I object to POLICY 7.1: DUNTON HILLS GARDEN VILLAGE for several reasons:
The size of the proposed development represents a concentrated expansion into land that has been designated as green belt to protect open green space and prevent urban sprawl. Whilst some green belt development could be deemed acceptable, it must be commensurate to the locality's supporting infrastructure, services and amenities.If this development as currently sized proceeds, a major chunk of the green belt will be used. If residential development creeps from within the boundary of the M25 outward beyond Upminster, we could imagine an urban corridor created through green belt.
A development of this size could eventually increase the local population in Dunton/ East Hordon by up to 10K with a proportion of this population which would ruin the villages of Dunton & West Hordon.
The development will increase rail passenger usage on C2c. Assuming a station is not developed, there is likely to be a large influx of commuters at the already busy stations of Laindon and West Horndon based on a development of this size.
In conclusion, the scale of this development poses many questions which the proposal lacks detail on, particularly on supporting infrastructure, roads, rail, services etc, plus there are the wider community and environmental impacts of removing such a large chunk of greenbelt.

I am very supportive of this. As a council, we must meet our housing target and I believe that having a "strategic site" for 2,500 homes is far better than having extra houses in all villages/parts of the borough

I do not support the provision of sites for gypsy and traveller accomodation

As set out in detail in Sport England's representations made on the 2015 consultation on this proposal, consideration will need to be given to the following matters when developing the masterplan for this proposal:

* The Dunton Hills Golf Centre will need to be retained or relocated unless it can be demonstrated that it is surplus to requirements through a needs assessment;
* The Council's emerging evidence base for sport (Sport and Leisure Study being prepared by PLC) should be used (together with Basildon BC's evidence base) to inform the scale and nature of community sports facility provision that will need to be provided on-site or off-site to meet the additional needs generated by a development of this scale
* Sport England & Public Health England's Active Design guidance should be used for guiding the masterplanning of the development in order to promote sport and physical activity in the new development and thereby help meet the local plan's wider strategic objective relating to promoting and enhancing health and well-being (SO11)

While the proposed masterplan would be expected to consider these matters, it is advocated that these issues are highlighted in the supporting text to policy 7.1 in order to provide a framework for the masterplan.

In principle I agree that new homes are needed, however, there are plenty of brown field sites around the Boroughs that are better re-developed than on valuable green belt land. If the green belt is eroded, as in this plan, there will be one continuous urban sprawl from London to Southend. The green belt is there for a purpose and must be protected. Canvey Island Council have refused to build on their green belt, and so should Brentwood.
The infrastructure in the area is already overloaded. The road system is always a nightmare for traffic, Basildon hospital cannot cope with volumes, there are no new secondary schools in the plan and a few small industrial facilities will not bring sufficient new employment for this volume of people. Doctor's surgeries are overloaded and we already can't get an appointment within 2 weeks.

Development on this scale is going to (once more) greatly increase the risk of flooding and destroy the environment and local cultural heritage.
Brentwood council and residents get a lot out of this plan. It helps Brentwood council meet their government targets, but there are hardly any Brentwood residents within miles of this development. It also keeps this additional development away from the affluent northern part of Brentwood - Shenfield etc. Clearly West Horndon is close, but is placed out of the way from the key areas of Brentwood.
Basildon already exceeds its obligations for (and costly) gypsy and traveller sites, and we do not need more in the area. Brentwood council should deliver their share but not immediately next to Basildon.
This plan should be either ditched completely, or drastically reduced in scope to minimise the impact and use other brownfield sites instead.

I do not agree with the proposal for building 4000 - 6000 homes as part of the the draft l plan. I do not believe that the local infrastructure will be able to sustain this extra population . The schools , GPs , roads & rail infrastructure is already at breaking point. The trains are overcrowded & people already have to stand and this is without extra people trying to use the services.The roads are already jammed. And it is already difficult for current residents to get places in local schools or see their gps.There are no plans in the document for a new secondary school to the west of the district to educate the extra children that the development will bring.
We will lose valuable green spaces and the impact on local wildlife will be devastating .
we need to protect the green belt to prevent London joining up with Southend in the East.The green belt acts a a buffer zone .
As obesity becomes more of an issue the lack of open spaces for children to play and people to exercise in for free will exacerbate this.This will in turn cause increased pressure on the NHS.
The more homes that are built will lead to an increase in traffic and this in turn will lead to poorer air quality and an increase in respiratory diseases . This will cause the NHS to become even more stretched.
The development should be shared throughout the whole of Brentwood and not just on the South Eastern Boundary with Basildon.

Disappointing that we are to loose this laarge chunk of greenbelt. Paarticularly so if the village is to contain traveller facilities as I imagine this will reduce the enthusiasm of potential village dwellers

Loss of Green Belt Land
Protection for green belt land is set out clearly in the National Planning Policy Framework (NPPF) with important clarification in the Planning Practice Guidance (PPG).
The NPPF section 79 says that "the essential characteristics of Green Belts are their openness and their permanence" The proposed site for Dunton Hills Garden Village covers an area of 250 hectares of green belt land including farm land and a golf course at Dunton Hills. Apart from the golf course (which has not harmed the utility of the land as green belt or its scenic quality), little has changed in the character of this area since the green belt boundaries were first defined over 50 years ago. Although precise plans have not been provided it is expected that about 250 hectares would be developed for up to 2500 homes with the possibility of a similar number adjacent in Basildon. Even on a national scale this would signal a significant acceleration in the loss of green belt land which cannot be considered only in isolation. If sections of land of this size are allowed to be removed from the green belt without justification other than the housing shortage then there is nothing to prevent the gradual loss of most of the green belts in the UK.
Section 80 of the NPPF described the five purposes of green belt all of which apply to the land which is proposed as the site for Dunton Garden Suburb as follows:
"to check the unrestricted sprawl of large built-up areas" : Basildon nearby can now be classed as a large built up area whose sprawl needs to be restricted by its green belt. Furthermore the green belt around Brentwood is part of the metropolitan green belt which protects us from the sprawl of London.
"to prevent neighbouring towns merging into one another" Basildon is currently separated from West Horndon by only two miles of green belt and this would be reduced to less than one mile if Dunton Hills Garden Village is build. The inclusion of the Brentwood Enterprise Park will lead to the development of much of the area between Upminster and West Hoendon. It would be a large and clear step towards the eventual coalescence of London with Basildon.
" to assist in safeguarding the countryside from encroachment " Dunton Hills is a scenic area of countryside with field boundaries that date back to at least the Middle Saxon era. It is home to important biodiversity and wildlife habitats. Building over this land would be a serious encroachment of the countryside
"to preserve the setting and special character of historic towns" Dunton Village next door in neighbouring Basildon is itself is a community mentioned in the doomsday book whose character is shaped by the history of Basildon. It includes a mobile homes park which houses many elderly and vulnerable residents who have been living there happily for many years with connections to the earlier plotlands areas. The new development at Dunton Hills would change the character of the present village of Dunton.
" to assist in urban regeneration, by encouraging the recycling of derelict and other urban land ." Such brownfields sites throughout the country should be redeveloped before any green belt land such as this can be touched
The construction of new housing on green belt land is classed as inappropriate development in section 89 of the NPPF and section 87 stipulates that this can only be allowed in "very exceptional circumstances" This means in section 88 that the harm must be "clearly outweighed by other considerations" As I will elaborate further below, the harm is very much greater than any other considerations. Circumstances that might be considered very exceptional could include the loss of small parts of green belt for a much needed school or hospital, certainly not the loss of large sections of it for ordinary housing.
I understand that in the case of Dunton Hills Garden Village the loss of green belt could take the form of a change in green belt boundaries through a green belt review. Section 83 of the NPPF says that "once established the green belt boundaries should only be altered in exceptional circumstances" The authorities must have "regard to their intended permanence in the long term" Since these areas of green belt have been established for decades there is no justification for making the changes that would be required to allow the building on Dunton Hills Garden Village. It would be flying in the face of the clearly stated intention that green belt should be permanent. The justification for such a large loss would have to be very substantial to justify the proposed harm. The current housing crisis can be resolved in other ways so it does not constitute such circumstances.
In considering a move which would lead to the loss of a large part of green belt land to housing the local authorities should take into account public opinion rather than pressure from developers and planning consultancies who stand to gain financially from their ability to build on cheaper green belt land. For example, a poll in The Guardian showed that 75% of the public who responded thought that houses should not be built on green belt land ( http://www.theguardian.com/commentisfree/poll/2014/mar/24/houses-built-in-green-belt ). In a poll in the maidenhead-advertiser 72.7% said that not enough was being done to protect the green belt ( http://www.maidenhead-advertiser.co.uk/News/Areas/Maidenhead/POLL-RESULTS-Is-enough-being-done-to-protect-the-greenbelt-16102014.htm )
Brentwood council has repeatedly claimed that it must build on green belt land to fulfil the Objectively Assessed Needs (OAN) for housing as prescribed by central government. This claim is false in two ways. Firstly the numbers produced by the councils for their OAN are too high. Secondly and even more importantly the government has made it absolutely clear that the calculation of the Objectively Assessed Need is only the first stage in the preparation of the local authorities housing targets. Paragraph 44 of the PPG answers the question "Do housing and economic needs override constraints on the use of land, such as Green Belt?" by saying that objectively assessed needs do not have to be met if the benefits of doing so would be significantly and demonstrably outweighed when assessed against adverse impacts. This includes where the policies of the NPPF indicate that development should be restricted including those related to land designated as Green Belt. In paragraph 45 which addresses the question "Do local planning authorities have to meet in full housing needs identified in needs assessments?" the PPG states that "assessing need is just the first stage in developing a Local Plan" and clarifies that when preparing an SHLAA the local authority should take into account "any constraints such as Green Belt, which indicate that development should be restricted and which may restrain the ability of an authority to meet its need." In paragraph 34 of the PPG on the question: "In decision taking, can unmet need for housing outweigh Green Belt Protection?" the answer is quite simply that "Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the 'very special circumstances' justifying inappropriate development on a site within the Green Belt."
Brentwood is immersed in green belt so can easily justify using the green belt as a constraint to reduce the housing target below their OAN once optimal use of all brownfield sites has been accounted for. Nevertheless they tell us they fear that when their local plan is submitted to the planning inspectorate it will be rejected if the OAN is not met by the targets. I have personally talked with the Rt Hon Eric Pickles MP to ask him if this is the case and he stated categorically that the planning inspectors will not be able to reject the plan for this reason because the policy is absolutely clear about the need to protect the green belt. Furthermore he told me that if local authorities have such concerns there is a scheme to let them seek advice from former inspectors.
What Eric Pickles has said to us about using green belt as a constraint was consistent with his public statements dating back to his completion of the NPPF. The situation was clarified again in Westminster during a debate on the NPPF on 5 th March 2015 when Brandon Lewis MP who is the minister for Housing and Planning said " The Government attach the highest importance to the protection of green belt. Our new guidance in October last year re-emphasised that importance, adding that the presence of constraints might limit the ability of planning authorities to meet their needs ." This prompted Laurence Robertson to say that " Some local authorities, however—this is happening in our joint core strategy area—will redesignate the green belt when submitting their local plan or the JCS, so that it is not green belt any more. If that is not a contravention of Government policy, I do not know what is. Can nothing be done about that ?" to which Brandon Lewis replied " A key consideration is that it should not be up to us in Westminster to decide what is important to the local area; it is up to the local council. We have put the protections in place—we have made it clear that development on green belt should be exceptional and the last resort, and even then should be carried out only with great care and consideration. If local authorities make a green belt area a developable piece of land, they should do so only as part of a full review and a local plan process. Indeed, there are examples of inspectors turning down such work if there is not a strong evidence base to show why the local authority wants it. So green belt should be redesignated only in exceptional circumstances and as a last resort. Furthermore, the NPPF notes green belt as one of the environmental constraints on development in the framework and local planning process. A core principle of the framework is that planning authorities should recognise the intrinsic character and beauty of their countryside. The characteristics of different landscape and the importance of ensuring that development is suitable for the local context should be recognised. As my hon. Friends have mentioned this afternoon, much countryside is loved and cherished by local communities. I acknowledge such concerns, and I will write to the Planning Inspectorate setting out publicly how the existing policy should operate, to ensure that it is fully understood not only by the inspectorate, but—to go back to my earlier point—by councils and councillors as well ."
In view of this there is absolutely no justification for Basildon or Brentwood Borough Councils to claim that they must build on green belt land to meet their OAN. On the contrary they should use the green belt as a constraint to reduce their housing targets and protect the green belt as required in the NPPF. In view of the statements by Eric Pickles and Brandon Lewis it seems more likely that the planning inspectorate would reject a plan that removes areas of the green belt without good reason beyond unmet housing need, than one which does not meet its OAN due to green belt constraints.
If the Councillors and planning officers of Brentwood and Basildon have any further doubts of this they can surely talk directly to Eric Pickles. If he is willing to discuss this with an ordinary member of the public such as myself who is not even one of his constituents I am sure he would also talk to them.
Any justification for the loss of green belt through exceptional circumstances must be evidence based. The PPG states that unmet housing needs is unlikely to outweigh the harm, therefore further justification is needed. No such evidence has been provided. Indeed the only other possible reason for the council's apparently strong desire to build on green belt land is the financial incentives provided by the government through schemes such as the New Homes Bonus which for Brentwood had risen to £798,685 in 2013-14 and which could rise to even higher levels if the councils ambitious targets for housing can be achieved. Further monetary incentives come from the Affordable Housing Program and through schemes such as the Thames Gateway project and the South East Local Enterprise Partnership.
I can understand that the councils are tempted to reach out for these grants and bonuses in the face of cuts from central government to funding allocations accompanied by rate caps. However, such short term financial pressures cannot be used as evidence to justify any loss of green belt land.
The housing shortage in the UK is a serious problem and I recognise the need for action, but this must be done with more vision. The housing density of London is only half that of the other major financial centres of the world; New York and Tokyo. Instead of saying that housing needs to be near London because of the availability of jobs there, we also need to look at ways of creating more new jobs in other areas of the country where growth would be more sustainable. If financial incentives from the government do not encourage the right planning aims then our local politicians need to lobby their government and political parties to put in place better policies that do.

