What medical infrastructure is in place to support a further influx of residents? Since the Base complex was populated it now takes almost a month to get an appointment with a GP and the same for a local dentist. What about local NHS hospital services? There's only so much the Community Hospital can cope with.

The proportion of the contribution from Brownfield land in the GB at 1% is woefully low. We have poor grade GB land that is typically sites of redundant for businesses such as construction yards, Civils yard and garden centres that could be developed and the council is currently overlooking or presuming against these.

yes

Not sure exactly what is govered by strategic growth or Windfall (thought that was apples!) but no building on green belt - brownfield only.

Also no reclassification of current green belt to brownfield

I strongly opbject our services CAN NOT COPE THERE IS NO IFASTRUCTURE iN PLACE FOR THIS SO CALLED NEEDED HOUSING OUR HOSPITALS bASILDON IS ON BLACK ALERT -THAT MEANS THAT THE HOSPITALS CAN NOT COPE NOW ,THEY WILL NOT COPE IF YOU DECIDE TO BUILD 100 NEW HOMES LET ALONE THE AMOUNT YOU DICTATE, THERE IS NO evidence that we need to build this housing , London housing is available laying empty, our a128 & Billericay roads are failing as they conjested to the point of being unusable.Greenbelt should not be built on & these are definitely not exceptional circumstances

18% of new housing is going to be built on green belt land??? This is a ridiculour amount! On the one hand you say it will only be a little bit, but 18% is NOT a little bit!

I object this is greenbelt & no exceptional circumstances.
a127& a128 +Billericay road at standstill every morning & evening
no infastucture in place
hospitals =Basildon black alert =gp surgeries &schools playgroups & pre schools oversubscribed
No need for this housing & no proof
not affordable housing

