Policy 6.3: General Development Criteria

Showing comments and forms 1 to 22 of 22

Support

Draft Local Plan

Representation ID: 13117

Received: 15/02/2016

Respondent: Mr Chris Hossack

Representation Summary:

common sense

Full text:

common sense

Comment

Draft Local Plan

Representation ID: 13205

Received: 03/03/2016

Respondent: Sport England

Representation Summary:

Criterion (i) which requires new development to mitigate its impact on local services and community infrastructure is welcomed and considered justified. However, it would be helpful if the supporting text in paragraph 6.19 explains what is included within the term community facilities and services so that there is clarity when implementing the policy about what this covers e.g. are sport, leisure and recreation facilities included?

Full text:

Criterion (i) which requires new development to mitigate its impact on local services and community infrastructure is welcomed and considered justified. However, it would be helpful if the supporting text in paragraph 6.19 explains what is included within the term community facilities and services so that there is clarity when implementing the policy about what this covers e.g. are sport, leisure and recreation facilities included?

Object

Draft Local Plan

Representation ID: 13509

Received: 23/03/2016

Respondent: Mrs Helen Gabell

Representation Summary:

Developing at Dunton is in breach of almost every one of the criteria set out, as it is a valuable Green Belt for the nearby communities, with no roads and infrastructure in place for the development, leaving users in complete isolation, and risking their health through noise and air pollution, increased flood risk, traffic, etc. It is unacceptable visually and environmentally, as it is a destruction of Green Belt in an area with little Green Belt fulfilling its purpose.

Full text:

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.

Object

Draft Local Plan

Representation ID: 13836

Received: 23/03/2016

Respondent: Mr Joe Gabell

Representation Summary:

Development of Dunton Hills Garden would not be consistent with the General Development Criteria. [See full Rep for criteria breakdown]

Full text:

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.

Object

Draft Local Plan

Representation ID: 13847

Received: 23/03/2016

Respondent: Mr Harry Gabell

Representation Summary:

Development of Dunton Hills Garden would not be consistent with the General Development Criteria. See full Rep for criteria breakdown.

Full text:

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.

Object

Draft Local Plan

Representation ID: 13859

Received: 23/03/2016

Respondent: Mr Paul Gabell

Representation Summary:

Development of Dunton Hills Garden would not be consistent with the General Development Criteria. See full Rep for criteria breakdown.

Full text:

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.

Comment

Draft Local Plan

Representation ID: 13922

Received: 06/04/2016

Respondent: Mr Ian Blackburn

Representation Summary:

The Dunton Hills Garden Village development would not meet the criteria f Polciy 6.3 on nearly all accounts compared with alternative growth models. Concentration of development would give rise to the following effects:

- It would have a much larger effect on the character and appearance of the surrounding area
- It would likely give rise to adverse highway implications. This is evident by considering the additional traffic that would use the A127, A128 and Station Road/ St Mary's lane
- It would be more likely give rise to adverse health effects
- It would have a greater impact on designated heritage assets i.e. Thordon Park

Full text:

See attached.

Attachments:

Support

Draft Local Plan

Representation ID: 14016

Received: 08/04/2016

Respondent: Glenda Fleming

Representation Summary:

Support. New development should make a positive contribution to the environment.

Full text:

See two attached comment sheets.

Attachments:

Comment

Draft Local Plan

Representation ID: 14063

Received: 11/04/2016

Respondent: J M Gillingham

Representation Summary:

The Dunton Hills Garden Village development would not meet the criteria f Polciy 6.3 on nearly all accounts compared with alternative growth models. Concentration of development would give rise to the following effects:

- It would have a much larger effect on the character and appearance of the surrounding area
- It would likely give rise to adverse highway implications. This is evident by considering the additional traffic that would use the A127, A128 and Station Road/ St Mary's lane
- It would be more likely give rise to adverse health effects
- It would have a greater impact on designated heritage assets i.e. Thordon Park

Full text:

See attached.

Attachments:

Support

Draft Local Plan

Representation ID: 15150

Received: 28/04/2016

Respondent: CEG Land Promotions Limited

Agent: CODE Development Planners Ltd

Representation Summary:

CEG support the general development criteria of policy 6.3 and note from evidence prepared so far on behalf of the Promoters that the development of Dunton Hills Garden Village will be in total compliance with its criteria. Compliance is easily achievable in the case of this single large strategic site with its existing characteristics and the development's ability to build in appropriate elements.

