Object

Representation ID: 15644

Received: 10/05/2016

Respondent: Basildon Borough Council

Basildon Borough Council do not however support the proposed location of new employment within the Dunton Hills Garden Village as set out in the above corresponding section, this area of land was not put forward in the call for sites and the land within the Green Belt is currently rated a 'high' 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 when considering the purposes of land within the Green Belt.

Object

Representation ID: 15645

Received: 10/05/2016

Respondent: Basildon Borough Council

Brentwood Borough Council have set out to locate their employment land close to the strategic highway network. As detailed above a SHLAA does not appear to have been carried out since 2011, therefore the required changes to review economic land as part of the process have not been recently assessed along with any other form of review of suitable, available and achievable employment land. Consequently there has not been any evidence produced to inform the selection of employment sites for inclusion in the Local Plan. The suitability and availability of such sites is not therefore justified by the evidence currently available. Consequently, further evidence to justify the Dunton Hills Garden Village employment location, amongst others, is required.

Comment

Representation ID: 15650

Received: 10/05/2016

Respondent: Basildon Borough Council

It should also be noted that one of the proposed routes to the Lower Thames Crossing, Route 4, would alter the location of Dunton Hills Garden Village. Further consideration would need to be given to a revised location, especially in terms of impact on infrastructure.

Object

Representation ID: 15663

Received: 10/05/2016

Respondent: Basildon Borough Council

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough Council to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Hills Garden Village is the most appropriate location for growth based on evidence and supporting infrastructure mitigation in order to make an informed decision at a future date as to whether it can support this proposal.

Comment

Representation ID: 15673

Received: 10/05/2016

Respondent: Anglian Water

Anglian Water has made an initial assessment of the impact of the proposed housing, employment retail and leisure allocation sites on existing water and water recycling infrastructure located within Anglian Water's area of responsibility. This will need to be revisited when planning applications are submitted to the District Council and we are approached by developers as part of the planning application process. A copy of the initial assessment made by Anglian Water is included with this consultation response.
In relation to the strategic sites identified in the Local Plan it would be helpful to cross refer to the requirements of Policies 10.13 (Flood Risk) and (Sustainable Drainage) to ensure that these development proposals which are of strategic significance provide sufficient evidence relating to foul drainage and surface water management and the timing of any required improvements.

Comment

Representation ID: 15717

Received: 11/05/2016

Respondent: British Horse Society

Dunton Hills Garden Village - we note that the Council wishes to establish green links from this new development to the rest of Brentwood Borough. We request therefore that these green links are accessible to all - pedestrians, cyclists and equestrians - rather than just pedestrians and cyclists.

Support

Representation ID: 15788

Received: 11/05/2016

Respondent: Persimmon Homes Essex

Support this policy to meet the Borough's housing needs. Although Basildon's Draft Plan concluded that the joint area has not been progressed due to the lack of technical work to support the delivery of development in this location. However Basildon seeks to allocate and safeguard land to the west of Basildon therefore the proposed allocation of Policy 7.1 could result in coalescence. Therefore Brentwood and Basildon should work together to ensure that development in this location has regards to (a) neighbouring allocation, (b) cumulative impacts and mitigation, (c) that the totality of development is deliverable.

Comment

Representation ID: 15789

Received: 11/05/2016

Respondent: Persimmon Homes Essex

This area is identified location for route C, if route C be the preffered location for Lower Thames Crossing it would severely impact the deliverability of the proposed allocation. The Draft Plan has not identified how the Council will overcome this issue should Route 4 be progressed. The Council should identify reserved sites that can be called upon if (a) the allocation does not come forward or (b) the Council cannot demonstrate a 5 year housing land supply.

Comment

Representation ID: 15795

Received: 11/05/2016

Respondent: Essex County Council

ECC considers the growth at West Horndon and Dunton is the absolute minimum required to sustain a secondary school of sufficient size to be viable. A school is unlikely to be delivered until later in the development meaning secondary school age pupils moving into the area would need to be transported to and from existing schools in Brentwood/Shenfield. Consideration will need to be given to cross boundary issues with Basildon proposing development at the Basildon West Urban Extension.

Comment

Representation ID: 15865

Received: 11/05/2016

Respondent: Sammi Developments Ltd

Agent: Phase 2 Planning and Development Ltd

Development at Dunton seeks to provide 35% of housing for the Borough. Although a development of this type will bring forward some facilities and services, these are likely to be limited in nature and scale due to the limited size of the planned population. This site should either be excluded from the Plan or reliance on the delivery of this site within the Plan period should be reduced and other sites should be allocated adjoining the urban areas of Brentwood/ Shenfield.

The Sustainability Appraisal identifies the potential for significant negative effects arising from the draft Plan "given the uncertainty that remains regarding Dunton Hills Garden Village". In the same report, flooding is also identified as a notable issue.

Comment

Representation ID: 15881

Received: 22/03/2016

Respondent: Revera Ltd

Agent for landowners of 39 acres of land between Basildon and West Horndon, support the allocation of land under Policy 7.1.
The inclusion of land in this location would suggest the evidence base supports its development and request reconsideration of the allocation under Policy 7.1 working towards a cross boundary development with Basildon BC.
Large scale development is supported by paragraph 52 of the NPPF.
Clients land is under option with Persimmon Homes demonstrating deliverability in the plan period with no safeguarding beyond 2034.
Should Brentwood BC deliver the land separately our clients land should still be considered for development.

Support

Representation ID: 15893

Received: 12/05/2016

Respondent: Mr Adam Smith

Agent: Collins & Coward Ltd

Fully supportive of policy.
Policy makes a very clear and fundamental contribution to the delivery of housing within the Plan period. This point needs to be considered within the context of paragraph 14 of the NPPF and the requirement to have an up-to-date housing land supply or else applications across a variety of sites may be countenanced with regard to the provisions of the NPPF.

Comment

Representation ID: 15908

Received: 12/05/2016

Respondent: Kitewood

Agent: Kitewood

There appears to be a lack of cross-boundary co-operation between Brentwood and Basildon Borough Council on this matter. The Basildon Consultation 2016 (Policy H10) confirms that insufficient evidence has been prepared to demonstrate that the Dunston Garden Village is appropriate or deliverable in the plan period.

Object

Representation ID: 15912

Received: 12/05/2016

Respondent: West Horndon Parish Council

WHPC comment up front that whilst the Draft Local Plan document sets out historic consultation processes, it fails to provide a full background as to consultation response on a number of points. In particular, and as noted in 2.12 of this document, 84% of respondents to the Dunton Garden Suburb consultation in January 2015 rejected the proposal for significant development at Dunton, with only 3% supporting conditionally, and 3% supporting unconditionally. Whilst Dunton Hills Garden Village looks only at the Brentwood side of the originally proposed Dunton Garden Suburb, there was clear rejection of material development both 1) at this site and 2) within West Horndon village as stated throughout the Draft Local Plan, in response to the 2013 consultation round. As such, consultations to date clearly reject material development at either potential location within the A127 Corridor. Yet the current Draft Local Plan is supporting this approach.

Object

Representation ID: 15913

Received: 12/05/2016

Respondent: West Horndon Parish Council

WHPC note that the proposed development within the Draft Local Plan is highly concentrated within the A127 Corridor. This scale and concentration will irrevocably harm Green Belt within this area (at a disproportionate level than the wider Borough), create problems and risks with regards to deliverability, contribute to urban sprawl rather than prevent it, and create material infrastructure requirements that are simply not considered in sufficient detail within the Draft Local Plan. These issues are either ignored, or glossed ove r, in the Draft Local Plan document. WHPC believe that these issues lead to the potential for the Draft Local Plan to be considered unsound, unsustainable, and lacking in the level of detail that is required for a proposal of this nature. Much of the discussion below picks up on, and expands on the issues around material development within the A127 Corridor.
On this basis, and considering the independent Sustainability Appraisal undertaken by WHPC, WHPC represent that a sustainable level of development within the A127 Corridor would be limited to a maximum of 500 houses across sites 020 and 021 (the West Horndon Industrial Estates). As noted in 3.7 above however, even this level of development would require a significant amount of infrastructure expenditure to ensure it is sustainable. On this basis, and considering the independent Sustainability Appraisal undertaken by WHPC, WHPC represent that a sustainable level of development within the A127 Corridor would be limited to a maximum of 500 houses across sites 020 and 021 (the West Horndon Industrial Estates). Even this level of development would require a significant amount of infrastructure expenditure to ensure it is sustainable.