We object to the policy to deliver only the minimum objectively assessed need for the Borough. Firstly, the objectively assessed need should be a minimum requirement. Secondly, the policy should identify sufficient sites to not only meet, but exceed, this requirement. Finally, we do not consider that the housing trajectory supporting this policy demonstrates sufficient deliveries over either the first five years of the plan period or the entire plan period.
Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. It expects the identification of key sites which are critical to the delivery of the housing strategy for the Borough over the plan period.
Paragraph 47 goes on to identify the requirement for sufficient specific deliverable sites to be identified to meet five years worth of the housing requirement. It is expected that a buffer of 5% is added to the supply of deliverable sites to ensure choice and competition in the market for land. A greater buffer of 20% is required if there has been a persistent pattern of under-delivery. The NPPG is clear that any backlog in delivery must also be made up within the first five years of the plan, where possible.
Beyond year five, it is expected that developable sites are identified to meet the need for at least a further 5 years, but ideally for a further ten years.
As such, unless the Plan identifies sufficient land to deliver the five year housing land requirement, it will fall foul of NPPF paragraph 47 and cannot be considered sound under NPPF paragraph 182.
The objectively assessed need should be a minimum requirement, in order to satisfy the requirement of NPPF paragraph 47 to boost significantly the supply of housing.
The table included with policy 5.2 summarises how the objectively assed need will be met. This demonstrates only how it will be met, with no contingency or reserve sites to either exceed this need or replace any identified sites which do not deliver.
The windfall allowance is used to meet the need, not provide a contingency. We do not consider that relying on almost 1,000 windfall deliveries is a sound approach. Paragraph 5.44 of the Draft Plan states that the Council are "keen not to be reliant on windfall to meet needs", suggesting agreement with this concern. The Council intend to address this through delivering higher densities which we do not consider to be a robust solution.
Allocations should seek to deliver the highest densities appropriate from the outset, particularly given the Green Belt status of much of the Borough.
Draft policy 7.3 deals with density and sets out a density of 30 dph or higher, other than where the special character of the surrounding area suggests lower densities. It also expects higher densities of 65 dph in town and district centres.
The supporting text to policy 7.3 suggests that the highest densities possible have been assumed in site allocations and the housing trajectory. It states that efficient use of land and development at the highest densities possible to avoid pressure to release more Green Belt is critical to delivery of the Plan.
If the Plan relies on the highest densities possible or appropriate being used for the allocated sites it cannot be a sound approach to include the potential for higher densities as the only contingency in housing numbers.
It does not appear that any non-implementation allowance is included so in order to meet the objectively assessed need every single extant consent, allocation, permitted development and windfall allowance must come forward during the plan period in order to meet the minimum need requirement.
As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF.
We do not consider that the Housing Trajectory which supports this policy accurately underpins the numbers reported in policy 5.2. It does not demonstrate a five year supply, or indeed, sufficient deliveries to meet the Borough need as set out in policy 5.2.
Policy 5.2 sets out a housing requirement of 7,240 new dwellings over the 20 year plan period, equating to 362 dwellings per annum.
Appendix 2 lists deliveries totalling 5,555. This falls well short of the 7,240 housing requirement. This shortfall is partly made up in the housing trajectory by extant permissions, class C2 completions, permitted development allowance and a significant windfall allowance. However, whilst the housing trajectory claims to demonstrate 7,240 deliveries, the totals at the bottom of the trajectory add up to only 7,121 which is below the housing requirement.
There are further discrepancies between the phasing contained in appendix 2 and housing trajectory contained in appendix 3.
The timescales for delivery do not correlate. Appendix 2 gives a "Phasing estimate" for each site but does not state whether this is from adoption of the Plan or the start date of the Plan. These phasing estimates do not always match the deliveries in the housing trajectory. For example, in appendix 2 site 22 is stated as delivering 250 dwellings in 0-5 years. In the housing trajectory deliveries are spread over 6 years starting in 2018 which is 5 years after the start date of the plan and 1 year after the proposed adoption date of Q2 2017 according to the Local Development Scheme. Similarly, sites 20, 21 and 152 are phased for 5-10 years under appendix 2, but deliveries are spread over 10 years. Dunton Hills Garden Village is shown in the trajectory as delivering for 14 years from 2019 to 2033 whereas appendix 2 phases it for 5-15 years.
Paragraph 7.37 is clear that the trajectory and delivery phasing is merely an estimate. "Delivery ultimately depends upon external factors such as finance availability for house builders, mortgage availability for purchasers, and landowner aspirations."
We contend that in order to be considered sound under NPPF paragraph 182, such issues should be resolved and underpinned by robust evidence prior to adoption of the Plan.
The housing trajectory does not demonstrate a five year supply. Assuming 2017-2021 is taken to be the relevant five year time period from adoption, those sites contained within the trajectory, plus extant permissions, class C2 completions, the permitted development allowance, and windfall allowance, total 1,737 dwellings. 200 of these deliveries would be from Dunton Hills Garden Village which we consider highly questionable (see below).
A simple multiplication of the 362 dpa figure by five years equates to 1,810 dwellings, rising to 1,900 dwellings with a 5% buffer or 2,172 dwellings with a 20% buffer. As such, the trajectory clearly does not demonstrate a five year supply.
Furthermore, we question whether the trajectory is deliverable due to the reliance on deliveries from Dunton Hills Garden Village. This strategic allocation is "critical to delivering the Plan's key development objectives" as set out in Policy 6.6 and supporting text and is crucial to the ability to demonstrate a five year supply on adoption of the Plan.
According to the trajectory, Dunton Hills Garden village needs to start delivering housing in 2019, only two years after adoption of the Plan and deliver 200 dwellings in the first five years following adoption. This is considered to be unrealistic given the scale of the site and its location in the Green Belt.
Large strategic sites, particularly those which require significant infrastructure investment, typically take considerably longer to deliver than smaller sites, as set out fully in our response to Policy 7.1.
If deliveries from Dunton Hills Garden Village are excluded or delayed, the housing trajectory falls considerably short of a five year supply.
Failing to meet the objectively assessed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.

There is no need to encroach upon the green belt -- require new developments in the urban area to be high-density, and that would solve the problem. There would be no shortage of buyers.

I object to development on green belt when previous consultation documents identified the increased population in Brentwood as migratory. By its very nature a migratory population can move to available housing anywhere. Therefore it is incorrect to identify a need to provide additional housing for such prospective residents as they can move to where supply exists rather than forcing unnecessary development of protected green belt spaces and fuelling sprawl.