Full text:

See attached

Attachments:

Comment

Draft Local Plan

Representation ID: 15241

Received: 03/05/2016

Respondent: Natural England

Representation Summary:

We have also looked at, and are generally supportive of, the Strategic Objectives, Spatial Strategy, General Development Criteria, and the various policies covering the environment, Green Infrastructure, air quality, lighting, flood risk and Sustainable Urban Drainage.

Full text:

See attached

Attachments:

Comment

Draft Local Plan

Representation ID: 15288

Received: 03/05/2016

Respondent: Brentwood School

Number of people: 2

Agent: JTS Partnership LLP

Representation Summary:

Policy 6.3 is generally supported however criteria h is unnecessary and the Council places too great a weight on it. It should either be removed or additional words added:

"h) result in no net loss of residential units unless other material public and planning benefits outweigh such loss"

The Local Authority's over emphasis of the need for the retention of residential at all costs. There may be many opportunities for greater community benefits to come forward where there is inconsequential loss of one or two units or where other plan objectives can be met.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 15594

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Policy 6.3 wording is not considered to be 'Consistent with national policy' as per the following:

Part (a): This requirement is not contained within the NPPF. Instead, paragraph 58 directs that policies should ensure development responds to local character, reflect the local surroundings and is visually attractive, whilst not preventing or discouraging appropriate innovation.

Part (c): wording is inconsistent with the NPPF (para 32), which states that development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are "severe".

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 15595

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Policy 6.3 wording is not considered to be 'Consistent with national policy' as per the following:

Part (d): wording fails to take account of the balance within the NPPF (para 109) in that both new and existing development should be prevented from contributing to or being put at unacceptable risk from, or being adversely affect by unacceptable levels of soil, air, water or noise pollution or land instability.

Part (f): The NPPF (para 118) directs the planning applications should be encouraged to seek opportunities to incorporate biodiversity in and around developments, and therefore it is considered inappropriate to state that proposals "should take full account" of biodiversity opportunities.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 15596

Received: 05/05/2016

Respondent: Croudace Strategic Ltd

Agent: Barton Willmore

Representation Summary:

Policy 6.3 wording is not considered to be 'Consistent with national policy' as per the following:

Part (g): This is considered to be largely in compliance with the NPPF (para 132), excluding the additional requirement to consider the assets enhancement. In addition, "greater" should be reworded to state "great" in accordance with paragraph 132. The test to be considered in the NPPF, when considering the impact of a development on the significance of a designated heritage asset, is whether such development would lead to substantial harm to/total loss of a heritage asset's significance (Para 133), or less than substantial harm (Para 134).

Part (i): This fails to take acknowledge the NPPF (para 204), in that planning obligations should only be sought where necessary to make the development acceptable in planning terms, directly related to the development, and fairly and reasonably related in scale and kind to the development.

Full text:

See attached.

Attachments:

Comment

Draft Local Plan

Representation ID: 15727

Received: 11/05/2016

Respondent: Highways England

Representation Summary:

Policy 6.3 C covering general development criteria states that development proposals will need to be accompanied by transport assessments to ensure that the transport network can accommodate the generated traffic. We would caution against examining development impacts on a site by site basis only as this may overlook the impacts of Local Plan development as a whole. Looking at the Housing Land Allocations in Figure 7.2 there are numerous small sites that would have no impact upon the A12 or M25 although the aggregate impact for the smaller sites fully built out could add to queueing and delays on the two Strategic Road Network roads within the Borough. There should be a transport assessment of the overall Local Plan developments and the need for any mitigation identified. We would need to be assured by evidence that the overall Local Plan development has been considered if we are to support the Local Plan.