Roads - The road network around Langdon Hills is only just able to cope with the demands currently being placed upon it adding a potential additional vehicles (if every property had two cars) to the local road network would bring the area to a standstill. The A127 from the Dunton junction is always jammed in the morning rush hour - and this is without the additional houses already being built around Dunton Fords coming on stream. Before any new homes are built our road network must be developed to accommodate the influx of vehicles - this cannot be left until after they are built as this will be too late and has the danger of never actually taking place due to funding constraints

Other infrastructure - Similarly our local infrastructure (hospital, schools, GP surgeries etc) also need to be improved before any new homes are developed as you cannot wait for an influx of between more if there are families people bring the already overstretched facilities grind to a halt. Similarly the Sporting Village is already incredibly busy with major parking problems most night

local train operators are already changing their timetables in a way that massively impacts on commuters from the Laindon and West Horndon areas. People are already paying thousands of pounds for the 'luxury' of being made to stand on their journey to London. This development will just further exacerbate this issue

It is vital we protect the green belt across the whole of the borough and not build on it - once it has gone its gone forever

This is not designed to be a NIMBY response - it is designed to point out the major negative impacts the proposed development will have and lodge my objections to the plans.

I strongly oppose the Dunton Hills Garden Village development. With plans to build 2500 homes, this would amount to about 6000 extra people, about 2/3 the amount of Langdon Hills, the village where I live. Here are the reasons why I oppose the development:
- Basildon and Southend hospitals are both on Red or Black Alerts during most of the winter this year due to lack of beds. Furthermore there is already a shortage of healthcare professionals to fill healthcare posts. This will be exacerbated due to erosion of pay in real terms and stress due to short staffing. The introduction of university fees on student nurses and forced contracts on junior doctors will make the situation far worse. Thus, the increase in population resulting from this development will further increase the pressure on hospital services.
- Local roads heavily congested at peak times, especially the A127.
- Pollution levels will be unacceptable due to the extra cars this development will generate and due to roads on standstill as a result of congested traffic.
- The trains are at capacity at peak time
- A secondary school is already needed in the Langdon Hills area as there are already 3 large primary schools nearby.
- Concern with GP surgeries. How will Doctors be found to fill posts as there is already a shortage of GPs in the UK? This will be exacerbated with the new forced contract by the government in August this year.
- Erosion of green belt land which will incur loss of wildlife habitat. Green belt was created to stop urban sprawl and building on it is against government policy unless in extreme circumstances. Using housing targets should not be allowed to constitute extreme circumstances.
- Floodings: the area is known to be prone to flooding. Such a large scale development will require extensive drainage, but where will this be directed to? This may precipitate floodings in the area itself and neighbourhood areas, especially the ones located at lower level.
- Austerity: funds will be insufficient to finance the infrastructure required for such a development to be sustainable. Here is what the letter that Basilson council sent today (21/03/16) announcing to residents: "As the government continues to reduce funding for local councils, the fact is that things are going to get tougher for all councils". So where will the funds needed come from? Essex County Council's funding is also reduced as mentioned by its leader: "Funding will fall by almost a quarter by the end of the decade", Basildon Echo, 9 December 2015.
Also why does Brentwood council push for most of its housing by the Basildon side and hardly any houses on its side? This means that the new residents will use Basildon's infrastructure and amenities that as I have described are currently already at breaking point. This large scale development is pushed to the Basildon side even though Brentwood is benefiting from Crossrail and vast improvement on the A12.