Green Belt should be better protected, the new surgery was built out on Green Belt, what's going to be next.
1 - I personally thought the whole show of plans showing many separate areas on our maps were very confusing. On the maps, no roads name, and major roads had been labelled. I suggest the maps when next shown are marked clearly with local road.
2 - We clearly are aware more people need houses with also the influx of foreign people, can schools, trains, roads accomodate these policies?

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.

At the age of 20 I don't want to live in the London Borough of South Essex, which is what will happen if this tiny, valuable for so many reasons, piece of Green Belt is buried under concrete, air and noise pollution, as it is one of the few pieces fulfilling its purpose of preventing urban sprawl.

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.

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 object to the policy to deliver only the minimum objectively assessed need for the Borough. Firstly, the objectively assessed need should be a minimum requirement. Secondly, the policy should identify sufficient sites to not only meet, but exceed, this requirement. Finally, we do not consider that the housing trajectory supporting this policy demonstrates sufficient deliveries over either the first five years of the plan period or the entire plan period.
Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. It expects the identification of key sites which are critical to the delivery of the housing strategy for the Borough over the plan period.
Paragraph 47 goes on to identify the requirement for sufficient specific deliverable sites to be identified to meet five years worth of the housing requirement. It is expected that a buffer of 5% is added to the supply of deliverable sites to ensure choice and competition in the market for land. A greater buffer of 20% is required if there has been a persistent pattern of under-delivery. The NPPG is clear that any backlog in delivery must also be made up within the first five years of the plan, where possible.
Beyond year five, it is expected that developable sites are identified to meet the need for at least a further 5 years, but ideally for a further ten years.
As such, unless the Plan identifies sufficient land to deliver the five year housing land requirement, it will fall foul of NPPF paragraph 47 and cannot be considered sound under NPPF paragraph 182.
The objectively assessed need should be a minimum requirement, in order to satisfy the requirement of NPPF paragraph 47 to boost significantly the supply of housing.
The table included with policy 5.2 summarises how the objectively assed need will be met. This demonstrates only how it will be met, with no contingency or reserve sites to either exceed this need or replace any identified sites which do not deliver.
The windfall allowance is used to meet the need, not provide a contingency. We do not consider that relying on almost 1,000 windfall deliveries is a sound approach. Paragraph 5.44 of the Draft Plan states that the Council are "keen not to be reliant on windfall to meet needs", suggesting agreement with this concern. The Council intend to address this through delivering higher densities which we do not consider to be a robust solution.
Allocations should seek to deliver the highest densities appropriate from the outset, particularly given the Green Belt status of much of the Borough.
Draft policy 7.3 deals with density and sets out a density of 30 dph or higher, other than where the special character of the surrounding area suggests lower densities. It also expects higher densities of 65 dph in town and district centres.
The supporting text to policy 7.3 suggests that the highest densities possible have been assumed in site allocations and the housing trajectory. It states that efficient use of land and development at the highest densities possible to avoid pressure to release more Green Belt is critical to delivery of the Plan.
If the Plan relies on the highest densities possible or appropriate being used for the allocated sites it cannot be a sound approach to include the potential for higher densities as the only contingency in housing numbers.