Full text:

FOR THE ATTENTION OF: The Planning Team
Brentwood Local Plan Response
Dear sirs,
Thank you for giving Highways England (HE) the opportunity to comment upon the Draft Local Development Plan setting out your development needs, policies and strategies over the next 15 years. Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
In the case of the Draft Local Development Plan, Highways England is interested in the potential impact that the development might have upon the M25 Junctions 28 and 29 and the A12. We would be concerned as to whether there would be any adverse safety implications or material increase in queues and delays on the strategic road network as a result of your Local Plan developments.
We have reviewed the Draft Development Plan and have the following comments
Policy 6.3 C covering general development criteria states that development proposals will need to be accompanied by transport assessments to ensure that the transport network can accommodate the generated traffic. We would caution against examining development impacts on a site by site basis only as this may overlook the impacts of Local Plan development as a whole. Looking at the Housing Land Allocations in Figure 7.2 there are numerous small sites that would have no impact upon the A12 or M25 although the aggregate impact for the smaller sites fully built out could add to queueing and delays on the two SRN roads within the Borough. There should be a transport assessment of the overall Local Plan developments and the need for any mitigation identified. We would need to be assured by evidence that the overall Local Plan development has been considered if we are to support the Local Plan.
We are pleased to see in Policy 6.3 C that you stipulate a requirement to consider safety as part of a transport assessment. Given the high speed nature of the M25 and A12 safety is a primary concern to Highways England and we would object to any safety implications of development, development traffic or highway mitigation.
As you know, in 2014 we were consulted by you and made comments on your suggested approach to the transport assessment for your Local Plan at that time. We have not heard further to this time any more details of an assessment but assume that you will still be undertaking such an assessment. We look forward to receiving your full Local Plan transport assessment in due course. Should you require further advice on transport related issues please do not hesitate to contact us.
Policy 8.8 relates to retail and commercial development. The policy calls for mitigation to the transport network where travel demand cannot be accommodated satisfactorily. Again, this approach suggests that any impacts are examined on an individual development basis. There is a risk in adopting this approach downstream for two reasons. Firstly, the full impacts of the local plan will not be considered, rather assessment of the larger developments only. Secondly, full impacts should be assessed within the Local Plan rather than at planning application stage, otherwise mitigation may be required that for whatever reason may be undeliverable.
Policy 10.1 covers sustainable transport. We are pleased to see a dedicated policy covering sustainable transport measures in addition to Policy 8.3 stating the need to locate development in accessible areas close to the arterial corridors M25, A12 and A127. To marry the two policies there will be a need to develop sustainable transport measures that manage down the private vehicle demand to and from these accessible developments. Policy 8.3 also states the need for employment development to be accessible by walking and cycling. Therefore, we will be keen to see what measures are to be adopted under your Local Plan to ensure that these policies are compatible.
We hope that you find these comments useful and we look forward to further correspondence in due course.
Sent on behalf of Janice Burgess (Spatial Planning Manager)

Comment

Draft Local Plan

Representation ID: 15728

Received: 11/05/2016

Respondent: Highways England

Representation Summary:

We are pleased to see in Policy 6.3 C that you stipulate a requirement to consider safety as part of a transport assessment. Given the high speed nature of the M25 and A12 safety is a primary concern to Highways England and we would object to any safety implications of development, development traffic or highway mitigation.

Full text:

FOR THE ATTENTION OF: The Planning Team
Brentwood Local Plan Response
Dear sirs,
Thank you for giving Highways England (HE) the opportunity to comment upon the Draft Local Development Plan setting out your development needs, policies and strategies over the next 15 years. Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
In the case of the Draft Local Development Plan, Highways England is interested in the potential impact that the development might have upon the M25 Junctions 28 and 29 and the A12. We would be concerned as to whether there would be any adverse safety implications or material increase in queues and delays on the strategic road network as a result of your Local Plan developments.
We have reviewed the Draft Development Plan and have the following comments
Policy 6.3 C covering general development criteria states that development proposals will need to be accompanied by transport assessments to ensure that the transport network can accommodate the generated traffic. We would caution against examining development impacts on a site by site basis only as this may overlook the impacts of Local Plan development as a whole. Looking at the Housing Land Allocations in Figure 7.2 there are numerous small sites that would have no impact upon the A12 or M25 although the aggregate impact for the smaller sites fully built out could add to queueing and delays on the two SRN roads within the Borough. There should be a transport assessment of the overall Local Plan developments and the need for any mitigation identified. We would need to be assured by evidence that the overall Local Plan development has been considered if we are to support the Local Plan.
We are pleased to see in Policy 6.3 C that you stipulate a requirement to consider safety as part of a transport assessment. Given the high speed nature of the M25 and A12 safety is a primary concern to Highways England and we would object to any safety implications of development, development traffic or highway mitigation.
As you know, in 2014 we were consulted by you and made comments on your suggested approach to the transport assessment for your Local Plan at that time. We have not heard further to this time any more details of an assessment but assume that you will still be undertaking such an assessment. We look forward to receiving your full Local Plan transport assessment in due course. Should you require further advice on transport related issues please do not hesitate to contact us.
Policy 8.8 relates to retail and commercial development. The policy calls for mitigation to the transport network where travel demand cannot be accommodated satisfactorily. Again, this approach suggests that any impacts are examined on an individual development basis. There is a risk in adopting this approach downstream for two reasons. Firstly, the full impacts of the local plan will not be considered, rather assessment of the larger developments only. Secondly, full impacts should be assessed within the Local Plan rather than at planning application stage, otherwise mitigation may be required that for whatever reason may be undeliverable.
Policy 10.1 covers sustainable transport. We are pleased to see a dedicated policy covering sustainable transport measures in addition to Policy 8.3 stating the need to locate development in accessible areas close to the arterial corridors M25, A12 and A127. To marry the two policies there will be a need to develop sustainable transport measures that manage down the private vehicle demand to and from these accessible developments. Policy 8.3 also states the need for employment development to be accessible by walking and cycling. Therefore, we will be keen to see what measures are to be adopted under your Local Plan to ensure that these policies are compatible.
We hope that you find these comments useful and we look forward to further correspondence in due course.
Sent on behalf of Janice Burgess (Spatial Planning Manager)