Object

Representation ID: 15924

Received: 12/05/2016

Respondent: West Horndon Parish Council

WHPC note significant concern however that the Green Belt boundaries are not currently defined. The Draft Plan is considered too vague, and given the importance within BBC's proposed Spatial Strategy, greater detail of boundaries of any development east of the A128 is required for any final Local Plan.

Object

Representation ID: 15925

Received: 12/05/2016

Respondent: West Horndon Parish Council

The south of the Borough is bounded by neighbouring authorities Thurrock, Havering and Basildon. Whilst WHPC agree that it is bounded by the A127 and railway line, in reality it would be easy for all neighbouring authorities to develop up to their borders, creating massive urban sprawl from London to Basildon. Indeed, the Basildon Dunton Extension plans in their emerging LDP already point to this. As such, WHPC reject the notion stated throughout the Draft Local Plan that current "defensible boundaries" would prevent this.

Comment

Representation ID: 15933

Received: 12/05/2016

Respondent: West Horndon Parish Council

It is unclear what the proposed phasing or delivery timing is for Dunton Hills Garden Village. It is not included in Appendix 3. WHPC state concern regarding any development within this site given its scale, and the knock-on impact to West Horndon should infrastructure not be delivered in an appropriate, timely, and properly phased manner.

Comment

Representation ID: 15963

Received: 13/05/2016

Respondent: Kelvedon Hatch Parish Council

Kelvedon Hatch Parish Council Discussed the above Plan at our Council meeting on the 10th of March 2016. We decided that although there were no identified sites for housing or commercial development within our parish our response would largely remain as it was last year during the then consultation. There were some changes, of course, with regard to the developments to the south of the town in the then Dunton Garden Suburb. We were in agreement that the now proposed development under the sole control of the Brentwood Borough Council would seem a better option than under partnership with adjacent councils. The previous submission is attached for clarification of our position.

Comment

Representation ID: 15970

Received: 13/05/2016

Respondent: St Modwen Properties PLC

Number of people: 2

Agent: Strutt & Parker LLP

Paragraph 7.8 states that "It is recognised that the A127 highway is constrained and further work will need to be undertaken [...]" Rather than currently constrained, it is more accurate to identify that it's forecast to be under increased pressure in future years with the realisation of local plan development; for further examination with Highways England this should probably apply to the M25 Junction 29 as a key gateway for the borough, including direct access to the Brentwood Enterprise Park.

Comment

Representation ID: 15998

Received: 11/05/2016

Respondent: Essex County Council

Consider that, given the proximity of the site to Policy H10 (Basildon Borough New Draft Local Plan), both local authorities should be in discussion concerning the potential synergies between development, potential for shared evidence base, and the consideration of the cumulative impact on primary and secondary education, and early years and childcare provision, key highway junctions and the wider network. Essential that joint working between relevant partners is progressed to ensure that the appropriate economies of scale can be achieved.

Comment

Representation ID: 16000

Received: 11/05/2016

Respondent: Essex County Council

ECC recommends that growth identified in the Basildon Local Plan (Policy H10) would require a minimum of a 2 forms of entry (420-place) primary school. The 2,500 dwellings identified in the Brentwood Local Plan at Dunton Hills Garden Village could require the provision of at least one large (31/2 forms of entry - 735-places), or more probably two smaller ( 1 x 2 forms of entry (420-places) and 1 x 11/2 form of entry (315-places) new primary schools. The precise requirement would be dependent on the housing mix agreed for the development. A further 150 primary school places would be required to accommodate the pupils generated by the 500 homes identified for West Horndon. Some of this additional demand could probably be accommodated by an expansion of West Horndon Primary School but some of the growth may need to be accommodated in the new primary schools on the Dunton Garden Village development.