It does not appear that any non-implementation allowance is included so in order to meet the objectively assessed need every single extant consent, allocation, permitted development and windfall allowance must come forward during the plan period in order to meet the minimum need requirement.
As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF.
We do not consider that the Housing Trajectory which supports this policy accurately underpins the numbers reported in policy 5.2. It does not demonstrate a five year supply, or indeed, sufficient deliveries to meet the Borough need as set out in policy 5.2.
Policy 5.2 sets out a housing requirement of 7,240 new dwellings over the 20 year plan period, equating to 362 dwellings per annum.
Appendix 2 lists deliveries totalling 5,555. This falls well short of the 7,240 housing requirement. This shortfall is partly made up in the housing trajectory by extant permissions, class C2 completions, permitted development allowance and a significant windfall allowance. However, whilst the housing trajectory claims to demonstrate 7,240 deliveries, the totals at the bottom of the trajectory add up to only 7,121 which is below the housing requirement.
There are further discrepancies between the phasing contained in appendix 2 and housing trajectory contained in appendix 3.
The timescales for delivery do not correlate. Appendix 2 gives a "Phasing estimate" for each site but does not state whether this is from adoption of the Plan or the start date of the Plan. These phasing estimates do not always match the deliveries in the housing trajectory. For example, in appendix 2 site 22 is stated as delivering 250 dwellings in 0-5 years. In the housing trajectory deliveries are spread over 6 years starting in 2018 which is 5 years after the start date of the plan and 1 year after the proposed adoption date of Q2 2017 according to the Local Development Scheme. Similarly, sites 20, 21 and 152 are phased for 5-10 years under appendix 2, but deliveries are spread over 10 years. Dunton Hills Garden Village is shown in the trajectory as delivering for 14 years from 2019 to 2033 whereas appendix 2 phases it for 5-15 years.
Paragraph 7.37 is clear that the trajectory and delivery phasing is merely an estimate. "Delivery ultimately depends upon external factors such as finance availability for house builders, mortgage availability for purchasers, and landowner aspirations."
We contend that in order to be considered sound under NPPF paragraph 182, such issues should be resolved and underpinned by robust evidence prior to adoption of the Plan.
The housing trajectory does not demonstrate a five year supply. Assuming 2017-2021 is taken to be the relevant five year time period from adoption, those sites contained within the trajectory, plus extant permissions, class C2 completions, the permitted development allowance, and windfall allowance, total 1,737 dwellings. 200 of these deliveries would be from Dunton Hills Garden Village which we consider highly questionable (see below).
A simple multiplication of the 362 dpa figure by five years equates to 1,810 dwellings, rising to 1,900 dwellings with a 5% buffer or 2,172 dwellings with a 20% buffer. As such, the trajectory clearly does not demonstrate a five year supply.
Furthermore, we question whether the trajectory is deliverable due to the reliance on deliveries from Dunton Hills Garden Village. This strategic allocation is "critical to delivering the Plan's key development objectives" as set out in Policy 6.6 and supporting text and is crucial to the ability to demonstrate a five year supply on adoption of the Plan.
According to the trajectory, Dunton Hills Garden village needs to start delivering housing in 2019, only two years after adoption of the Plan and deliver 200 dwellings in the first five years following adoption. This is considered to be unrealistic given the scale of the site and its location in the Green Belt.
Large strategic sites, particularly those which require significant infrastructure investment, typically take considerably longer to deliver than smaller sites, as set out fully in our response to Policy 7.1.
If deliveries from Dunton Hills Garden Village are excluded or delayed, the housing trajectory falls considerably short of a five year supply.
Failing to meet the objectively assessed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.