Comment

Draft Local Plan

Representation ID: 15946

Received: 12/05/2016

Respondent: West Horndon Parish Council

Representation Summary:

6.18 of the Draft Local Plan states that "In order for a scheme to be acceptable development will be required to make satisfactory arrangements for vehicular, cycle and pedestrian access into the site and for parking and servicing within the site". At present, the sites are served by a small entrance placed in a hazardous location below a blind hill created by the railway bridge, opposite the station, and on a busy road. Traffic is already considered dangerous in this location. Any redevelopment of the sites will need to be able to show an improvement in road layout safety, together with appropriate access consideration (one entrance/exit will be insufficient for size of proposed development). This point is repeated in Policy 6.4a of the Draft Local Plan: "Development proposals will be favourably considered where the planning and design of buildings and spaces - arrange access points, routes within the site, public and private spaces, building forms and ancillary functions in an efficient, safe, workable, spatially coherent and attractive manner".

Full text:

See eight attached documents

Attachments:

Comment

Draft Local Plan

Representation ID: 15985

Received: 11/05/2016

Respondent: Essex County Council

Representation Summary:

Criteria c. supported by ECC & consistant with NPPF. Policy should be expanded to have regard to the right location in respect of the current highway network and proposed improvements.
ECC proposes an amendment to the policy, which seeks to ensure the potential wider implications of the installation of new utility services in the vicinity of the highway network or proposed new highway network take account of the Highway Authority's land requirements, so as to not impede or add to the cost of the highway mitigation schemes.
`The location and route of new utility services in the vicinity of the highway network or proposed new highway network should take account of the Highway Authority's land requirements'.

Full text:

See attached

Attachments:

Comment

Draft Local Plan

Representation ID: 16105

Received: 16/05/2016

Respondent: EA Strategic Land LLP

Agent: Iceni Projects Limited

Representation Summary:

This policy is sound, in line with paragraph 58 of the NPPF; however, in applying the policy the Council should ensure that each assessment is made on a case-by-case basis having regard to the local context. The Council should consider inserting this into the policy to ensure flexibility.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 16133

Received: 16/05/2016

Respondent: Countryside Properties

Agent: Andrew Martin Planning Ltd

Representation Summary:

Policy 6.3 - General Development Criteria, requires proposals for development to meet all of nine specified criteria. These require a robust evidence base assessment of visual impact and landscape character, access and transport, health, noise impact, biodiversity, heritage, and impact on local services and community infrastructure. It is without question that the plan is not supported by a robust and complete assessment along these lines that would permit the identification of preferred allocations for growth and the rejection of alternatives.

Full text:

See attached

Attachments:

Comment

Draft Local Plan

Representation ID: 16489

Received: 19/05/2016

Respondent: CPREssex

Agent: Campaign for the Protection of Rural England (CPRE) Brentwood Branch

Representation Summary:

This Policy should be modified to show that in addition, actual compensation should be paid to immediate neighbors who experience a loss of amenity or actual home value reduction, in the event the Council grant planning permission in these circumstances.

Full text:

See attached.

Attachments: