Development at Dunton is unnecessary. Better to have high-density housing in existing urban areas, and lower the housing targets to account for green belt (as per NPPF guidance, which clearly states that green belt takes precedence over 'objective' need).

I object on the grounds that such a dense development will put further strain on a transport network that is already at maximum capacity. The A127 and A128 are already at a standstill in peak hours without further road users and associated pollution. Schools are at full capacity and there are no public transport links to Brentwood capable of servicing needs and a staged development wouldn't see medical and transport links developed until after the housing. The 35% designation for affordable housing will totally alter the local demographic. Existing homes locally are 2/3 bedroom bungalows with gardens whereas the proposed development uses much smaller personal space measures. The area is a recognised flood plain which is entirely at odds with the suitable allocation land for travellers pitches. The number of pitch allocations for the area is also disproportionate to the borough as a whole. The underlying need for additional housing was identified in previous consultations as migratory rather than existing resident demand. I therefore challenge the need for such high volumes of additional housing when a migratory population can move to available housing wherever it may be in the country as a whole.

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

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

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

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

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

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

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

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

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

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

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

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

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


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

I would like to wholeheartedly support the idea of this development.

I am 23, and want to live and breath in this area, enjoying wildlife, rather than see everything disappear under a smog of pollution, that kills both people and animals. The number of people fighting to use the same limited resources is ridiculous, and it will only get worse if this goes ahead.

This tiny little bit of Green Belt is more valuable than the vast swathes elsewhere in Brentwood, because it stops the south of the A127 becoming totally developed from London to Southend.

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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.

See attached.

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.

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.

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.

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.

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.

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.

The local plan does not seem to be very local to the rest of the borough considering of the proposed 5000 new homes 3000 are to be located in just 2 developments at the extreme edges of the borough. And relatively close to each other. So although these areas will have road links the people in them will not see themselves as part of Brentwood. They will gravitate towards other areas or centres. . These developments along with the proposed Enterprise areas in the A127 corridor will put too much strain on the junction of the A127 and the M25. The A127 is already congested. There is no provision for improvement whereas the A12 is being improved. The public transport from West Horndon to Brentwood town centre is infrequent and not fit for purposed if the size of the village is to be doubled. The Dunton Garden development although in the borough boundary will, to all intense purposes, be a development of Basildon (Laindon) and will have no connect physical connection to Brentwood and will have no identity with the Borough. So apart from achieving a quota of housing and gaining some local tax for the borough any additional economic benefits will fall to Basildon. The lack provision of school places in the local areas to these developments will lead to further traffic flows to and from the wider areas.

And in what order will the developments take place?

I would like to see the smaller developments take place first.
Organic growth will be much less intrusive and will allow the area to slowly digest the changes.
Only when these options have run out should larger developments on Green Belt land be considered. the used of Green Belt should be a last resort.

Dear Sir / Madam
I am writing to formally register my objection to the 'Brentwood Draft Local Plan' proposal, due to the negative impact I believe it will have on the surrounding communities. I, as I am sure many residents, have lots of questions with regards to this consultation. I have summarised my concerns and questions here with further explanations and questions explained in detail below.
Summary of questions:

1. Why is greenbelt land now being considered for declassification in and around the Brentwood / Basildon area?
1.1 The proposed land can often be seen throughout the year growing many varieties Vegetables, food and hay for livestock. Is this land no longer needed for agriculture?

2. What, if any, consideration has been given to the wildlife that will be impacted with such a large scale development on greenbelt land?
2.1 Has the Wildlife Trust, RSPB, Butterfly and Rare species groups been properly consulted on the wildlife in the proposed area?
2.1a Will their views, comments and professional advice be properly listened to and addressed?
2.2 What thoughts and considerations have been made to ensure that our wildlife continues to thrive?
2.3 Simply including a green space 'here and there' isn't sufficient as unlike humans wildlife knows no boundaries and by segregating them to a specific area will just encourage inbreeding, predation and further decline as they have nowhere else to go.
2.4 Will there be any considerations to wildlife corridors between open spaces allowing species to breed, migrate and exist safely and naturally?

3. Have all brownfield sites been considered and exhausted before planning on building on greenbelt land?
3.1 Why is it that greenbelt land appears to be more appealing than brownfield sites for developments?


4. Approx 2500 for Dunton Hills Garden Village! Does this truly reflect Brentwood towns growth expectations for the indigenous Brentwood people over the next few years?
4.1 Will these new homes be designated solely for the people of Brentwood? If not why not and please explain how this will be divided up.
4.2 Will the infrastructure as it stands cope with an increase in the new population
4.3 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village area?
4.4 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village
4.5 Schools, Hospitals, Emergency services are all under strain as it is. Are there plans to rectify this before the proposal of new buildings goes ahead?
4.6 Will there be any revisions to the proposal to consider allocations, both land and infrastructure for the likes of schools, hospitals and emergency services?
4.7 Can Brentwood cope with the additional waste, landfill and sewage that will be created?
4.8 What measures are going to be put in place and enforced to ensure a good level of air quality? Surrounding areas are already fairly high!
4.8 Who will foot the bill for all of the above?

5. With the ever increasing worry and risk of flooding, what assurances can the residents of Brentwood and the new residents of the Dunton Hills Garden Village that they won't be affected by any increases in flooding?
5.1 We have already seen that parts of the A127, Lower Dunton Road and some minor roads are prone to flooding due to either surface water or road drainage systems backing up. Will these be addressed especially since the new development will be partly built on flood plains?

6. West Basildon's and South West Brentwood's greenbelt land is land that we must save and preserve. Not just for our wildlife, health and wellbeing but with the proposed Lower Thames Crossing; the London sprawl and housing development will bring the end of Essex as a community and Brentwood and Basildon as towns.

Detail:
As mentioned at the start of my letter I am writing to formally register my objection to the 'Brentwood Draft Local Plan', due to the negative impact I believe it will have on the surrounding greenbelt areas, wildlife and communities. In fact this development will have far greater reaching impacts for anyone living, traveling or passing through South Essex. We should be proud of the green belt areas that surround our area and look to protect them for many years and generations to come. These areas should be the last place considered for building new properties especially when there are so many brown field sites yet to be improved and are suitable for housing development. It's madness that there is more red tape for developing brown field sites than on green belt land!
Simply declassifying green belt land (because it is easier than utilising brown field sites) without specialist investigation in to the species that use this as their habitat and home is unacceptable. There have been many sightings and recordings of wildlife in the area which include the following some of which are protected species and can be found in and around the Dunton Essex Wildlife Trust nature reserve. (Not an exhaustive list by any means):
- The following species are all found in the area and they are also in the UK Biodiversity Action Plan:- Water voles (legally protected and endangered) , Grizzled Skipper butterfly (legally protected and endangered) , Great Crested Newts (protected) , Slow Worm, Grass Snake, Cuckoo, Song Thrush, House Sparrow, Tree Sparrow, Turtle Dove, Wood Warbler. The following are also found in the area and will disappear should the proposal get passed:- Bats (protected), Badgers (protected), Adders (protected) , Kingfishers, Bullfinches, Buzzards, Sparrow Hawks, Owls, (Tawny, Barn and Short Eared Owl), Foxes, Rabbit, Deer. Although Dormice (legally protected and endangered) have not yet been found in the area because surveys have not been conducted, they have been found in neighbouring village of Stock within Billericay, not 10 minutes from the proposed site so there is an extremely high possibility that they are also in the area. Dormice are also a protected and endangered species.
- There are also many trees, plants and vegetation that would be lost that provide as homes and food for all of the above
- Roadside verges seem to be shrinking and are even being cleared which was once enforced by Basildon Council to help preserve and encourage wildlife to flourish. This can clearly be seen on the verges and central reservation of the A127 between Basildon and Dunton Junctions.

We are fortunate to have the Dunton Essex Wildlife Trust nature reserve where we can escape from the hustle and bustle of normal daily commuter life. There are very few places in Basildon where you can get to see beautiful countryside that hasn't been developed or see fields that haven't been concreated over. The views across to London from the top of Dunton reserve are amazing and will be lost forever should this development go ahead. These views have recently seen a Solar farm built directly opposite this reserve and now we are hearing of a proposed wind farm. More worryingly is that these views that we enjoy are a home, a habitat that links together to keep the great British wildlife flourishing. Nature doesn't understand boundaries and needs natural pathways, links and open spaces from one site to another to enable species (animals, insects and vegetation) to exist.

With the development of Dry Street now going ahead we will be putting a massive obstacle between two reserves (Langdon Hills Country Park & Dunton Essex Wildlife Trust nature reserve) which will unquestionably have a massive effect on these species. Now we are planning on doing the same between Dunton Essex Wildlife Trust nature reserve and Thorndon Country Park!

With an existing infrastructure that is already showing signs of excessive strain how is Basildon supposed to cope?
Basildon Hospital is already under pressure and it took over 4 hours for me to be seen in A&E when I had stiches in my leg due to a recent accident. Local Doctor Surgeries are also stretched and it can take me weeks to get an appointment with my doctor and inevitably I get to see a locum and not my allocated doctor. How will the local health services be improved to accommodate such a huge influx of people? What provisions for both land and infrastructure has been considered for Basildon hospital especially with the development of Dry Street?
The main transport routes of the A12, A127 and A13 are already stressed to breaking point . The sheer volume of traffic can bring both roads to a standstill and is a frequent occurrence during rush hour times, and that is before adding in the effects of any incidents or accidents. Even travelling down the A127 during the day is restricted rendering the speed cameras pretty much ineffective these days. When these main routes are blocked traffic spills into neighbouring side roads creating yet more traffic and pollution for our area. What plans have been taken to make the necessary improvements to these roads alleviating the already high volume of traffic and to cater for the obvious traffic that new properties will create? And that is not only new properties in the Brentwood area but also development sites stretching from Southend to London along the A127 and Colchester to London along the A12 as anyone who uses these two main routes will be affected.

The local Primary Schools in Langdon Hills are regularly oversubscribed meaning children have to pass their local school to go to another. Some families are even divided forcing siblings to attend different schools due to being oversubscribed. With the proposal of "affordable housing" you must expect many families with children to move in so why isn't there more schools being planned within the proposal. Where will the new Brentwood residents be expected to take their children to school?

** Wouldn't you agree that we have the right to protect our green belt land. Exhaust our brownfield sites and say enough is enough, we are full? Surely more properties for Brentwood brings us very close to its limits of being full! **

The local services can't handle the existing numbers of residents , so to propose to add many thousands more, without providing any level of detail within the proposal as to how they would be catered for is not the way a council with a responsible planning policy should behave. There needs to be more detail and information on infrastructure and services that will be planned. Tell us how much extra capacity you plan for the local transport links. As it stands there can only be negative impacts on our local infrastructure, natural beauty spots and way of life if this proposal were to proceed. Local services such as schools and healthcare will suffer, the extra congestion will make travel miserable, employment opportunities may be spread even more thinly, and the environmental effects of the construction and extra population could be disastrous. Is Brentwood & Basildon to become the new London? A place where you can't enjoy the country, a place where you can't drive your car and a place that is stupidly overcrowded!
Please register my vehement objection to this proposal , and ensure that this is taken into account.
Yours Sincerely
Marc Godfree

Dear Sir / Madam
I am writing to formally register my objection to the 'Brentwood Draft Local Plan' proposal, due to the negative impact I believe it will have on the surrounding communities. I, as I am sure many residents, have lots of questions with regards to this consultation. I have summarised my concerns and questions here with further explanations and questions explained in detail below.
Summary of questions:

1. Why is greenbelt land now being considered for declassification in and around the Brentwood / Basildon area?
1.1 The proposed land can often be seen throughout the year growing many varieties Vegetables, food and hay for livestock. Is this land no longer needed for agriculture?

2. What, if any, consideration has been given to the wildlife that will be impacted with such a large scale development on greenbelt land?
2.1 Has the Wildlife Trust, RSPB, Butterfly and Rare species groups been properly consulted on the wildlife in the proposed area?
2.1a Will their views, comments and professional advice be properly listened to and addressed?
2.2 What thoughts and considerations have been made to ensure that our wildlife continues to thrive?
2.3 Simply including a green space 'here and there' isn't sufficient as unlike humans wildlife knows no boundaries and by segregating them to a specific area will just encourage inbreeding, predation and further decline as they have nowhere else to go.
2.4 Will there be any considerations to wildlife corridors between open spaces allowing species to breed, migrate and exist safely and naturally?

3. Have all brownfield sites been considered and exhausted before planning on building on greenbelt land?
3.1 Why is it that greenbelt land appears to be more appealing than brownfield sites for developments?


4. Approx 2500 for Dunton Hills Garden Village! Does this truly reflect Brentwood towns growth expectations for the indigenous Brentwood people over the next few years?
4.1 Will these new homes be designated solely for the people of Brentwood? If not why not and please explain how this will be divided up.
4.2 Will the infrastructure as it stands cope with an increase in the new population
4.3 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village area?
4.4 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village
4.5 Schools, Hospitals, Emergency services are all under strain as it is. Are there plans to rectify this before the proposal of new buildings goes ahead?
4.6 Will there be any revisions to the proposal to consider allocations, both land and infrastructure for the likes of schools, hospitals and emergency services?
4.7 Can Brentwood cope with the additional waste, landfill and sewage that will be created?
4.8 What measures are going to be put in place and enforced to ensure a good level of air quality? Surrounding areas are already fairly high!
4.8 Who will foot the bill for all of the above?

5. With the ever increasing worry and risk of flooding, what assurances can the residents of Brentwood and the new residents of the Dunton Hills Garden Village that they won't be affected by any increases in flooding?
5.1 We have already seen that parts of the A127, Lower Dunton Road and some minor roads are prone to flooding due to either surface water or road drainage systems backing up. Will these be addressed especially since the new development will be partly built on flood plains?

6. West Basildon's and South West Brentwood's greenbelt land is land that we must save and preserve. Not just for our wildlife, health and wellbeing but with the proposed Lower Thames Crossing; the London sprawl and housing development will bring the end of Essex as a community and Brentwood and Basildon as towns.

Detail:
As mentioned at the start of my letter I am writing to formally register my objection to the 'Brentwood Draft Local Plan', due to the negative impact I believe it will have on the surrounding greenbelt areas, wildlife and communities. In fact this development will have far greater reaching impacts for anyone living, traveling or passing through South Essex. We should be proud of the green belt areas that surround our area and look to protect them for many years and generations to come. These areas should be the last place considered for building new properties especially when there are so many brown field sites yet to be improved and are suitable for housing development. It's madness that there is more red tape for developing brown field sites than on green belt land!
Simply declassifying green belt land (because it is easier than utilising brown field sites) without specialist investigation in to the species that use this as their habitat and home is unacceptable. There have been many sightings and recordings of wildlife in the area which include the following some of which are protected species and can be found in and around the Dunton Essex Wildlife Trust nature reserve. (Not an exhaustive list by any means):
- The following species are all found in the area and they are also in the UK Biodiversity Action Plan:- Water voles (legally protected and endangered) , Grizzled Skipper butterfly (legally protected and endangered) , Great Crested Newts (protected) , Slow Worm, Grass Snake, Cuckoo, Song Thrush, House Sparrow, Tree Sparrow, Turtle Dove, Wood Warbler. The following are also found in the area and will disappear should the proposal get passed:- Bats (protected), Badgers (protected), Adders (protected) , Kingfishers, Bullfinches, Buzzards, Sparrow Hawks, Owls, (Tawny, Barn and Short Eared Owl), Foxes, Rabbit, Deer. Although Dormice (legally protected and endangered) have not yet been found in the area because surveys have not been conducted, they have been found in neighbouring village of Stock within Billericay, not 10 minutes from the proposed site so there is an extremely high possibility that they are also in the area. Dormice are also a protected and endangered species.
- There are also many trees, plants and vegetation that would be lost that provide as homes and food for all of the above
- Roadside verges seem to be shrinking and are even being cleared which was once enforced by Basildon Council to help preserve and encourage wildlife to flourish. This can clearly be seen on the verges and central reservation of the A127 between Basildon and Dunton Junctions.

We are fortunate to have the Dunton Essex Wildlife Trust nature reserve where we can escape from the hustle and bustle of normal daily commuter life. There are very few places in Basildon where you can get to see beautiful countryside that hasn't been developed or see fields that haven't been concreated over. The views across to London from the top of Dunton reserve are amazing and will be lost forever should this development go ahead. These views have recently seen a Solar farm built directly opposite this reserve and now we are hearing of a proposed wind farm. More worryingly is that these views that we enjoy are a home, a habitat that links together to keep the great British wildlife flourishing. Nature doesn't understand boundaries and needs natural pathways, links and open spaces from one site to another to enable species (animals, insects and vegetation) to exist.

With the development of Dry Street now going ahead we will be putting a massive obstacle between two reserves (Langdon Hills Country Park & Dunton Essex Wildlife Trust nature reserve) which will unquestionably have a massive effect on these species. Now we are planning on doing the same between Dunton Essex Wildlife Trust nature reserve and Thorndon Country Park!

With an existing infrastructure that is already showing signs of excessive strain how is Basildon supposed to cope?
Basildon Hospital is already under pressure and it took over 4 hours for me to be seen in A&E when I had stiches in my leg due to a recent accident. Local Doctor Surgeries are also stretched and it can take me weeks to get an appointment with my doctor and inevitably I get to see a locum and not my allocated doctor. How will the local health services be improved to accommodate such a huge influx of people? What provisions for both land and infrastructure has been considered for Basildon hospital especially with the development of Dry Street?
The main transport routes of the A12, A127 and A13 are already stressed to breaking point . The sheer volume of traffic can bring both roads to a standstill and is a frequent occurrence during rush hour times, and that is before adding in the effects of any incidents or accidents. Even travelling down the A127 during the day is restricted rendering the speed cameras pretty much ineffective these days. When these main routes are blocked traffic spills into neighbouring side roads creating yet more traffic and pollution for our area. What plans have been taken to make the necessary improvements to these roads alleviating the already high volume of traffic and to cater for the obvious traffic that new properties will create? And that is not only new properties in the Brentwood area but also development sites stretching from Southend to London along the A127 and Colchester to London along the A12 as anyone who uses these two main routes will be affected.

The local Primary Schools in Langdon Hills are regularly oversubscribed meaning children have to pass their local school to go to another. Some families are even divided forcing siblings to attend different schools due to being oversubscribed. With the proposal of "affordable housing" you must expect many families with children to move in so why isn't there more schools being planned within the proposal. Where will the new Brentwood residents be expected to take their children to school?

** Wouldn't you agree that we have the right to protect our green belt land. Exhaust our brownfield sites and say enough is enough, we are full? Surely more properties for Brentwood brings us very close to its limits of being full! **

The local services can't handle the existing numbers of residents , so to propose to add many thousands more, without providing any level of detail within the proposal as to how they would be catered for is not the way a council with a responsible planning policy should behave. There needs to be more detail and information on infrastructure and services that will be planned. Tell us how much extra capacity you plan for the local transport links. As it stands there can only be negative impacts on our local infrastructure, natural beauty spots and way of life if this proposal were to proceed. Local services such as schools and healthcare will suffer, the extra congestion will make travel miserable, employment opportunities may be spread even more thinly, and the environmental effects of the construction and extra population could be disastrous. Is Brentwood & Basildon to become the new London? A place where you can't enjoy the country, a place where you can't drive your car and a place that is stupidly overcrowded!
Please register my vehement objection to this proposal , and ensure that this is taken into account.
Yours Sincerely
Marc Godfree

Dear Sir / Madam
I am writing to formally register my objection to the 'Brentwood Draft Local Plan' proposal, due to the negative impact I believe it will have on the surrounding communities. I, as I am sure many residents, have lots of questions with regards to this consultation. I have summarised my concerns and questions here with further explanations and questions explained in detail below.
Summary of questions:

1. Why is greenbelt land now being considered for declassification in and around the Brentwood / Basildon area?
1.1 The proposed land can often be seen throughout the year growing many varieties Vegetables, food and hay for livestock. Is this land no longer needed for agriculture?

2. What, if any, consideration has been given to the wildlife that will be impacted with such a large scale development on greenbelt land?
2.1 Has the Wildlife Trust, RSPB, Butterfly and Rare species groups been properly consulted on the wildlife in the proposed area?
2.1a Will their views, comments and professional advice be properly listened to and addressed?
2.2 What thoughts and considerations have been made to ensure that our wildlife continues to thrive?
2.3 Simply including a green space 'here and there' isn't sufficient as unlike humans wildlife knows no boundaries and by segregating them to a specific area will just encourage inbreeding, predation and further decline as they have nowhere else to go.
2.4 Will there be any considerations to wildlife corridors between open spaces allowing species to breed, migrate and exist safely and naturally?

3. Have all brownfield sites been considered and exhausted before planning on building on greenbelt land?
3.1 Why is it that greenbelt land appears to be more appealing than brownfield sites for developments?


4. Approx 2500 for Dunton Hills Garden Village! Does this truly reflect Brentwood towns growth expectations for the indigenous Brentwood people over the next few years?
4.1 Will these new homes be designated solely for the people of Brentwood? If not why not and please explain how this will be divided up.
4.2 Will the infrastructure as it stands cope with an increase in the new population
4.3 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village area?
4.4 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village
4.5 Schools, Hospitals, Emergency services are all under strain as it is. Are there plans to rectify this before the proposal of new buildings goes ahead?
4.6 Will there be any revisions to the proposal to consider allocations, both land and infrastructure for the likes of schools, hospitals and emergency services?
4.7 Can Brentwood cope with the additional waste, landfill and sewage that will be created?
4.8 What measures are going to be put in place and enforced to ensure a good level of air quality? Surrounding areas are already fairly high!
4.8 Who will foot the bill for all of the above?

5. With the ever increasing worry and risk of flooding, what assurances can the residents of Brentwood and the new residents of the Dunton Hills Garden Village that they won't be affected by any increases in flooding?
5.1 We have already seen that parts of the A127, Lower Dunton Road and some minor roads are prone to flooding due to either surface water or road drainage systems backing up. Will these be addressed especially since the new development will be partly built on flood plains?

6. West Basildon's and South West Brentwood's greenbelt land is land that we must save and preserve. Not just for our wildlife, health and wellbeing but with the proposed Lower Thames Crossing; the London sprawl and housing development will bring the end of Essex as a community and Brentwood and Basildon as towns.

Detail:
As mentioned at the start of my letter I am writing to formally register my objection to the 'Brentwood Draft Local Plan', due to the negative impact I believe it will have on the surrounding greenbelt areas, wildlife and communities. In fact this development will have far greater reaching impacts for anyone living, traveling or passing through South Essex. We should be proud of the green belt areas that surround our area and look to protect them for many years and generations to come. These areas should be the last place considered for building new properties especially when there are so many brown field sites yet to be improved and are suitable for housing development. It's madness that there is more red tape for developing brown field sites than on green belt land!
Simply declassifying green belt land (because it is easier than utilising brown field sites) without specialist investigation in to the species that use this as their habitat and home is unacceptable. There have been many sightings and recordings of wildlife in the area which include the following some of which are protected species and can be found in and around the Dunton Essex Wildlife Trust nature reserve. (Not an exhaustive list by any means):
- The following species are all found in the area and they are also in the UK Biodiversity Action Plan:- Water voles (legally protected and endangered) , Grizzled Skipper butterfly (legally protected and endangered) , Great Crested Newts (protected) , Slow Worm, Grass Snake, Cuckoo, Song Thrush, House Sparrow, Tree Sparrow, Turtle Dove, Wood Warbler. The following are also found in the area and will disappear should the proposal get passed:- Bats (protected), Badgers (protected), Adders (protected) , Kingfishers, Bullfinches, Buzzards, Sparrow Hawks, Owls, (Tawny, Barn and Short Eared Owl), Foxes, Rabbit, Deer. Although Dormice (legally protected and endangered) have not yet been found in the area because surveys have not been conducted, they have been found in neighbouring village of Stock within Billericay, not 10 minutes from the proposed site so there is an extremely high possibility that they are also in the area. Dormice are also a protected and endangered species.
- There are also many trees, plants and vegetation that would be lost that provide as homes and food for all of the above
- Roadside verges seem to be shrinking and are even being cleared which was once enforced by Basildon Council to help preserve and encourage wildlife to flourish. This can clearly be seen on the verges and central reservation of the A127 between Basildon and Dunton Junctions.

We are fortunate to have the Dunton Essex Wildlife Trust nature reserve where we can escape from the hustle and bustle of normal daily commuter life. There are very few places in Basildon where you can get to see beautiful countryside that hasn't been developed or see fields that haven't been concreated over. The views across to London from the top of Dunton reserve are amazing and will be lost forever should this development go ahead. These views have recently seen a Solar farm built directly opposite this reserve and now we are hearing of a proposed wind farm. More worryingly is that these views that we enjoy are a home, a habitat that links together to keep the great British wildlife flourishing. Nature doesn't understand boundaries and needs natural pathways, links and open spaces from one site to another to enable species (animals, insects and vegetation) to exist.

With the development of Dry Street now going ahead we will be putting a massive obstacle between two reserves (Langdon Hills Country Park & Dunton Essex Wildlife Trust nature reserve) which will unquestionably have a massive effect on these species. Now we are planning on doing the same between Dunton Essex Wildlife Trust nature reserve and Thorndon Country Park!

With an existing infrastructure that is already showing signs of excessive strain how is Basildon supposed to cope?
Basildon Hospital is already under pressure and it took over 4 hours for me to be seen in A&E when I had stiches in my leg due to a recent accident. Local Doctor Surgeries are also stretched and it can take me weeks to get an appointment with my doctor and inevitably I get to see a locum and not my allocated doctor. How will the local health services be improved to accommodate such a huge influx of people? What provisions for both land and infrastructure has been considered for Basildon hospital especially with the development of Dry Street?
The main transport routes of the A12, A127 and A13 are already stressed to breaking point . The sheer volume of traffic can bring both roads to a standstill and is a frequent occurrence during rush hour times, and that is before adding in the effects of any incidents or accidents. Even travelling down the A127 during the day is restricted rendering the speed cameras pretty much ineffective these days. When these main routes are blocked traffic spills into neighbouring side roads creating yet more traffic and pollution for our area. What plans have been taken to make the necessary improvements to these roads alleviating the already high volume of traffic and to cater for the obvious traffic that new properties will create? And that is not only new properties in the Brentwood area but also development sites stretching from Southend to London along the A127 and Colchester to London along the A12 as anyone who uses these two main routes will be affected.

The local Primary Schools in Langdon Hills are regularly oversubscribed meaning children have to pass their local school to go to another. Some families are even divided forcing siblings to attend different schools due to being oversubscribed. With the proposal of "affordable housing" you must expect many families with children to move in so why isn't there more schools being planned within the proposal. Where will the new Brentwood residents be expected to take their children to school?

** Wouldn't you agree that we have the right to protect our green belt land. Exhaust our brownfield sites and say enough is enough, we are full? Surely more properties for Brentwood brings us very close to its limits of being full! **

The local services can't handle the existing numbers of residents , so to propose to add many thousands more, without providing any level of detail within the proposal as to how they would be catered for is not the way a council with a responsible planning policy should behave. There needs to be more detail and information on infrastructure and services that will be planned. Tell us how much extra capacity you plan for the local transport links. As it stands there can only be negative impacts on our local infrastructure, natural beauty spots and way of life if this proposal were to proceed. Local services such as schools and healthcare will suffer, the extra congestion will make travel miserable, employment opportunities may be spread even more thinly, and the environmental effects of the construction and extra population could be disastrous. Is Brentwood & Basildon to become the new London? A place where you can't enjoy the country, a place where you can't drive your car and a place that is stupidly overcrowded!
Please register my vehement objection to this proposal , and ensure that this is taken into account.
Yours Sincerely
Marc Godfree

Dear Sir / Madam
I am writing to formally register my objection to the 'Brentwood Draft Local Plan' proposal, due to the negative impact I believe it will have on the surrounding communities. I, as I am sure many residents, have lots of questions with regards to this consultation. I have summarised my concerns and questions here with further explanations and questions explained in detail below.
Summary of questions:

1. Why is greenbelt land now being considered for declassification in and around the Brentwood / Basildon area?
1.1 The proposed land can often be seen throughout the year growing many varieties Vegetables, food and hay for livestock. Is this land no longer needed for agriculture?

2. What, if any, consideration has been given to the wildlife that will be impacted with such a large scale development on greenbelt land?
2.1 Has the Wildlife Trust, RSPB, Butterfly and Rare species groups been properly consulted on the wildlife in the proposed area?
2.1a Will their views, comments and professional advice be properly listened to and addressed?
2.2 What thoughts and considerations have been made to ensure that our wildlife continues to thrive?
2.3 Simply including a green space 'here and there' isn't sufficient as unlike humans wildlife knows no boundaries and by segregating them to a specific area will just encourage inbreeding, predation and further decline as they have nowhere else to go.
2.4 Will there be any considerations to wildlife corridors between open spaces allowing species to breed, migrate and exist safely and naturally?

3. Have all brownfield sites been considered and exhausted before planning on building on greenbelt land?
3.1 Why is it that greenbelt land appears to be more appealing than brownfield sites for developments?


4. Approx 2500 for Dunton Hills Garden Village! Does this truly reflect Brentwood towns growth expectations for the indigenous Brentwood people over the next few years?
4.1 Will these new homes be designated solely for the people of Brentwood? If not why not and please explain how this will be divided up.
4.2 Will the infrastructure as it stands cope with an increase in the new population
4.3 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village area?
4.4 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village
4.5 Schools, Hospitals, Emergency services are all under strain as it is. Are there plans to rectify this before the proposal of new buildings goes ahead?
4.6 Will there be any revisions to the proposal to consider allocations, both land and infrastructure for the likes of schools, hospitals and emergency services?
4.7 Can Brentwood cope with the additional waste, landfill and sewage that will be created?
4.8 What measures are going to be put in place and enforced to ensure a good level of air quality? Surrounding areas are already fairly high!
4.8 Who will foot the bill for all of the above?

5. With the ever increasing worry and risk of flooding, what assurances can the residents of Brentwood and the new residents of the Dunton Hills Garden Village that they won't be affected by any increases in flooding?
5.1 We have already seen that parts of the A127, Lower Dunton Road and some minor roads are prone to flooding due to either surface water or road drainage systems backing up. Will these be addressed especially since the new development will be partly built on flood plains?

6. West Basildon's and South West Brentwood's greenbelt land is land that we must save and preserve. Not just for our wildlife, health and wellbeing but with the proposed Lower Thames Crossing; the London sprawl and housing development will bring the end of Essex as a community and Brentwood and Basildon as towns.

Detail:
As mentioned at the start of my letter I am writing to formally register my objection to the 'Brentwood Draft Local Plan', due to the negative impact I believe it will have on the surrounding greenbelt areas, wildlife and communities. In fact this development will have far greater reaching impacts for anyone living, traveling or passing through South Essex. We should be proud of the green belt areas that surround our area and look to protect them for many years and generations to come. These areas should be the last place considered for building new properties especially when there are so many brown field sites yet to be improved and are suitable for housing development. It's madness that there is more red tape for developing brown field sites than on green belt land!
Simply declassifying green belt land (because it is easier than utilising brown field sites) without specialist investigation in to the species that use this as their habitat and home is unacceptable. There have been many sightings and recordings of wildlife in the area which include the following some of which are protected species and can be found in and around the Dunton Essex Wildlife Trust nature reserve. (Not an exhaustive list by any means):
- The following species are all found in the area and they are also in the UK Biodiversity Action Plan:- Water voles (legally protected and endangered) , Grizzled Skipper butterfly (legally protected and endangered) , Great Crested Newts (protected) , Slow Worm, Grass Snake, Cuckoo, Song Thrush, House Sparrow, Tree Sparrow, Turtle Dove, Wood Warbler. The following are also found in the area and will disappear should the proposal get passed:- Bats (protected), Badgers (protected), Adders (protected) , Kingfishers, Bullfinches, Buzzards, Sparrow Hawks, Owls, (Tawny, Barn and Short Eared Owl), Foxes, Rabbit, Deer. Although Dormice (legally protected and endangered) have not yet been found in the area because surveys have not been conducted, they have been found in neighbouring village of Stock within Billericay, not 10 minutes from the proposed site so there is an extremely high possibility that they are also in the area. Dormice are also a protected and endangered species.
- There are also many trees, plants and vegetation that would be lost that provide as homes and food for all of the above
- Roadside verges seem to be shrinking and are even being cleared which was once enforced by Basildon Council to help preserve and encourage wildlife to flourish. This can clearly be seen on the verges and central reservation of the A127 between Basildon and Dunton Junctions.

We are fortunate to have the Dunton Essex Wildlife Trust nature reserve where we can escape from the hustle and bustle of normal daily commuter life. There are very few places in Basildon where you can get to see beautiful countryside that hasn't been developed or see fields that haven't been concreated over. The views across to London from the top of Dunton reserve are amazing and will be lost forever should this development go ahead. These views have recently seen a Solar farm built directly opposite this reserve and now we are hearing of a proposed wind farm. More worryingly is that these views that we enjoy are a home, a habitat that links together to keep the great British wildlife flourishing. Nature doesn't understand boundaries and needs natural pathways, links and open spaces from one site to another to enable species (animals, insects and vegetation) to exist.

With the development of Dry Street now going ahead we will be putting a massive obstacle between two reserves (Langdon Hills Country Park & Dunton Essex Wildlife Trust nature reserve) which will unquestionably have a massive effect on these species. Now we are planning on doing the same between Dunton Essex Wildlife Trust nature reserve and Thorndon Country Park!

With an existing infrastructure that is already showing signs of excessive strain how is Basildon supposed to cope?
Basildon Hospital is already under pressure and it took over 4 hours for me to be seen in A&E when I had stiches in my leg due to a recent accident. Local Doctor Surgeries are also stretched and it can take me weeks to get an appointment with my doctor and inevitably I get to see a locum and not my allocated doctor. How will the local health services be improved to accommodate such a huge influx of people? What provisions for both land and infrastructure has been considered for Basildon hospital especially with the development of Dry Street?
The main transport routes of the A12, A127 and A13 are already stressed to breaking point . The sheer volume of traffic can bring both roads to a standstill and is a frequent occurrence during rush hour times, and that is before adding in the effects of any incidents or accidents. Even travelling down the A127 during the day is restricted rendering the speed cameras pretty much ineffective these days. When these main routes are blocked traffic spills into neighbouring side roads creating yet more traffic and pollution for our area. What plans have been taken to make the necessary improvements to these roads alleviating the already high volume of traffic and to cater for the obvious traffic that new properties will create? And that is not only new properties in the Brentwood area but also development sites stretching from Southend to London along the A127 and Colchester to London along the A12 as anyone who uses these two main routes will be affected.

The local Primary Schools in Langdon Hills are regularly oversubscribed meaning children have to pass their local school to go to another. Some families are even divided forcing siblings to attend different schools due to being oversubscribed. With the proposal of "affordable housing" you must expect many families with children to move in so why isn't there more schools being planned within the proposal. Where will the new Brentwood residents be expected to take their children to school?

** Wouldn't you agree that we have the right to protect our green belt land. Exhaust our brownfield sites and say enough is enough, we are full? Surely more properties for Brentwood brings us very close to its limits of being full! **

The local services can't handle the existing numbers of residents , so to propose to add many thousands more, without providing any level of detail within the proposal as to how they would be catered for is not the way a council with a responsible planning policy should behave. There needs to be more detail and information on infrastructure and services that will be planned. Tell us how much extra capacity you plan for the local transport links. As it stands there can only be negative impacts on our local infrastructure, natural beauty spots and way of life if this proposal were to proceed. Local services such as schools and healthcare will suffer, the extra congestion will make travel miserable, employment opportunities may be spread even more thinly, and the environmental effects of the construction and extra population could be disastrous. Is Brentwood & Basildon to become the new London? A place where you can't enjoy the country, a place where you can't drive your car and a place that is stupidly overcrowded!
Please register my vehement objection to this proposal , and ensure that this is taken into account.
Yours Sincerely
Marc Godfree

Dear Sir / Madam
I am writing to formally register my objection to the 'Brentwood Draft Local Plan' proposal, due to the negative impact I believe it will have on the surrounding communities. I, as I am sure many residents, have lots of questions with regards to this consultation. I have summarised my concerns and questions here with further explanations and questions explained in detail below.
Summary of questions:

1. Why is greenbelt land now being considered for declassification in and around the Brentwood / Basildon area?
1.1 The proposed land can often be seen throughout the year growing many varieties Vegetables, food and hay for livestock. Is this land no longer needed for agriculture?

2. What, if any, consideration has been given to the wildlife that will be impacted with such a large scale development on greenbelt land?
2.1 Has the Wildlife Trust, RSPB, Butterfly and Rare species groups been properly consulted on the wildlife in the proposed area?
2.1a Will their views, comments and professional advice be properly listened to and addressed?
2.2 What thoughts and considerations have been made to ensure that our wildlife continues to thrive?
2.3 Simply including a green space 'here and there' isn't sufficient as unlike humans wildlife knows no boundaries and by segregating them to a specific area will just encourage inbreeding, predation and further decline as they have nowhere else to go.
2.4 Will there be any considerations to wildlife corridors between open spaces allowing species to breed, migrate and exist safely and naturally?

3. Have all brownfield sites been considered and exhausted before planning on building on greenbelt land?
3.1 Why is it that greenbelt land appears to be more appealing than brownfield sites for developments?


4. Approx 2500 for Dunton Hills Garden Village! Does this truly reflect Brentwood towns growth expectations for the indigenous Brentwood people over the next few years?
4.1 Will these new homes be designated solely for the people of Brentwood? If not why not and please explain how this will be divided up.
4.2 Will the infrastructure as it stands cope with an increase in the new population
4.3 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village area?
4.4 What plans are being proposed to cope with a minimum of 5,000 new people to the Dunton Hills Village
4.5 Schools, Hospitals, Emergency services are all under strain as it is. Are there plans to rectify this before the proposal of new buildings goes ahead?
4.6 Will there be any revisions to the proposal to consider allocations, both land and infrastructure for the likes of schools, hospitals and emergency services?
4.7 Can Brentwood cope with the additional waste, landfill and sewage that will be created?
4.8 What measures are going to be put in place and enforced to ensure a good level of air quality? Surrounding areas are already fairly high!
4.8 Who will foot the bill for all of the above?

5. With the ever increasing worry and risk of flooding, what assurances can the residents of Brentwood and the new residents of the Dunton Hills Garden Village that they won't be affected by any increases in flooding?
5.1 We have already seen that parts of the A127, Lower Dunton Road and some minor roads are prone to flooding due to either surface water or road drainage systems backing up. Will these be addressed especially since the new development will be partly built on flood plains?

6. West Basildon's and South West Brentwood's greenbelt land is land that we must save and preserve. Not just for our wildlife, health and wellbeing but with the proposed Lower Thames Crossing; the London sprawl and housing development will bring the end of Essex as a community and Brentwood and Basildon as towns.

Detail:
As mentioned at the start of my letter I am writing to formally register my objection to the 'Brentwood Draft Local Plan', due to the negative impact I believe it will have on the surrounding greenbelt areas, wildlife and communities. In fact this development will have far greater reaching impacts for anyone living, traveling or passing through South Essex. We should be proud of the green belt areas that surround our area and look to protect them for many years and generations to come. These areas should be the last place considered for building new properties especially when there are so many brown field sites yet to be improved and are suitable for housing development. It's madness that there is more red tape for developing brown field sites than on green belt land!
Simply declassifying green belt land (because it is easier than utilising brown field sites) without specialist investigation in to the species that use this as their habitat and home is unacceptable. There have been many sightings and recordings of wildlife in the area which include the following some of which are protected species and can be found in and around the Dunton Essex Wildlife Trust nature reserve. (Not an exhaustive list by any means):
- The following species are all found in the area and they are also in the UK Biodiversity Action Plan:- Water voles (legally protected and endangered) , Grizzled Skipper butterfly (legally protected and endangered) , Great Crested Newts (protected) , Slow Worm, Grass Snake, Cuckoo, Song Thrush, House Sparrow, Tree Sparrow, Turtle Dove, Wood Warbler. The following are also found in the area and will disappear should the proposal get passed:- Bats (protected), Badgers (protected), Adders (protected) , Kingfishers, Bullfinches, Buzzards, Sparrow Hawks, Owls, (Tawny, Barn and Short Eared Owl), Foxes, Rabbit, Deer. Although Dormice (legally protected and endangered) have not yet been found in the area because surveys have not been conducted, they have been found in neighbouring village of Stock within Billericay, not 10 minutes from the proposed site so there is an extremely high possibility that they are also in the area. Dormice are also a protected and endangered species.
- There are also many trees, plants and vegetation that would be lost that provide as homes and food for all of the above
- Roadside verges seem to be shrinking and are even being cleared which was once enforced by Basildon Council to help preserve and encourage wildlife to flourish. This can clearly be seen on the verges and central reservation of the A127 between Basildon and Dunton Junctions.

We are fortunate to have the Dunton Essex Wildlife Trust nature reserve where we can escape from the hustle and bustle of normal daily commuter life. There are very few places in Basildon where you can get to see beautiful countryside that hasn't been developed or see fields that haven't been concreated over. The views across to London from the top of Dunton reserve are amazing and will be lost forever should this development go ahead. These views have recently seen a Solar farm built directly opposite this reserve and now we are hearing of a proposed wind farm. More worryingly is that these views that we enjoy are a home, a habitat that links together to keep the great British wildlife flourishing. Nature doesn't understand boundaries and needs natural pathways, links and open spaces from one site to another to enable species (animals, insects and vegetation) to exist.

With the development of Dry Street now going ahead we will be putting a massive obstacle between two reserves (Langdon Hills Country Park & Dunton Essex Wildlife Trust nature reserve) which will unquestionably have a massive effect on these species. Now we are planning on doing the same between Dunton Essex Wildlife Trust nature reserve and Thorndon Country Park!

With an existing infrastructure that is already showing signs of excessive strain how is Basildon supposed to cope?
Basildon Hospital is already under pressure and it took over 4 hours for me to be seen in A&E when I had stiches in my leg due to a recent accident. Local Doctor Surgeries are also stretched and it can take me weeks to get an appointment with my doctor and inevitably I get to see a locum and not my allocated doctor. How will the local health services be improved to accommodate such a huge influx of people? What provisions for both land and infrastructure has been considered for Basildon hospital especially with the development of Dry Street?
The main transport routes of the A12, A127 and A13 are already stressed to breaking point . The sheer volume of traffic can bring both roads to a standstill and is a frequent occurrence during rush hour times, and that is before adding in the effects of any incidents or accidents. Even travelling down the A127 during the day is restricted rendering the speed cameras pretty much ineffective these days. When these main routes are blocked traffic spills into neighbouring side roads creating yet more traffic and pollution for our area. What plans have been taken to make the necessary improvements to these roads alleviating the already high volume of traffic and to cater for the obvious traffic that new properties will create? And that is not only new properties in the Brentwood area but also development sites stretching from Southend to London along the A127 and Colchester to London along the A12 as anyone who uses these two main routes will be affected.

The local Primary Schools in Langdon Hills are regularly oversubscribed meaning children have to pass their local school to go to another. Some families are even divided forcing siblings to attend different schools due to being oversubscribed. With the proposal of "affordable housing" you must expect many families with children to move in so why isn't there more schools being planned within the proposal. Where will the new Brentwood residents be expected to take their children to school?

** Wouldn't you agree that we have the right to protect our green belt land. Exhaust our brownfield sites and say enough is enough, we are full? Surely more properties for Brentwood brings us very close to its limits of being full! **

The local services can't handle the existing numbers of residents , so to propose to add many thousands more, without providing any level of detail within the proposal as to how they would be catered for is not the way a council with a responsible planning policy should behave. There needs to be more detail and information on infrastructure and services that will be planned. Tell us how much extra capacity you plan for the local transport links. As it stands there can only be negative impacts on our local infrastructure, natural beauty spots and way of life if this proposal were to proceed. Local services such as schools and healthcare will suffer, the extra congestion will make travel miserable, employment opportunities may be spread even more thinly, and the environmental effects of the construction and extra population could be disastrous. Is Brentwood & Basildon to become the new London? A place where you can't enjoy the country, a place where you can't drive your car and a place that is stupidly overcrowded!
Please register my vehement objection to this proposal , and ensure that this is taken into account.
Yours Sincerely
Marc Godfree

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

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

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1.
I strongly object to the current Spatial Strategy in the draft Local Plan. It fails to take into account the needs of existing villages in the north of the Borough.

The draft Local Plan disproportionally favours the centre and south of the Borough, along existing transport corridors that are already congested, while failing to take into account the needs of existing villages in the north of the Borough, like Blackmore. The Strategic Growth Options consultation document (2015) recognizes that villages must grow to provide for local need, the current draft Spatial Strategy fails to take this into account. Where is the evidence to support this U-turn in planning policy?

2.
Has the Council provided a Settlement Hierarchy paper to assess the needs at local villages?

For example what is the justification in allowing development at Mountessing, rather than larger villages further north in the Borough, like Blackmore? If the Council is basing the plan on transport corridors alone, it has failed to objectively assess the needs across the entire Borough.

3.
SO's 1 &2 (pg 25) prejudice development growth to existing or proposed infrastructure to the centre and south of the Borough. The Council has a duty of care to ensure the entire Borough's needs are met to 2033 and the draft plan only meets the needs of part of the Borough.

4.
S03 is not being met in the north of the Borough in the respect of creating "inclusive, balanced, sustainable communities" (p25) to the year 2033. An objectively assessed local plan would recognize the need to ensure that existing villages, like Blackmore, need some development to retain their working population which will ensure that services such as local shops, leisure amenities, primary schools, GP practices and public transport services are sustained.