We object to the policy to deliver only the minimum objectively assessed need for the Borough. Firstly, the objectively assessed need should be a minimum requirement. Secondly, the policy should identify sufficient sites to not only meet, but exceed, this requirement. Finally, we do not consider that the housing trajectory supporting this policy demonstrates sufficient deliveries over either the first five years of the plan period or the entire plan period.
Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. It expects the identification of key sites which are critical to the delivery of the housing strategy for the Borough over the plan period.
Paragraph 47 goes on to identify the requirement for sufficient specific deliverable sites to be identified to meet five years worth of the housing requirement. It is expected that a buffer of 5% is added to the supply of deliverable sites to ensure choice and competition in the market for land. A greater buffer of 20% is required if there has been a persistent pattern of under-delivery. The NPPG is clear that any backlog in delivery must also be made up within the first five years of the plan, where possible.
Beyond year five, it is expected that developable sites are identified to meet the need for at least a further 5 years, but ideally for a further ten years.
As such, unless the Plan identifies sufficient land to deliver the five year housing land requirement, it will fall foul of NPPF paragraph 47 and cannot be considered sound under NPPF paragraph 182.
The objectively assessed need should be a minimum requirement, in order to satisfy the requirement of NPPF paragraph 47 to boost significantly the supply of housing.
The table included with policy 5.2 summarises how the objectively assed need will be met. This demonstrates only how it will be met, with no contingency or reserve sites to either exceed this need or replace any identified sites which do not deliver.
The windfall allowance is used to meet the need, not provide a contingency. We do not consider that relying on almost 1,000 windfall deliveries is a sound approach. Paragraph 5.44 of the Draft Plan states that the Council are "keen not to be reliant on windfall to meet needs", suggesting agreement with this concern. The Council intend to address this through delivering higher densities which we do not consider to be a robust solution.
Allocations should seek to deliver the highest densities appropriate from the outset, particularly given the Green Belt status of much of the Borough.
Draft policy 7.3 deals with density and sets out a density of 30 dph or higher, other than where the special character of the surrounding area suggests lower densities. It also expects higher densities of 65 dph in town and district centres.
The supporting text to policy 7.3 suggests that the highest densities possible have been assumed in site allocations and the housing trajectory. It states that efficient use of land and development at the highest densities possible to avoid pressure to release more Green Belt is critical to delivery of the Plan.
If the Plan relies on the highest densities possible or appropriate being used for the allocated sites it cannot be a sound approach to include the potential for higher densities as the only contingency in housing numbers.
It does not appear that any non-implementation allowance is included so in order to meet the objectively assessed need every single extant consent, allocation, permitted development and windfall allowance must come forward during the plan period in order to meet the minimum need requirement.
As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF.
We do not consider that the Housing Trajectory which supports this policy accurately underpins the numbers reported in policy 5.2. It does not demonstrate a five year supply, or indeed, sufficient deliveries to meet the Borough need as set out in policy 5.2.
Policy 5.2 sets out a housing requirement of 7,240 new dwellings over the 20 year plan period, equating to 362 dwellings per annum.
Appendix 2 lists deliveries totalling 5,555. This falls well short of the 7,240 housing requirement. This shortfall is partly made up in the housing trajectory by extant permissions, class C2 completions, permitted development allowance and a significant windfall allowance. However, whilst the housing trajectory claims to demonstrate 7,240 deliveries, the totals at the bottom of the trajectory add up to only 7,121 which is below the housing requirement.
There are further discrepancies between the phasing contained in appendix 2 and housing trajectory contained in appendix 3.
The timescales for delivery do not correlate. Appendix 2 gives a "Phasing estimate" for each site but does not state whether this is from adoption of the Plan or the start date of the Plan. These phasing estimates do not always match the deliveries in the housing trajectory. For example, in appendix 2 site 22 is stated as delivering 250 dwellings in 0-5 years. In the housing trajectory deliveries are spread over 6 years starting in 2018 which is 5 years after the start date of the plan and 1 year after the proposed adoption date of Q2 2017 according to the Local Development Scheme. Similarly, sites 20, 21 and 152 are phased for 5-10 years under appendix 2, but deliveries are spread over 10 years. Dunton Hills Garden Village is shown in the trajectory as delivering for 14 years from 2019 to 2033 whereas appendix 2 phases it for 5-15 years.
Paragraph 7.37 is clear that the trajectory and delivery phasing is merely an estimate. "Delivery ultimately depends upon external factors such as finance availability for house builders, mortgage availability for purchasers, and landowner aspirations."
We contend that in order to be considered sound under NPPF paragraph 182, such issues should be resolved and underpinned by robust evidence prior to adoption of the Plan.
The housing trajectory does not demonstrate a five year supply. Assuming 2017-2021 is taken to be the relevant five year time period from adoption, those sites contained within the trajectory, plus extant permissions, class C2 completions, the permitted development allowance, and windfall allowance, total 1,737 dwellings. 200 of these deliveries would be from Dunton Hills Garden Village which we consider highly questionable (see below).
A simple multiplication of the 362 dpa figure by five years equates to 1,810 dwellings, rising to 1,900 dwellings with a 5% buffer or 2,172 dwellings with a 20% buffer. As such, the trajectory clearly does not demonstrate a five year supply.
Furthermore, we question whether the trajectory is deliverable due to the reliance on deliveries from Dunton Hills Garden Village. This strategic allocation is "critical to delivering the Plan's key development objectives" as set out in Policy 6.6 and supporting text and is crucial to the ability to demonstrate a five year supply on adoption of the Plan.
According to the trajectory, Dunton Hills Garden village needs to start delivering housing in 2019, only two years after adoption of the Plan and deliver 200 dwellings in the first five years following adoption. This is considered to be unrealistic given the scale of the site and its location in the Green Belt.
Large strategic sites, particularly those which require significant infrastructure investment, typically take considerably longer to deliver than smaller sites, as set out fully in our response to Policy 7.1.
If deliveries from Dunton Hills Garden Village are excluded or delayed, the housing trajectory falls considerably short of a five year supply.
Failing to meet the objectively assessed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.

We object to the policy to deliver only the minimum objectively assessed need for the Borough. Firstly, the objectively assessed need should be a minimum requirement. Secondly, the policy should identify sufficient sites to not only meet, but exceed, this requirement. Finally, we do not consider that the housing trajectory supporting this policy demonstrates sufficient deliveries over either the first five years of the plan period or the entire plan period.
Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. It expects the identification of key sites which are critical to the delivery of the housing strategy for the Borough over the plan period.
Paragraph 47 goes on to identify the requirement for sufficient specific deliverable sites to be identified to meet five years worth of the housing requirement. It is expected that a buffer of 5% is added to the supply of deliverable sites to ensure choice and competition in the market for land. A greater buffer of 20% is required if there has been a persistent pattern of under-delivery. The NPPG is clear that any backlog in delivery must also be made up within the first five years of the plan, where possible.
Beyond year five, it is expected that developable sites are identified to meet the need for at least a further 5 years, but ideally for a further ten years.
As such, unless the Plan identifies sufficient land to deliver the five year housing land requirement, it will fall foul of NPPF paragraph 47 and cannot be considered sound under NPPF paragraph 182.
The objectively assessed need should be a minimum requirement, in order to satisfy the requirement of NPPF paragraph 47 to boost significantly the supply of housing.
The table included with policy 5.2 summarises how the objectively assed need will be met. This demonstrates only how it will be met, with no contingency or reserve sites to either exceed this need or replace any identified sites which do not deliver.
The windfall allowance is used to meet the need, not provide a contingency. We do not consider that relying on almost 1,000 windfall deliveries is a sound approach. Paragraph 5.44 of the Draft Plan states that the Council are "keen not to be reliant on windfall to meet needs", suggesting agreement with this concern. The Council intend to address this through delivering higher densities which we do not consider to be a robust solution.
Allocations should seek to deliver the highest densities appropriate from the outset, particularly given the Green Belt status of much of the Borough.
Draft policy 7.3 deals with density and sets out a density of 30 dph or higher, other than where the special character of the surrounding area suggests lower densities. It also expects higher densities of 65 dph in town and district centres.
The supporting text to policy 7.3 suggests that the highest densities possible have been assumed in site allocations and the housing trajectory. It states that efficient use of land and development at the highest densities possible to avoid pressure to release more Green Belt is critical to delivery of the Plan.
If the Plan relies on the highest densities possible or appropriate being used for the allocated sites it cannot be a sound approach to include the potential for higher densities as the only contingency in housing numbers.
It does not appear that any non-implementation allowance is included so in order to meet the objectively assessed need every single extant consent, allocation, permitted development and windfall allowance must come forward during the plan period in order to meet the minimum need requirement.
As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF.
We do not consider that the Housing Trajectory which supports this policy accurately underpins the numbers reported in policy 5.2. It does not demonstrate a five year supply, or indeed, sufficient deliveries to meet the Borough need as set out in policy 5.2.
Policy 5.2 sets out a housing requirement of 7,240 new dwellings over the 20 year plan period, equating to 362 dwellings per annum.
Appendix 2 lists deliveries totalling 5,555. This falls well short of the 7,240 housing requirement. This shortfall is partly made up in the housing trajectory by extant permissions, class C2 completions, permitted development allowance and a significant windfall allowance. However, whilst the housing trajectory claims to demonstrate 7,240 deliveries, the totals at the bottom of the trajectory add up to only 7,121 which is below the housing requirement.
There are further discrepancies between the phasing contained in appendix 2 and housing trajectory contained in appendix 3.
The timescales for delivery do not correlate. Appendix 2 gives a "Phasing estimate" for each site but does not state whether this is from adoption of the Plan or the start date of the Plan. These phasing estimates do not always match the deliveries in the housing trajectory. For example, in appendix 2 site 22 is stated as delivering 250 dwellings in 0-5 years. In the housing trajectory deliveries are spread over 6 years starting in 2018 which is 5 years after the start date of the plan and 1 year after the proposed adoption date of Q2 2017 according to the Local Development Scheme. Similarly, sites 20, 21 and 152 are phased for 5-10 years under appendix 2, but deliveries are spread over 10 years. Dunton Hills Garden Village is shown in the trajectory as delivering for 14 years from 2019 to 2033 whereas appendix 2 phases it for 5-15 years.
Paragraph 7.37 is clear that the trajectory and delivery phasing is merely an estimate. "Delivery ultimately depends upon external factors such as finance availability for house builders, mortgage availability for purchasers, and landowner aspirations."
We contend that in order to be considered sound under NPPF paragraph 182, such issues should be resolved and underpinned by robust evidence prior to adoption of the Plan.
The housing trajectory does not demonstrate a five year supply. Assuming 2017-2021 is taken to be the relevant five year time period from adoption, those sites contained within the trajectory, plus extant permissions, class C2 completions, the permitted development allowance, and windfall allowance, total 1,737 dwellings. 200 of these deliveries would be from Dunton Hills Garden Village which we consider highly questionable (see below).
A simple multiplication of the 362 dpa figure by five years equates to 1,810 dwellings, rising to 1,900 dwellings with a 5% buffer or 2,172 dwellings with a 20% buffer. As such, the trajectory clearly does not demonstrate a five year supply.
Furthermore, we question whether the trajectory is deliverable due to the reliance on deliveries from Dunton Hills Garden Village. This strategic allocation is "critical to delivering the Plan's key development objectives" as set out in Policy 6.6 and supporting text and is crucial to the ability to demonstrate a five year supply on adoption of the Plan.
According to the trajectory, Dunton Hills Garden village needs to start delivering housing in 2019, only two years after adoption of the Plan and deliver 200 dwellings in the first five years following adoption. This is considered to be unrealistic given the scale of the site and its location in the Green Belt.
Large strategic sites, particularly those which require significant infrastructure investment, typically take considerably longer to deliver than smaller sites, as set out fully in our response to Policy 7.1.
If deliveries from Dunton Hills Garden Village are excluded or delayed, the housing trajectory falls considerably short of a five year supply.
Failing to meet the objectively assessed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound.