1) This land is green belt and should not be built upon.

2) I feel from the consultation meeting that this is Brentwood council getting Basildon to build houses on their land that should be built in Brentwood.

3) If Brentwood has to build houses build them on the A128 side of this plot. The A128 and the subsequent A127 roundabout are far bigger and less used.

4) The A127 itself is too small for the traffic now, let alone with 6000 + homes added to the usage.

5)Dunton A127 roundabout serves a main road into Laindon, A massive boot sale (Sundays and Wednesdays + bank holidays), Lower Dunton road , Ford test centre offices (1000's of employees all who drive), and soon houses built at the fortune of war are going to be finished and starting to use this small roundabout too.
It is a crazy idea to think that it can be used as an entrance for another 6000 homes, I am sure the highways agency will not readily approve it.

6) Small villages like Dunton are few and far between and the eradication of such places is further destruction of our English way of life.

7) we don't need this many houses anyway brentwood is going way over the amount of housing required by the government.

8) What about the strain on existing services in Basildon like schools and doctors, police, firemen etc I think we were told this amount of housing will warrant 5 primary schools and a secondary school where are they going to be located?

9) Why do we need this anyway all the flats in Basildon at Icon and Morello corner didn't exactly fly off the shelves did they??(I'm led to believe that some have yet to be sold) and the next stage has not been built probably due to lack of interest. ??

10) Basildon council and the highways authority have objected to plans for 50 houses further down lower Dunton road at Malgraves farm as it is not a road suited to any more traffic, so how can the other end of the same road be a viable option?

1) This land is green belt and should not be built upon.

2) I feel from the consultation meeting that this is Brentwood council getting Basildon to build houses on their land that should be built in Brentwood.

3) If Brentwood has to build houses build them on the A128 side of this plot. The A128 and the subsequent A127 roundabout are far bigger and less used.

4) The A127 itself is too small for the traffic now, let alone with 6000 + homes added to the usage.

5)Dunton A127 roundabout serves a main road into Laindon, A massive boot sale (Sundays and Wednesdays + bank holidays), Lower Dunton road , Ford test centre offices (1000's of employees all who drive), and soon houses built at the fortune of war are going to be finished and starting to use this small roundabout too.
It is a crazy idea to think that it can be used as an entrance for another 6000 homes, I am sure the highways agency will not readily approve it.

6) Small villages like Dunton are few and far between and the eradication of such places is further destruction of our English way of life.

7) we don't need this many houses anyway brentwood is going way over the amount of housing required by the government.

8) What about the strain on existing services in Basildon like schools and doctors, police, firemen etc I think we were told this amount of housing will warrant 5 primary schools and a secondary school where are they going to be located?

9) Why do we need this anyway all the flats in Basildon at Icon and Morello corner didn't exactly fly off the shelves did they??(I'm led to believe that some have yet to be sold) and the next stage has not been built probably due to lack of interest. ??

10) Basildon council and the highways authority have objected to plans for 50 houses further down lower Dunton road at Malgraves farm as it is not a road suited to any more traffic, so how can the other end of the same road be a viable option?

This development would remove a significant area of green belt land to the detriment of the local environment and would be against the wishes of local residents

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.

I object to the above development for the reasons below:-

1) This land is green belt and should not be built upon.

2) I feel from the consultation meeting that this is Brentwood council getting Basildon to build houses on their land that should be built in Brentwood.

3) If Brentwood has to build houses build them on the A128 side of this plot. The A128 and the subsequent A127 roundabout are far bigger and less used.

4) The A127 itself is too small for the traffic now, let alone with 6000 + homes added to the usage.

5)Dunton A127 roundabout serves a main road into Laindon, A massive boot sale (Sundays and Wednesdays + bank holidays), Lower Dunton road , Ford test centre offices (1000's of employees all who drive), and soon houses built at the fortune of war are going to be finished and starting to use this small roundabout too.
It is a crazy idea to think that it can be used as an entrance for another 6000 homes, I am sure the highways agency will not readily approve it.

6) Small villages like Dunton are few and far between and the eradication of such places is further destruction of our English way of life.

7) we don't need this many houses anyway brentwood is going way over the amount of housing required by the government.

8) What about the strain on existing services in Basildon like schools and doctors, police, firemen etc I think we were told this amount of housing will warrant 5 primary schools and a secondary school where are they going to be located?

9) Why do we need this anyway all the flats in Basildon at Icon and Morello corner didn't exactly fly off the shelves did they??(I'm led to believe that some have yet to be sold) and the next stage has not been built probably due to lack of interest. ??

10) Basildon council and the highways authority have objected to plans for 50 houses further down lower Dunton road at Malgraves farm as it is not a road suited to any more traffic, so how can the other end of the same road be a viable option?

This seems a very feasible & practical solution to the housing shortage within the Brentwood area. It is very close to road links (A127/A128 & M25) & also a railway link to London & Southend.
Although on green belt land it will include open spaces,schools & healthcare facilities.

Whilst I am not in favour of development of greenbelt land, I think that the Dunton Garden Village seems like a sensible solution to the problem of housing in the borough. As a resident of West Horndon, I am concerned about the effect of too much housing development on the size and character of the village but the Dunton Garden Village could still have a similar adverse effect. I wonder how the proposed additional Thames Crossing Development will affect the plans for the Dunton Garden Village.