5.
The proposed plan fails to spread economic prosperity across the Borough and in particular in the north of the Borough. SO4, S05, S06, S07 promoting Economic Prosperity in the Borough (pg 25) focus on Brentwood and new development in the south of the Borough. There is no evidence that this plan seeks to implement SO8 (Promote and support a prosperous rural economy) in the north of the Borough because no GB development is planned, despite there being no brownfield opportunities.

6.
How do you define "inappropriate" (S09 Safeguard the Green Belt from inappropriate development and enhance its beneficial use, pg 26)? A 10% increase in existing villages for the next 20 years (is "inappropriate") but the creation of a new garden village of 2,500 houses (is "appropriate")?

7. How do you define "character"?

Para. 5.21 of the draft plan indicate's that development in the rural north and rural south will be limited to retain local "character". Throughout the plan there are references to safeguarding the GB land and then the need to release some GB land for development as 96% of the Borough falls in GB allocation. Surely the loss of village services as a result of inadequate housing and subsequent decline in the working age community will result in a detrimental "character"?

8. Assessment of GB Site

An assessment of 60 GB sites was produced after this plan was written. And yet the draft plan proposes to create a new garden village at Dunton Hills on GB land that is rated "medium value", for 2,500 new homes (35%) of housing needs in the Borough to 2033, compared to SHLAA site G070A, Land South of Redrose Lane, Blackmore, being promoted by Crest Nicholson for circa 40 houses within the village with clearly defensible boundaries is also rated "medium" but not part of the proposed allocation plan. A Local Housing Requirements Study for Blackmore by Barton Wilmore in August 2013 projected household growth in the village required circa 80 dwellings in the next 20 years.

9. Villages in the north of the Borough will atrophy over the period of the plan.

As the plan covers the to period 2033, Blackmore and some of the other larger villages in the north of the Borough will atrophy in this timespan. How when both sites are rated GB "medium value" can it be justified to "create" rather than "sustain" a village?

Furthermore as the Council has noted "new housing growth will deliver a boost to the local economy" para. 5.39 Why then is there no consideration of the larger villages, like Blackmore in the north of the Borough?

10.
I strongly object to the creation of a new garden village at Dunton Hills.
The proposed new village is not equitable, deliverable or sustainable, requires the release of a significant area of GB land, adds more pressure to the already congested A127, is disproportionate in terms of total housing capacity for the Borough from one single source and will not be deliverable within a reasonable timeframe. I strongly disagree that para 5.41 "A proportionate approach has been taken...". It is clear contrary to para 5.42 the Council has NOT "applied densities to potential development sites in a realistic manner...".

11. Brownfield Redevelopment Opportunities in the rural north and rural south of the Borough

These "Brownfield redevelopment opportunities" (para 5.33) do not exist in the GB villages to the north of the Borough. The case has been made in this draft plan that larger villages in the rural north of the Borough have limited services/amenities and therefore development should not take place here. A limited amount of development needs to take place here to ensure the future vitality and viability of villages like Blackmore. This does not mean changing the "character" of the north of the Borough but rather managing growth in a discrete and viable way.

12.
I strongly disagree with the statement para 5.41 "the Council has reluctantly considered appropriate and sustainable locations within Green Belt". (See point 8 above)

With regard to S010 (Protect & enhance valuable landscape & the natural and historic environment), Figure 9.1 Environment and Biodiversity (p126) indicates that the proposed development sites to the south of the Borough are in areas of a high concentration of both local wildlife sites and sites of special scientific interest, compared to those in the north of the Borough which have a much lower concentration of these sites.

What justification can there be to allow the development of 2,500 houses in one area in GB, while not allowing a 10% growth of existing villages in the next 20 years. Para 9.53 "Development will be restricted to those limited types of development which may be allowed in exceptional circumstances within the Green Belt" but barring Brownfield opportunities such development has been excluded in the rural villages of the north of the Borough.

13.
With regard to SO11, S012, S13 re the Quality of Life & Community Infrastructure, rural villages to the north of the Borough have been largely overlooked.

For example S012 Improving public transport, cycle and walking facilities and encourage sustainable transport choices should be implemented throughout the Borough. Villages such as Blackmore need to maintain a demand for a bus service for it to be economically viable for services to run which means the village needs to maintain an active, balanced community. The existing road network needs to be maintained to 2033 to enable rural villages to reach existing and new services/amenities available in the Brentwood area.

The bias of the current plan is again evidenced by the lack of a proposed Green Travel Route linking villages to the north of the Borough to Brentwood and/or train links. Figure 10.1 Proposes a Green Travel Route to support the proposed development in the south, while ignoring linkages and benefits for those villages in the north of the Borough.

Ensuring a viable bus service, maintaining current road networks and implementing a Green Travel Route to the north of Brentwood would be in line with S011 & S012.

S013 benefits the centre and south of the Borough alone if the plan allows for no development to take place in the rural north. It seems that the population of the Borough is intended to be concentrated in a confined geographic area. It must be possible to protect and enjoy the GB in the Borough while at the same time permitting a more equitable dispersal of the population in the area available.

14. Primary school places in the Borough

I note that Brentwood has capacity for secondary school places but limited capacity for primary school places. Building new villages and new schools takes a significant amount of time. Keeping primary schools open in rural villages is key to ensuring an "inclusive, balanced, sustainable" pg 25 S03 community. Primary school capacity currently exists within the village of Blackmore and perhaps within other villages. Do we need to create a new village or focus on maintaining the ones that currently exist?

15. Housing Trajectory

Para 5.46 states that "The Council has strived to be realistic about the likelihood of sites coming forward .... A clear commitment is shown in this Plan to bring forward land as quickly as possible to meet housing needs swiftly in line with national policy and guidance."

May I ask why, when in the Council's SHLAA (2010) and Draft Site Assessment (July 2013) site (ref 70A, site 076 in this plan) is identified as a suitable site for development of new housing being within defensible boundaries of the village and available to be delivered within 1-5 years, the Council's new spatial policy eliminates this site?

Crest Nicholson, second time National Builder of the Year, have a vision statement that identifies the benefits and opportunities to Blackmore for the development of site 076. I believe it can be proven that it falls within national policy and guidance. This site is achievable and could assist with the five year housing suppy. This complies with site selection para 7.29 "The fourth tier allows for limited greenfield sites in the GB which comprise urban extensions within reach of services and infrastructure and with defensible boundaries".

16. Travel by non-car modes

It is not reasonable to have a policy para. 7.62 that requires: "the ability to travel by non-car modes" in a Borough with an extensive rural community. This again demonstrates extreme bias and a lack of consideration for assuring the future viability of the Borough's rural villages in the north. Furthermore if development is to be limited to areas where non-car modes exist, then the local plan will be spatially inequitable... as this draft is.

Thank you for re-considering these points and re-examining the draft plan.