Comment

Representation ID: 16003

Received: 11/05/2016

Respondent: Essex County Council

ECC provided comments to the joint `Concept Consultation in 2015, and these comments remain pertinent. The proposal is at an early stage, but there is limited evidence and information available to comment on its appropriateness, including Strategic Green Belt Review; Transport modelling and highway impact assessments; Infrastructure requirements (including education/early years and childcare); Environmental issues (ie landscape impacts; surface water management).

Comment

Representation ID: 16005

Received: 11/05/2016

Respondent: Essex County Council

Would seek early consultation regarding any proposal to consider any impacts on designated and non- designated heritage assets, as identified in the Historic Environment Record (HER).

Comment

Representation ID: 16006

Received: 11/05/2016

Respondent: Essex County Council

In progressing any allocation further strategic and project level assessment of ecology and Country Parks will be necessary and should be in accordance with best-practice guidelines. In addition appropriate engagement with the Parks Services will need to be undertaken to inform any design of future assessment/mitigation studies for ecology and green infrastructure. ECC request further investigation into Enhancement Measures and ECC note that the strategic allocation is located between three living landscape areas which presents significant opportunities to establish a strategic framework to ensure the "concept" delivers a positive contribution to the local ecological network and habitat species.

Comment

Representation ID: 16011

Received: 11/05/2016

Respondent: Essex County Council

Will seek early consultation on any proposal to ensure that there are sufficient opportunities to meet the identified needs of an area for the management of waste and to apply and promote the waste management hierarchy within sustainable development. Consideration needs to be given to the provision for waste management uses as an employment activity within any proposed commercial or industrial employment areas. Considerations should also be given to the potential for integrated land uses and low carbon heating / power systems.

Support

Representation ID: 16013

Received: 13/05/2016

Respondent: Persimmon Homes Essex

Landowners: Mrs Mountford, Mrs Collins and Mr Mountford own circa 15.7ha of land between Basildon and West Horndon. Previous consultation by Brentwood on the Dunton Garden Suburb has not been progressed according to Basildon's drfat local plan "due to the lack of technical work undertaken to support the delivery of development in this location" despite both Council's allocating land identified within the document as an allocation in their draft local plans. The inclusion of this land would suggest that the evidence base supports its development and therefore we request that the council reconsider the allocation under policy 7.1 and work towards a cross boundary development with Basildon Borough Council.

Comment

Representation ID: 16014

Received: 11/05/2016

Respondent: Essex County Council

Consistency should be provided with regards the definition of the proposed allocation at Dunton, which is phrased as:
- Policy 7.1 Dunton Hills Garden Village
- Paragraph 7.5 - `will provide a new settlement'
- Hierarchy of Place, paragraph 5.30 - `a new self sustaining village' within Settlement Category 2: Village Service Centre.

Comment

Representation ID: 16015

Received: 11/05/2016

Respondent: Essex County Council

Advise if the allocation is being proposed as a `Garden Village' consideration should be given to applying the Garden City principles as outlined in the NPPF and the 2013 Town and Country Planning Association's publication "Creating garden cities and suburbs today".

Support

Representation ID: 16016

Received: 13/05/2016

Respondent: Persimmon Homes Essex

Large scale development is supported by National Policy. Paragraph 52 of the National Planning Policy Framework states that "the supply of new homes can sometimes be best achieved through planning for large scale development, such as new settlements or extensions to existing villages and towns". It is felt that this approach is relevant to Policy 7.1 as the council have an opportunity to deliver a large scale development which has the ability to deliver new employment land, social infrastructure and open space too.