I object there is no infastucture in place for this, our main A127 s failing & air pollution is rife as cars are at a standstill most mornings & evenings the A127 and Billericay road are backed up with traffic every morning ,More houses more traffic No No NO ,Greenbelt being demolished for the greed of this so called nec essary housing ,many already empty houses in Basildon & Brentwood fill these before you build more

I'm objecting because we need to keep greenbelt there is no special reason to build on this.
we do not need any more traffic on our local roads its already at standstill most mornings.A127 -a128 -Billericay road
no facilities to cope with more housing overcrowded schools ,doctors & hospitals on black alert

The Dunton Hills development is disgraceful. It results in a large loss of green belt land, which is unacceptable. We NEED to keep our green belt areas for wildlife. Half of the planets wildlife has been lost in just the last 40 years and most species are now struggling - all due to human expansion. We must put a stop to all expansion to protect whats left of our precious wildlife.

I do not think this is a good idea. We will lose the green belt land affecting the wildlife. there will be more congestion both on the main roads such as the A127 which are already bad enough even at 6am, where I am now queing to get on to the A127 at Dunton. The local streets are no better especially with all the potholes. The train station will be over crowded, I already have issues with people parking on corners etc to then walk to the station. This is becoming more and more dangerous.

Basildon Hospital is already at breaking point as are the doctors.

In Moderate rain we already have flood issues let alone if more greenbelt is built on. which will not allow water to drain in the soil. There is also a lack of a secondary school.

Why do we need to build all these extra houses? There has already been hundreds / thousands built at the back of dunton and on the old Laindon school site. Plus the ones planned for Dry street. The houses that keep popping up are not the type I would buy or even want to live in. I like the area for it's open spaces. Please keep it that way. The area is becoming too congested. I do not want to become an extension of London.

We object to this policy to propose a new settlement to deliver 2,500 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged.
We consider there to be both generic and site specific constraints to delivery and as such, the site is undeliverable over the timeframe envisaged in the housing trajectory. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF.
It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need, and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example nearby Uttlesford District Council.
A range of factors affect commencement and delivery of strategic sites including the number of builders involved, market demand and supply of sites, the economy, complexity of infrastructure, site conditions, pre-application requirements and developer contribution negotiations.
The Advisory Team for Large Application (ATLAS) produced a Strategic Sites Deliverability Advice Note (August 2014) for East Herts District Council on key infrastructure and site deliverability for emerging strategic sites.
This advises that the evidence base should identify critical/essential infrastructure, engage directly with timing issues, show flexibility in aligning the planning application process and plan preparation, consider a delivery plan, demonstrate contingency planning, clearly identify how, when and by whom masterplanning will be undertaken, and develop flexible site specific policies.
ATLAS further advised that the breadth and depth of evidence needed will vary depending upon when the development is expected to come forward. For delivery within the first five years of the Plan, as is the case for Dunton Hills Garden Village, a high degree of certainty is required.
The evidence base underpinning the Draft Plan does not appear to include any exploration of the developability or deliverability of this strategic site. We consider that such evidence is required in order for deliveries from Dunton Hills Garden Village to be considered robust and included in the trajectory.
We strongly believe that such an exploration would demonstrate that deliveries from this strategic allocation as early as 2019 will be unachievable, based on research and evidence produced by other local authorities.
For example, East Herts District Council commissioned a report by Peter Brett Associates (September 2015) to underpin four strategic sites ranging from 750 to 10,000 dwellings.
This reviewed research undertaken by ATLAS on delivery rates of strategic sites in the East of England between 1980 and 2005 which demonstrated the average time period between application submission and the first build year is about five years. This is from application, not Plan adoption and in some situations planning applications can be submitted ahead of Plan adoption, which could shorten this lag. In the case of Dunton Hills Garden Village an early application is unlikely since it lies within the Green Belt.
The report also found that due to a consolidation of house builders nationally, whilst it may have previously been sensible to assume 5-6 developers operating on a large site at any one time, a more realistic estimate is now 2-4 resulting in annual sales of between 70 and 200 dwellings.
The study estimated for each strategic site in East Herts a range of between 1 and 5 years to produce the Masterplan from Plan adoption and a further 3 to 7 years to submit and secure planning and start on site. For the 10,000 dwelling site, 15 plus years were estimated for the whole process.
Despite finding the Uttlesford Local Plan unsound, the Inspector in that instance found that the housing trajectory was generally sound, including that it did not rely upon completions on the strategic allocation during the first 5-year period.
The Brentwood housing trajectory envisages Dunton Hills Garden Village to start delivering within 2 years of adoption. In light of the above, we do not consider this to be a realistic timeframe. Deliveries from this site in the first five years of the Plan period should be removed from the trajectory and detailed evidence work undertaken to establish developability or deliverability of this strategic site.
There are no circumstances that suggest that Dunton Hills Garden Village can deliver more quickly than the five years recommended by the above research. Indeed, the evidence available suggests that the time lag may in fact be slower.
Much of the detail of policy 7.1 has been deferred to the Masterplan to form part of the Brentwood Local Development Plan. No timetable is given for the adoption of this Masterplan and no draft has yet been produced. It is assumed that it will follow adoption of the Local Plan, which is not anticipated until 2017.
A planning application cannot be approved ahead of adoption of the Plan, which could expedite delivery, since the site is within the Green Belt. The Green Belt boundary will have to be amended before it could be considered appropriate development and a developer is unlikely to invest in the breadth of site survey and evidence work required for a site of this scale on a Green Belt site prior to allocation.
Even following grant of planning permission, a scheme of this scale will have significant pre-implementation conditions and issues to be resolved at reserved matters stage, hence the average 5 year time lag to delivery.
In addition to the normal delivery problems associated with large sites, Dunton Hills Garden Village also faces unique site specific delivery constraints, including infrastructure constraints, local opposition, cross-border issues with adjacent Basildon Council and the Lower Thames Crossing link road.

The scant evidence base already identifies a number of constraints to the site for example the historic assets of the settlement of Dunton Village, the medieval field patterns in the area, medieval buildings and long-distance views towards St Mary the Virgin Church in Little Burstead.
It cannot be assumed that a more thorough exploration of the site will not uncover additional constraints.
A site of this scale will require significant infrastructure investment prior to delivery and whether the site is deliverable in highways terms has not been established. The consultation document states that the A127 is constrained and further work will need to be undertaken with the Highways Authority and Highways England to address capacity and traffic flow. The key diagram suggests that an enhanced junction will be required onto the A127.
The necessary infrastructure would have to be secured via a S106 agreement which is likely to be a complex legal document. Even for small schemes these typically take in excess of six months to a year to complete and a strategic scale site such as this could easily take considerably longer. This is exacerbated if they are in multiple ownership where complex legal agreements are required.
Given that a local action group, "Residents Against Inappropriate Development", already exists and are encouraging objection, it can be assumed that the strategic allocation will encounter considerable objection throughout the process. Whilst the existence of opposition groups will not necessarily prevent allocation and development since it will be for the Inspector to determine whether it represents sustainable development, it would be naïve to assume that such groups cannot delay delivery, even post allocation.
The proposed site for Dunton Hills Garden Village is adjacent to the Borough boundary with Basildon. Basildon are also proposing West Basildon Urban Extension; a mixed use development site against this same boundary through their Local Plan 2014 - 2034 under draft policy H10. This is to provide around 1,000 homes, a residential care/nursing home, and at least 5.5ha of employment land. It also proposes safeguarded land for the provision of around a further 1,350 homes, a residential care and/or nursing home and a 2fe primary school and a secondary school beyond the current plan period.
A Memorandum of Understanding between the two councils was signed to investigate whether land known as "Dunton Garden Suburb" had potential of meeting some of the development needs of both Councils through a cross boundary development opportunity, and a joint consultation was undertaken. However, this was effective for only 15 months and expired in February 2016.
In the absence of any formal agreement between the two councils, there is a lack of clarity as to how these two proposals are to work in conjunction with each other.
The Brentwood Plan states at paragraph 7.9 as follows:
Work will continue with adjoining authorities and other bodies as part of the Duty to Cooperate. This includes consideration of growth along the wider A127 Corridor as well as proposed development to the Brentwood border in Basildon.
Whilst this acknowledges the need to co-operate with neighbouring authorities, it gives no assurance that the duty has been complied with and does not suggest that the two sites will be brought forward together.
The Basildon Plan states at paragraph 11.88 as follows:
In January 2015, the Council consulted on a proposal jointly with Brentwood Borough Council which considered whether there was an opportunity to use land either side of the shared administrative boundary in this location to meet development needs for both local planning authorities, particularly housing needs. This proposal, termed 'Dunton Garden Suburb' was based on a high level appraisal of a community which could provide between 4,000 and 6,000 homes, a gypsy and traveller site, commercial buildings and supporting infrastructure. Given the variety of issues raised in the consultation, which are set out in the Dunton Garden Suburb Statement of Consultation (2015) it has not been possible for either Council to resolve this proposal in isolation to their Local Plans, but the exercise has served a purpose to determine if a cross boundary development could be an option in this location.
This suggests that cross boundary development is not an option in this location, supported by the fact that no agreement in place.
It is therefore apparent that the Brentwood allocation is intended to be a new settlement, whilst the Basildon allocation is intended to be an urban extension with no assessment of the impact each allocation will have on the other.
Paragraph 178 of the NPPF requires joint working to be "diligently undertaken" for "the mutual benefit of neighbouring authorities".
This cooperation does not apply only to joint working in order to meet development requirements which cannot be met within boundaries, but in all aspects of plan making which have cross boundary impacts.
Paragraph 180 requires local planning authorities to take account of different geographic areas including travel to work patterns.
Crucially, paragraph 181 states that local planning authorities are expected "to demonstrate evidence of having effectively cooperated to plan for issues with cross-boundary impacts when their Local Plans are submitted for examination." It goes on to explain that this should be a continuous process and result in plans which support current and projected levels of development.
This demonstrate a lack of lack of co-operation between the Councils. This raises serious concerns as to whether either can demonstrate compliance with the Duty to Co-operate and at the vey least indicates a lack of joined up thinking and due regard to how the two sites would operate alongside each other.
Far from being compatible, there are significant conflicts between Basildon's draft policy H10 and Brentwood policy 7.1.
Firstly, the Basildon allocation is proposed as an urban extension to Basildon, making use of services in Basildon. The Brentwood allocation is for a new settlement, which will be directly adjacent to this urban extension. Neither authority have addressed how these two allocations will operate alongside each other.
The Basildon policy proposes landscaped buffers should be provided to the northern and western boundaries of the sites, with the western landscaping being specifically in order to limit harm to the open landscape to the west.
The Brentwood policy proposes to locate a new settlement on this landscape.
The Basildon policy requires the design and layout of development to respect the historic assets of the settlement of Dunton Village, the medieval field patterns in the area, medieval buildings and long-distance views towards St Mary the Virgin Church in Little Burstead.
The Brentwood policy proposes to locate a new settlement in this area that Basildon seeks to preserve.
Land to the west of Basildon, as identified on the Policies Map with the notation H10b, will be safeguarded for the provision of around a further 1,350 high quality homes developed at a density of 30dph, a residential care and/or nursing home and a 2fe primary school beyond the current plan period. Additionally, land within this location must be reserved for the provision of a secondary school, as specified by the Essex County Council School Place Commissioning Service, and this land must be made available for the provision of a secondary school should the need arise, either during this plan period or the next.
The Brentwood policy also provides for a secondary school and there is no information to indicate whether these are likely to be linked, combined or simply just be geographically close to each other.
A final site specific issue facing Dunton Hills Garden Village is the potential for the site to be required to provide a new road from a new Thames Crossing to the M25.
Highways England are currently consulting on the Lower Thames Crossing, due to close on 24th March 2016. Two potential crossing locations and three potential route options have been identified north of the river in Essex and two south of the river in Kent.
One of the three north route options proposes a new road from the crossing following an easterly line via the existing A127 to the M25 at junction 29. This transects the proposed Dunton Hills Garden Village site diagonally from south east to north west. It would comprise a 70mph dual carriageway with separate northbound and southbound carriageways and would include upgrading of the A127/A1289 junction across the site.
If this new road were to proceed, it would result in loss of a significant proportion of the site, which may not leave enough land to deliver the 2,500 dwellings proposed. There would be significant problems with achieving linkages between the two halves of the site, if it were split by the new road. Furthermore, it could prevent delivery of the site entirely as it would present significant noise, air quality and vibration issues which could make development of the remainder of the site unsuitable.
The options are still open for consultation and no evidence that Brentwood Borough Council have consulted Highways England in regard to this and implications for the delivery of policy 7.1 has been presented.
The Basildon draft policy H10 includes a provision to have regard to the route, impacts and implications of the Lower Thames Crossing, should Route Option C be pursued by the Government during the plan period. The supporting text states that a decision on the preferred route will be taken in 2016 by the Secretary of State for Transport and if this route is selected there are potential highways and land use implications for this site which will need to be considered in the preparation of the masterplan/development brief for this site.
We contend that at the very least, the Brentwood draft policy 7.1 should contain a similar provision, in order to maintain flexibility over the plan period.
Paragraph 182 of the NPPF requires plans to be effective, in order to be considered sound. In order to be effective "the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities".
Finally, whilst the policy is clear that the new settlement is intended to meet the needs of Brentwood Borough, we seriously question whether this will occur in reality. Being physically attached to Basildon, Dunton Hills Garden Village is likely to integrate more with Basildon Borough than Brentwood and serve the housing needs of Basildon as opposed to Brentwood.
Brentwood Borough is dominated by its largest settlement Brentwood and suburbs Hutton, Shenfield, Pilgrim's Hatch, Warley and Brook Street; 70% of the population live in Brentwood town.
Whilst the Borough has been split into four sectors for the purpose of the spatial strategy, the evidence base does not show where housing need arises across the Borough in relation to these areas. However, it can be reasonably assumed that the need arises primarily from Brentwood Town. This is evidenced by the existing jobs and employment areas being focused on Brentwood.
As such, locating the new settlement to the edge of the Borough is not providing the need where it arises. Better transport linkages and closer employment opportunities exist in the neighbouring Borough, and as such, it is likely that market forces will result in Dunton Hills Garden Village serving the needs arising from Basildon, as opposed to Brentwood, despite is contributing to the Brentwood 'numbers'.
This is contrary to Strategic Objective 3, which is to plan for housing to meet the needs "of the Borough's population". It is also contrary to paragraph 47 of the NPPF which requires local plans to meet the full objectively assessed needs "in the housing market area". The Draft Local Plan is clear at paragraph 5.36 that Brentwood Borough is self-contained and occupies its own housing market area.
As demonstrated above, policy 7.1 is not positively prepared, justified, effective or consistent with national policy. It is not based on effective joint working and therefore does not satisfy the duty to co-operate. The delivery of policy 7.1 over the plan period is questionable; insufficient justification has been provided to demonstrate that all 2,500 dwellings can be delivered over the plan period. Furthermore, the potential Lower Thames Crossing route raises serious additional questions about deliverability of the site at all.
Given that policy 7.1 is relied upon heavily in delivering "a significant proportion" of the housing needs of the Borough and deliveries from this site are crucial to the ability to demonstrate a five year supply in the early years of the Plan period, unsoundness of this policy is sufficient to render the entire Plan unsound.
As such the Draft Plan is not justified, as required by paragraph 182 of the NPPF. It is not the most appropriate strategy when considered against reasonable alternatives. Reasonable alternatives exist, namely the allocation of more, smaller sites for housing adjacent to the Main Town, Village Service Centres and Larger Villages.