See attached.

See two attached comment sheets.

See attached.

See attached.

See attached.

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.

See attached

1. The Parish Council considers that the proposed document and its supporting material, the Site Allocation and Pattern Maps, are well-constructed and contain well thought through and comprehensive policies that the Parish Council supports overall.
The Parish Council would like to congratulate the Borough Planning team working on this project for their hard work in producing this Draft Document for consultation.

2. A number of detailed comments, observations and requests are made as follows:
Recommendations for improvement. (NB. Reference in this paper to the "LDP" means the Brentwood Draft Local Plan (2013 - 2033):

2.1 Whilst mapping of the Parish Council boundaries is in the Pattern book on Page 18 it isn't referenced anywhere in the LDP, but knowledge of the Parish Council boundaries would help better inform the reader and make some of the statements easier to understand. For example paragraph 9.58 on Page 142 is being interpreted by many as meaning the whole of the area of the Parishes listed (they are called settlements in the document) are urban when it is the established residential areas that are being referred to as an urban classification and excluded from the Green Belt. Clear understanding is not helped by the fact that the proposals map (Fig 9.2) isn't referenced in 9.58 and you have to read the glossary to understand what a proposal map is. Parish Councils are referred to on page 16 of the LDP para 2.40, so perhaps a reference to the mapping of the Parish Council areas could be included here?

2.2 Errors observed on Page 42 of the LDP. Hook End and Wyatts Green are not separate villages as implied in the "Cat 4 smaller villages" table but are wards of Blackmore Parish Council and are within the Blackmore Parish Council area. Stondon Massey and Navestock (which are separate parished areas) are missing altogether.

2.3 Page 93 of the LDP. The Willows, Place Farm Lane is within the boundary of Doddinghurst Parish Council and therefore the address should be Doddinghurst and not Kelvedon Hatch. This error is also repeated in the pattern book on page 30.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.4 In comparison with historic housing growth in the Borough there are a very large number of dwellings (928) that are to be provided under the "windfall" allowance. We are concerned that, when the 255 non allocated housing and employment sites are studied this could lead to a planning blight in those area listed because all housing conveyance processes now ask for details of potential development in the area. The Parish Council therefore recommend that the non allocated site list is refined in the very near future, using the proposed LDP policies, to shortlist sites to meet the majority of "windfall" needs, rather than let a potential 10 year planning bun-fight start once the plan is adopted. At the moment people are being lulled into a false sense of security because the site allocation maps document omit potentially 100 or so sites where development will ultimately take place of 9 or more houses between now and 2033 to meet the proposed new housing targets.

2.5 LDP Policy 9.9 clause l. (NB has a stray "m" at the beginning). The Parish Council support the preservation of Bungalows but this particular clause relates only to the redevelopment of dwellings in the Green Belt. LDP Para 7.65 reflects on the fact that the population is aging but the need is not simply for specialist housing for the elderly. LDP Para 2.34 explains that there is a growth in numbers of the elderly in the Borough and para 9.76 expressly mentions giving older people the opportunity to downsize. This is no less so than in the villages, where there is a need for more bungalows for conventional retail purchase - not affordable or sheltered homes, to allow for the "churn" of people in the villages - for the elderly to "downsize" and families to "upsize" to the properties that now too large, or with gardens and stairs that are no longer an asset but a liability, for the aged. With the emphasis on affordable housing everywhere in the LDP the need for new bungalows has been somewhat squeezed out and there is no clear pathway in the policy document to facilitate this key provision - but with all the Green Belt safeguards that the Borough Council have rightly included. Can 9.76 perhaps reference approved Neighbourhood Plans as evidence of such requirement as well as the Council's Strategic Housing Market Assessment and local housing strategy?

2.6 LDP Policy 7.5 g (i). The Parish Council understands the drive for affordable housing but is nevertheless concerned about the possibility of unintended consequences of this policy clause which has the laudable intent of making new homes truly affordable in Brentwood, but, the Parish Council suspects that this approach could backfire badly in one of two ways, by either
(i) Deterring development entirely, or
(ii) By resulting in homes built to every minimum standard in the book in a race to the bottom in design with microscopic footprints and amenity space. In short, homes that are affordable but quite undesirable.

2.7 Green Belt and its development by stealth.
(i) The "Agricultural Business". One of the loopholes exploited by land speculators in the past and present (and we can point to several examples), is for an individual/ company to purchase a large green belt field, or either have (or purchase) an area of land behind their property, and then to set up a small scale rural business such as, e.g.: a stable; an egg farm; a mushroom farm etc. A typical approach will be where, sooner or later, an application will be lodged for some form of building annex where a person can live in order to tend "The Farm" and then in due course for this to be followed by an application for a full scale residential development. Once the residence is completed, the business soon seems to become unviable and ceases to trade, and the dwelling is sold for residential purposes.
(ii) As well as this approach we see the more clandestine method adopted in quiet backwaters where large screens or fences are put up to camouflage the field behind which small dwellings are constructed and then after 10 years a certificate of lawfulness is requested to make the development legal.
The question is, is there anything that can be done in the LDP to close these loopholes that are regularly exploited?

3. Consultation response approval.
The contents of this response to the Consultation detailed above has been agreed by the Parish Council have been as discussed at a meeting to review the LDP on the 7th January 2016.

I disagree with the proposed LDP.
I could write a whole essay but in short we just need to save the greenbelt land around here. There are much better options in redeveloping urban/run down areas instead of ruining this lovely land.

See attached

See attached