two new developments are far more likely to drive directly to higher order facilities in other towns than residents who live within easy walking distance of existing village facilities.
The site adjacent to Mountnessing Primary School does not serve any of the purposes of the Green Belt in accordance with the NPPF and no constraints have been identified that would prevent its development for residential use.
The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan period. This site is identified as the only suitable residential site at Mountnessing.
As such, Land adjacent to Mountnessing Primary School should be allocated for residential use to serve the needs of Mountnessing and contribute towards the Borough's needs.

Whilst we support elements of the spatial strategy as set out in policy 5.1, we do not believe that this strategy has been carried through into the allocations and detailed policies. We do not support other elements of the strategy. Specifically the reliance on a new settlement to deliver a significant proportion of the Borough's needs and the decision not to release any Green Belt sites adjacent to Larger Villages in the A12 corridor.
We support the strategy to focus development within the transport corridors with Brentwood and Shenfield being the main focus, however, we do not support the reliance two strategic allocations in the A127 corridor to deliver the Borough's needs.
Whilst the spatial strategy suggests Brentwood and Shenfield will be the main focus for development, urban area site allocations total only 1,266 dwellings. This is significantly lower than the so called "supporting" strategic allocation of 2,500 new dwellings, which comprises 35% of the Borough's housing requirement. Other Greenfield urban extensions account for a further 1,292 dwellings and Green Belt brownfield 97 dwellings. It is clear from the numbers alone that the focus of development is not, as stated in the spatial strategy, Brentwood and Shenfield, but Dunton Hills Garden Village in the A127 corridor.
Dunton Hills Garden Village does not support the strategy, it underpins it and the strategy relies upon it. Elsewhere in consultation document Dunton Hills Garden Village is described as delivering a "significant proportion" of need and being "critical to delivering the Plan's key development objectives".
We strongly object to the strategy to rely on a new settlement to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. Instead we suggest greater variation in the portfolio of land available for residential development and in particular a greater number of smaller site allocations.
Smaller allocations increase the flexibility that is in supply, attract smaller house building companies who will not be present upon larger strategic sites, ensure that there is variation in the timescales over which sites can be delivered and provide the consumer (i.e. the future resident) with choice about where they live.
Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have less complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take an average of five years to deliver, from submission of a planning application.
As such, we support the release of smaller Green Belt sites within the transport corridors to meet local needs fully and provide development quickly. We also support the strategy for limited development in villages. It is a logical approach to locate development along key arterial routes which already benefit from good transport links. It is also logical to allocate a range of site types and sizes as opposed to rely on larger strategic sites only.
We object to the decision not to allocate any sites surrounding Larger Villages, specifically at Mountnessing.
Mountnessing lies within the A12 corridor, which the spatial strategy claims to be the focus for development. It is also a sustainable settlement, being served by a local shopping parade and primary school.
However, no sites have been allocated save for existing permissions. Conversely, allocations have been made in Brentwood, Shenfield and Ingatestone, which are also in the A12 corridor.
The explanation for this departure from the spatial strategy appears to be due to Mountnessing occupying a lower position in the settlement hierarchy and/or the existence of recently granted planning permissions. However, to exclude allocations based on the settlement hierarchy is inconsistent compared to treatment of other settlements in this category and in the A12 corridor. Furthermore, the recently granted consents do not serve the needs of Mountnessing.
Mountnessing has been categorised as a "Larger Village" where, according to paragraph 5.33, no Green Belt alterations are proposed "in order to retain the character of the Borough in line with the spatial strategy".
Other Larger Villages are Blackmore, Doddinghurst, Herongate, Ingrave, Kelvedon Hatch and West Horndon.
Blackmore, Doddinghurst and Kelvedon Hatch are in the Rural North where the spatial strategy does not claim to focus development. It allows for only limited infilling at a level commensurate with services and facilities available. To exclude allocations from these settlements is consistent with the spatial strategy.
Similarly, Herongate and Ingrave are in the rural south where the same strategy exists and are therefore also logical exclusions.
The only other Larger Village within a transport corridor, where the spatial strategy seeks to focus development, is West Horndon in the A127 corridor. Whilst no Green Belt boundary change is made, the existing industrial estate is allocated for redevelopment, to deliver 500 new dwellings.
Ingatestone has sites within the urban area, plus both greenfield and brownfield sites outside of the urban area, proposed for delivery of 128 dwellings. Ingatestone, as Mountnessing, lies in the A12 corridor focus for growth area.
Ingatestone has been categorised as a "Village Service Centre" as the Borough's largest village. However, we question whether it occupies a higher category than Mountnessing and the other Larger Villages as a means of setting it apart in order to justify alterations to the Green Belt boundary. Whilst it is larger than the other Larger Villages and benefits from a greater service provision, it stands alone as the only settlement currently within this category. Whilst Dunton Garden Village and West Horndon are proposed to be included later in the Plan period, this is as a result of the development proposed through this Plan.
It is our strong opinion that being a sustainable settlement in the A12 corridor Mountnessing should be treated in the same way as Ingatestone and West Horndon and allocations for a modest level of development should be made. This would be consistent with the spatial strategy to focus development in the Borough's transport corridors and ensure that both the local and Borough's needs are met in the early years of the Plan. With no brownfield redevelopment opportunities, this would necessitate Green Belt release to comply with the spatial strategy to focus development in the transport corridors.
Paragraph 5.19 and figure 5.7 provide an explanation as to why no sites have been allocated at Mountnessing; that planning permission has already been granted for 172 new homes. Paragraph 5.19 states that these will "make a significant contribution to the Borough's needs" and figure 5.7 that they "will contribute to village life".
However, we object to the reliance on these sites; they do not make a "significant" contribution to the Borough's needs and they do not serve the needs of Mountnessing due to their physical separation from the settlement and lack of affordable housing provision.
The Borough's housing need for the Plan period is 7,240 dwellings. At only 2.4% of the Borough needs, 172 homes cannot be said to be a "significant" contribution.
Thoby Priory (15/00527/OUT) lies approximately 1km to the north of the Mountnessing village boundary, in open countryside. Whilst the highways support is subject to a condition to provide a new cycle and footway linking the site to Mountnessing, this does not change the physical separation of the site or guarantee sustainable movements between the site and the village.
The second site is the former scrap yard (14/01446/EIA) which lies approximately 700m to the south west of the Mountnessing village boundary, adjacent to the A12 junction. The highways condition for this consent also requires construction of a new cycle and footway.
Thoby Priory does not have planning consent; it is still subject to a resolution to grant. Whilst it is appreciated that this doesn't necessarily render the site undeliverable, it does raise questions, particularly since the delay in signing the section 106 agreement is due to viability testing in relation to affordable housing provision.
The proposal which went before the committee was for 87 market dwellings and no affordable housing. This was subject to a satisfactory Viability Assessment in support of this. A recent telephone conversation with the case officer confirmed that the Viability Assessment has not yet been agreed and nor has any Extension of Time. As such, there is no certainty of timescales for granting of consent or delivery of the site. Indeed, the case officer indicated that should no agreement be reached regarding the Viability Assessment, the application would have to be returned to committee.
Assuming that agreement can be reached and the permission granted as per the committee report, the site will deliver no affordable housing and no commuted sum for off-site provision. As such, it will not deliver local needs.
The former scrap yard site has planning permission granted for 85 residential units with a section 106 agreement to provide 24 of these dwellings as affordable dwellings on-site plus a financial contribution to provide a further 8 affordable dwellings off-site. It is not clear whether a specific site for the off-site provision has been identified and we are not aware of any sites for this purpose in Mountnessing.
Combined, these two sites provide less than half of the required level of affordable housing so fail to meet the localised affordability needs of Mountnessing and those of the Borough.

Paragraph 7.9 of the Draft Plan is unequivocal that there is a "significant need for additional affordable housing" in the Borough. This is evidenced by the SHMA.
Policy 7.2 requires residential development proposals to "provide an appropriate mix of dwelling types, sizes, tenures and specialist accommodator to meet the specific needs of existing and future households in the Borough"
Policy 7.5 requires a minimum of 35% of affordable housing on sites of 11 or more dwellings to be provided on-site, with only fractions being provided through a financial contribution. This allows for situations where the full affordable requirement cannot be provided and requires the developer to provide evidence as to why it is unviable and negotiate a level of affordable housing provision which is achievable.
Under this emerging policy, of the combined total of 172 dwellings with permission/resolution to grant in Mountnessing, 60 would be required to be affordable housing. However, these sites provide only 24 on-site affordable dwellings, or 14%. This falls considerably short the 35% required. Even if the additional 8 dwellings are included (which it is assumed will not be provided in Mountnessing since no amendments to the village boundary are proposed), the provision would be only 19%.
Whilst it is appreciated that as brownfield sites, the reduction in affordable housing may well be justified on viability grounds, this does not change the fact that there is an under provision of affordable housing for Mountnessing under the Draft Plan.
Mountnessing Parish Council objected to the Thoby application on the basis of a lack of affordable housing, confirming that the development, "...will not address the current situation where even small houses are unaffordable for many people especially the younger generation."
This underprovision of affordable housing is an unsound approach since it fails to meet the policy tests within the NPPF (which requires the needs identified in the SHMA to be met) and those of the draft Plan itself. As such, additional greenfield land must be released adjacent to Mountnessing, which will be able to deliver this affordable need.
Allocation of additional land for housing at Mountnessing would not only meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services. Historically, there has been little new development within Mountnessing which has had a negative impact upon local services, including high vacancy rates in the three retail units within the village and led to a shortfall of housing and Mountnessing Primary School in need of additional pupils on its roll (currently circa 15-30 pupils under capacity).
One such suitable site is Land Adjacent to Mountnessing Primary School, (site 073 under the Strategic Growth Options Consultation and SHLAA site G093). Previously promoted by Crest Nicholson under an option agreement, it is now being promoted directly by the Landowner with Sworders acting as Planning Consultants on the Landowner's behalf.
This site could be sensitively developed to provide short term delivery of much needed private and affordable homes of up to 18 units.
The site is well screened, with defensible boundaries and development on four sides, ensuring minimal visual impact, it would not result in any coalescence with Ingatestone and represents a logical extension to the existing settlement boundary. It is situated close to the existing retail units and is thus more likely to support these than the two recently applied for developments at Thoby Priory and Mountnessing Roundabout, which are some distance from the village. Occupants of these two new developments are far more likely to drive directly to higher order facilities in other towns than residents who live within easy walking distance of existing village facilities.
The site adjacent to Mountnessing Primary School does not serve any of the purposes of the Green Belt in accordance with the NPPF and no constraints have been identified that would prevent its development for residential use.
The Local Plan evidence base identifies sites that are included within the SHLAA (2011) and "Draft Site Assessment" (2013) as being suitable, available and achievable within the Plan period. This site is identified as the only suitable residential site at Mountnessing.
As such, Land adjacent to Mountnessing Primary School should be allocated for residential use to serve the needs of Mountnessing and contribute towards the Borough's needs.

See two attached comment sheets.

See two attached comment sheets.

I respond the the current consultation of the draft Local Development Plan.

1. I oppose the loss of any greenbelt land to meet housing needs.
2. I challenge BBC as to why they have not contested/objected to the levels of housing development outlined on the basis of the greenbelts special needs.
3. I do not agree to the transport-corridor approach that BBC has adopted, I do not see this as a fair way of apportioning development Borough wide.
4. I refute the assumption that the A127 corridor has greater potential to sustain growth than the A12 corridor or elsewhere in the /borough.
5. Not all brownfield sites are allocated for housing redevelopment. Why?
6. I note that certain locations/areas of the Borough have requested some controlled development but this is being ignored. Why?
7. I vehemently oppose the proposals as set out for West Horndon.
8. I align my response with that as submitted by West Horndon Parish Council.
9. From an earlier consultation on the Dunton scheme, 84% of respondents opposed this. Why hne is it still being put forward?
10. West Horndon is being targeted with almost 60% of the entire Boroughs housing requirement. This is an increase on the 43% proposed in the 2013 draft! This increase is still being proposed despite the 84% objection rate to DGS.
11. DGV as proposed is not sustainable. Once again BBC has produced insufficient assessments to justify such a proposal.
12. Adjoining Authorities including Basildon and Thurrock objected to DGS as did Essex County Council. With such united rejection of the proposal, why does BBC persist with it?
13. Neither ECC nor Highways England have plans to upgrade the A127, again rendering the DGS proposal unsustainable.
14. I do support again in alignment with WHPC, for limited and controlled residential development of the current West horndon Industrial sites. However, this support would be subject a full transport.highways appraisal as the current entrance/exit to the site could absolutely not support 500 new homes with the additional traffic congestion this would bring with it!
15. Neither C2c or Network Rail have any scope to improve the current rail link. In fact recent changes to the timetable have in fact backfired causing WH residents more travel problems.
16. There are no assurances that the loss of employment land would be offered up at the new BEC.
17. Whilst Green Transport routes are mentioned in the document, here again there is no detail to support the intention for these routes.
18. West Horndon has a primary/junior school which already operates over capacity. Its doctors surgery is near capacity, any development simply has to come with the guarantee of amenities and infrastructure upgrade not just a proposal for it!

See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.

See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.

See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.

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