STRONGLY OBJECT
You are decimating an incredibly large area of green belt for this. This green belt land is vital for our wildlife!
Earth has lost half of its wildlife in the past 40 years and most species are now struggling, all because of human expansion! You will be adding to this dreadful figure by going ahead with this monstrous project!
7.6: "Although the site lies within Green Belt, development here can contribute to Green Belt purposes" - what a load of rubbish! how is DESTROYING something helping it???
Please stop this dreadful project going ahead!
7.7: "The development footprint will be de-allocated from Green Belt" - unbelievable! You CANNOT just reclassify something to suit your own needs! It is called Green Belt for a reason. It is PROECTED for a reason!!!
What about all the wildlife that currently live in that special bit of green belt land?? You are not giving any thought to what this will mean to them!

I object strongly to the proposed development at Dunton Garden Suburb. The infrastructure cannot cope at the moment. The A127 would need to be motorway standard at least. Hospitals/schools/doctors, etc, cannot cope and I do not want to see any traveller site provision at all. I do not want to see any green belt land or wildlife destroyed. I strongly object to Brentwood dumping its housing on Basildon's doorstep.

I object strongly to the proposed Dunton Garden Suburb. The infrastructure cannot cope at the moment, the A127 would need to be motorway standard at least, hospitals/schools/doctors, etc cannot cope. I object to any provision for travellers at all. I object strongly to the loss of green belt land and the destruction of wildlife.

I strongly object to the proposed Dunton Garden Suburb. The infrastructure cannot cope at the moment. The A127 is gridlocked every morning. Schools/hospitals/doctors, etc, cannot cope at the moment. I do not want any provision at all for travellers. I object strongly to the loss of green belt land and the destruction of the wildlife.

I strongly object to the proposed Dunton Garden Suburb. Infrastructure cannot cope at the moment, the A127 is gridlocked every morning and evening, schools/hospitals/doctors, etc are already bursting. I do not want any traveller site provision whatsoever. I object strongly to the loss of green belt and destruction of wildlife. I object to Brentwood dumping its housing plans on Basildon's doorstep.

this development would substantially change the rural location adding hugely to local traffic - which is already overwhelmed*. the proposed location is a much needed break between the urban sprawl of Havering and Basildon. the villages surrounding it are well established local communities and a development of this size would fundamentally change the whole area.
I don't doubt that the housing is needed. this is not the right location for it.
* I am equally opposed to Route 4/Lower Thames Crossing and see your proposals as part of a determined attempt to cram as much development into this location as you all think you can get away with.

The National Planning Policy Framework should be read as a whole: need alone is not the only factor to be considered when drawing up a Local Plan.
The Framework is clear that local planning authorities should, through their Local Plans, meet objectively assessed needs unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the Framework taken as a whole, or specific policies in the Framework indicate development should be restricted. Such policies include those relating to sites protected under the Birds and Habitats Directives, and/or designated as Sites of Special Scientific Interest; land designated as Green Belt, Local Green Space, an Area of Outstanding Natural Beauty, Heritage Coast or within a National Park or the Broads; designated heritage assets; and locations at risk of flooding or coastal erosion.
The Framework makes clear that, once established, Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan.
Unmet housing need (including for traveller sites) is unlikely to outweigh the harm to the Green Belt and other harm to constitute the "very special circumstances" justifying inappropriate development on a site within the Green Belt.
The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.
I wholly object to this development which is considered a wholly political move by Brentwood Council to avoid upsetting their voters. The development would if Basildon goes ahead with Policy H10 in their Local Plan completely negate the fundamental principle and aim of green belt to prevent urban sprawl. Furthermore because of its locality on the border of Basildon Borough it is clear that the necessary infrastructure and service providers in Basildon will bear the brunt of the impact of this development. There is only 400mtrs of green belt that acts as a buffer to prevent Basildon and Brentwood merging into one. As I understand it Brentwood Council have failed to carry out Green Belt, ecology, landscape and infrastructure assessments for the site. I do believe also that there is an over provision of traveller sites which does not conform to the latest guidance.

Further to the joint consultation with Basildon last year, I wish to object and disagree with the proposals on the following basis:

1. THE SIZE OF THE PROPOSAL

The impact of a potential 20,000 new residents and 12,000 cars on the local community will be devastating. The A127 is at a standstill in rush hour and the trains are packed full.

I question the need for the amount of houses that you state in the local plan, the houses will be particularly marketed by developers in London and attract an enormous influx of people who will use Basildon facilities but pay council tax to Brentwood.

In your paragraph 7.10 you state that ...."Land around West Horndon village remains a reasonable alternative because it can provide for similar development numbers towards local needs. However, it has not been selected as a preferred site in this Draft Plan owing to the impacts on the existing village, which would not be consistent with the emerging spatial strategy. It has also been considered that proposed redevelopment within West Horndon village will bring forward significant residential development, altering the character of the village but utilising brownfield land. Further development of Green Belt surrounding West Horndon is deemed disproportionate when considering the size of the existing village and how this fits with the spatial strategy for our Borough of villages."

I would very much like an explanation as to how Brentwood council are prepared to consider the Green belt surrounding West Horndon , but are in no way considering the larger impact on the tiny rural village of Dunton. By building right up to the Basildon border it leaves Basildon with no Green Belt but fulfills the social housing responsibility and traveller quota of Brentwood Council with little impact on the rest of Brentwood. The burden and mental anguish of seeing our community change beyond recognition remains purely with West Basildon residents in Langdon Hills and Dunton.

2. SEVERE LACK OF SUPPORTING INFRASTRUCTURE - Partiularly secondary schools


Basildon hospital, district nurses, maternity services and medical centres cannot cope with the medical needs of so many individuals.

Primary schools are oversubscribed, and secondary school provision has been an issue for years. There have been reducing child numbers in the Brentwood area, surely building 'pockets of houses' closer to these would make more sense, particularly with the Free schools that have opened/ are opening .

The roads are unbearable as it is around the Basildon District- Brentwood school buses are regularly late and delayed due to the volume of traffic.

3. LOSS OF AGRICULTURAL LAND, GREEN BELT SPACE AND RISK TO LOCAL WILDLIFE

There will be significant impact on our local wildlife and quality of life, especially from increased pollution. I question and object to the comments in paragraph 6. ..
'Although the site lies within Green Belt, development here can contribute to Green Belt purposes, such as restricting urban sprawl'.

Quite how this can be stated is beyond belief when your proposal for a Dunton Garden village will obliterate the green belt. Is this the answer - restrict further urban sprawl by building on the land that separates the villages.

4. ACCESS TO NEW DEVELOPMENT

If this preposterous and crude development goes ahead, access must be from the A128 roundabout to avoid negative impact in Langdon Hills.

5. ADDITIONAL TRAVELLER AND GIPSY SITE

It feels unjustified to dump Brentwood's traveller pitch responsibility on the border of Basildon. We would be sandwiched between 2 large traveller sites within 5 miles of each other along the A127.
In light of the recent Dale Farm debarcle, I find it extremely naïve to suggest that the provision of Traveller and Gipsy sites could be 'cohesive to the community' as stated in the Dunton garden suburb consultation. As mentioned by one of your councilors, this plan protects the villages of Brentwood and has little impact on Brentwood infrastructure.