Object

Representation ID: 15491

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

Council's Green Belt Assessment has commented that the proposed development would effectively harm three of the four purposes of the Green Belt - it would result in unrestricted sprawl of an urban area; significantly reduce the gap between West Horndon and Basildon; and encroach on the countryside. It's only positive attribute is that it does not impact on the setting or special character of historic towns.

Object

Representation ID: 15492

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

It is noted that representations were made to the Council during the last consultation which raised serious doubts over the deliverability of a proposed station at Dunton due to the proximity of other stations, Network Rail's technical requirements and viability issues. This does not appear to have been resolved within this version of the Draft Local Plan. Without a station, the site is solely dependent on travel by car, resulting in a highly unsustainable development.

Object

Representation ID: 15493

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

The development at Dunton would not assist in meeting existing settlement specific housing and socio-economic needs in the Borough, especially in the villages throughout Brentwood.

Object

Representation ID: 15494

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

The key characteristics of a garden village are that it forms the expansion of existing small settlements, is within the catchment of a town, located on an existing transport corridor and is partly or mostly self-sufficient in terms of local social infrastructure. The Dunton Hills proposal cannot meet three of the four characteristics identified above.

Object

Representation ID: 15495

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

There is no evidence of the financial viability of the Dunton Hills development. Whilst it is accepted that the proposal will prove to be a vital source of housing, the ability to fund significant new capital infrastructure will be extremely limiting. The Council should be aware that the recent consultation on the Lower Thames Crossing included a proposed Route 4, which passes through the Dunton Hills area. However, this is unlikely to come forward as a result of the A127 and the junction with the roundabout at the M25 being at capacity. Essex County Council has already acknowledged that the A127 is one of the busiest non-trunk roads in the Country, with regular extensive and widespread delay and disruption to traffic and on the local road network.

Object

Representation ID: 15496

Received: 09/05/2016

Respondent: Mr Richard Lunnon

Agent: JTS Partnership LLP

Of principle concern to the delivery of the Dunton Hills Garden Village is the located of the designated Flood Zone 2. Identification of the site fails to comply with Paragraph 100 of the NPPF, which requires that Local Plans are submitted by Strategic Flood Risk Assessment and that Local Plans should apply a sequential, risk-based approach to the location of development. The Strategic Flood Risk Assessment found in the Evidence Base was published in 2011, prior to the identification of the Dunton Hills Garden Village site. The SFRA provides a list of recommendations within Paragraph 7.1 in regard to the inclusion of sites. It states that "should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a specific site level".

Comment

Representation ID: 15511

Received: 10/05/2016

Respondent: Environment Agency

Whilst we have no comments to make on this policy. We have already provided our advice on this strategic site through the Joint Consultation with Basildon Council last year.

Object

Representation ID: 15568

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

Serious questions remain regarding the deliverability of the Dunton Hills Garden Village and the cooperation between Basildon Borough Council and Brentwood Borough Council appears to have ceased following the consultation on the Strategic Growth Options and Dunton Garden Suburb Consultation in early 2015.
The proposal for the Dunton Hills Garden Village is not sustainable and insufficient justification for its allocation has not been provided.

Object

Representation ID: 15569

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

The fact that the area annotated in the Basildon Borough Council Draft Local Plan H10b is not to be allocated until after 2034 is of serious detriment to Brentwood's own allocation and would result in Dunton Hills Garden Village sitting as an isolated development. It is highly unlikely, given the land ownership, infrastructure and other essential requirements and to ensure that this does not come forward as piecemeal development that the allocation could feasibly be delivered within the Plan period. As a result, the figures set out within Policy 5.2 do not meet the Objectively Assessed Needs of the plan period.

Object

Representation ID: 15570

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

Council's Green Belt Assessment has commented that the proposed development would effectively harm three of the four purposes of the Green Belt - it would result in unrestricted sprawl of an urban area; significantly reduce the gap between West Horndon and Basildon; and encroach on the countryside. It's only positive attribute is that it does not impact on the setting or special character of historic towns.

Object

Representation ID: 15572

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

It is noted that representations were made to the Council during the last consultation which raised serious doubts over the deliverability of a proposed station at Dunton due to the proximity of other stations, Network Rail's technical requirements and viability issues. This does not appear to have been resolved within this version of the Draft Local Plan. Without a station, the site is solely dependent on travel by car, resulting in a highly unsustainable development.

Object

Representation ID: 15574

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

The development at Dunton would not assist in meeting existing settlement specific housing and socio-economic needs in the Borough, especially in the villages throughout Brentwood.

Object

Representation ID: 15575

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

The key characteristics of a garden village are that it forms the expansion of existing small settlements, is within the catchment of a town, located on an existing transport corridor and is partly or mostly self-sufficient in terms of local social infrastructure. The Dunton Hills proposal cannot meet three of the four characteristics identified above.

Object

Representation ID: 15576

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

There is no evidence of the financial viability of the Dunton Hills development. Whilst it is accepted that the proposal will prove to be a vital source of housing, the ability to fund significant new capital infrastructure will be extremely limiting. The Council should be aware that the recent consultation on the Lower Thames Crossing included a proposed Route 4, which passes through the Dunton Hills area. However, this is unlikely to come forward as a result of the A127 and the junction with the roundabout at the M25 being at capacity. Essex County Council has already acknowledged that the A127 is one of the busiest non-trunk roads in the Country, with regular extensive and widespread delay and disruption to traffic and on the local road network.

Object

Representation ID: 15578

Received: 10/05/2016

Respondent: Mr Lee O'Connor

Agent: JTS Partnership LLP

Of principle concern to the delivery of the Dunton Hills Garden Village is the located of the designated Flood Zone 2. Identification of the site fails to comply with Paragraph 100 of the NPPF, which requires that Local Plans are submitted by Strategic Flood Risk Assessment and that Local Plans should apply a sequential, risk-based approach to the location of development. The Strategic Flood Risk Assessment found in the Evidence Base was published in 2011, prior to the identification of the Dunton Hills Garden Village site. The SFRA provides a list of recommendations within Paragraph 7.1 in regard to the inclusion of sites. It states that "should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a specific site level".

Comment

Representation ID: 15585

Received: 10/05/2016

Respondent: Castle Point Borough Council

Te Plan does not indicate what transport improvements will be undertaken to accommodate the growth planned within its borough. Further work would be needed to identify what impacts the proposed developments will have on the existing transport networks, and how to mitigate these impacts.
For example the proposed development at Dunton Hills Garden Village involves:
 2,500 new homes;
 at least 5 ha of employment land;
 local shops;
 community facilities;
 schools; and
 healthcare services
The Plan acknowledges that this development would have an impact on the A127 Corridor, but it does not indicate what mitigation measures would be put in place.

Object

Representation ID: 15614

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

Serious questions remain regarding the deliverability of the Dunton Hills Garden Village and the cooperation between Basildon Borough Council and Brentwood Borough Council appears to have ceased following the consultation on the Strategic Growth Options and Dunton Garden Suburb Consultation in early 2015.
The proposal for the Dunton Hills Garden Village is not sustainable and insufficient justification for its allocation has not been provided.

Object

Representation ID: 15615

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

The fact that the area annotated in the Basildon Borough Council Draft Local Plan H10b is not to be allocated until after 2034 is of serious detriment to Brentwood's own allocation and would result in Dunton Hills Garden Village sitting as an isolated development. It is highly unlikely, given the land ownership, infrastructure and other essential requirements and to ensure that this does not come forward as piecemeal development that the allocation could feasibly be delivered within the Plan period. As a result, the figures set out within Policy 5.2 do not meet the Objectively Assessed Needs of the plan period.

Object

Representation ID: 15616

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

Council's Green Belt Assessment has commented that the proposed development would effectively harm three of the four purposes of the Green Belt - it would result in unrestricted sprawl of an urban area; significantly reduce the gap between West Horndon and Basildon; and encroach on the countryside. It's only positive attribute is that it does not impact on the setting or special character of historic towns.

Object

Representation ID: 15617

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

It is noted that representations were made to the Council during the last consultation which raised serious doubts over the deliverability of a proposed station at Dunton due to the proximity of other stations, Network Rail's technical requirements and viability issues. This does not appear to have been resolved within this version of the Draft Local Plan. Without a station, the site is solely dependent on travel by car, resulting in a highly unsustainable development.

Object

Representation ID: 15619

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

The development at Dunton would not assist in meeting existing settlement specific housing and socio-economic needs in the Borough, especially in the villages throughout Brentwood.

Object

Representation ID: 15621

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

The key characteristics of a garden village are that it forms the expansion of existing small settlements, is within the catchment of a town, located on an existing transport corridor and is partly or mostly self-sufficient in terms of local social infrastructure. The Dunton Hills proposal cannot meet three of the four characteristics identified above.

Object

Representation ID: 15622

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

There is no evidence of the financial viability of the Dunton Hills development. Whilst it is accepted that the proposal will prove to be a vital source of housing, the ability to fund significant new capital infrastructure will be extremely limiting. The Council should be aware that the recent consultation on the Lower Thames Crossing included a proposed Route 4, which passes through the Dunton Hills area. However, this is unlikely to come forward as a result of the A127 and the junction with the roundabout at the M25 being at capacity. Essex County Council has already acknowledged that the A127 is one of the busiest non-trunk roads in the Country, with regular extensive and widespread delay and disruption to traffic and on the local road network.

Object

Representation ID: 15623

Received: 10/05/2016

Respondent: Tony Hollioake

Agent: JTS Partnership LLP

Of principle concern to the delivery of the Dunton Hills Garden Village is the located of the designated Flood Zone 2. Identification of the site fails to comply with Paragraph 100 of the NPPF, which requires that Local Plans are submitted by Strategic Flood Risk Assessment and that Local Plans should apply a sequential, risk-based approach to the location of development. The Strategic Flood Risk Assessment found in the Evidence Base was published in 2011, prior to the identification of the Dunton Hills Garden Village site. The SFRA provides a list of recommendations within Paragraph 7.1 in regard to the inclusion of sites. It states that "should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a specific site level".

Object

Representation ID: 15629

Received: 10/05/2016

Respondent: Basildon Borough Council

It is of concern to Basildon Borough Council that Brentwood Borough Council are looking to take forward development within the previously outlined Dunton Garden Suburb location. Basildon Borough Council do not believe that Brentwood Borough Council have provided sufficient evidence to show that development in that area would be the best location for new development, and that the scale of development proposed, over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure.

Object

Representation ID: 15630

Received: 10/05/2016

Respondent: Basildon Borough Council

The proposal included within the Brentwood Draft Local Plan departs from the proposal for a Dunton Garden Suburb insofar as it is a proposal for a stand-alone settlement to the south of the A127 and to the east of the A128 within the Brentwood Borough only. However, at this time the precise location and land requirement of this proposal is unknown, as are details such as access arrangements. It is therefore unclear as to whether these proposals will result in a stand-alone settlement or an extension to the Basildon urban area in the long-term. It is also unclear how this proposal will relate in terms of access and connectivity to the Basildon urban area in terms of highway impacts or demand for infrastructure and services within Basildon Borough.

Object

Representation ID: 15631

Received: 10/05/2016

Respondent: Basildon Borough Council

The land which would form the Dunton Hills Garden Village does not appear to have been put forward in the most recent call for sites and has not been assessed within the Brentwood Council Strategic Housing Land Availability Assessment (2011). The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use.

Object

Representation ID: 15632

Received: 10/05/2016

Respondent: Basildon Borough Council

As detailed above, a SHLAA has not been carried out since 2011. As it stands there is therefore no robust and credible evidence to demonstrate that the land required to provide the Dunton Hills Garden Village is available or suitable for the purpose to which it is proposed, or whether development in this location is achievable (viable). In the absence of such evidence, the proposals for Dunton Hills Garden Village are not supported by evidence, and it is not clear that they are deliverable. Consequently, Basildon Council is clear that without any further evidence to support this proposal Brentwood's Local Plan is unlikely to be sound on the basis of justification and effectiveness.

Object

Representation ID: 15633

Received: 10/05/2016

Respondent: Basildon Borough Council

Furthermore, evidence which is available for consideration indicates that the proposal for Dunton Hills Garden Village may not be the most suitable option for meeting the housing needs of Brentwood Borough. The working draft of the Assessment of Potential Housing, Employment and Mixed Use Sites in the Green Belt and their Relative Contribution to the Purposes of the Green Belt Designation study shows that the Dunton Hills Garden Village location (referenced as Site 200) is classed as 'high' in terms of meeting the purposes of the Green Belt when reviewed for both housing and employment delivery. This initial evidence indicates that this area is not the most suitable location in terms of Green Belt impacts and should not be taken forward. It is questioned therefore as to whether this evidence of Green Belt impacts has informed the plan-making process in preparing the Draft Local Plan given that it was published part way through the consultation, and therefore Basildon Borough Council would suggest that further consideration be given to its findings prior to the finalisation of the Brentwood Local Plan.

Object

Representation ID: 15634

Received: 10/05/2016

Respondent: Basildon Borough Council

Having regard to the absence of evidence regarding the consideration of this site within a SHLAA, and also the evidence regarding Green Belt impacts set out in the Assessment of Potential Housing, Employment and Mixed Use Sites in the Green Belt and their Relative Contribution to the Purposes of the Green Belt Designation study, Basildon Borough Council cannot support the proposals for Dunton Hills Garden Village as it is not convinced that the proposals are justified, and present a high risk of the Brentwood Local Plan being found unsound.