Policy 7.10: Gypsy and Traveller Provision

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Object

Draft Local Plan

Representation ID: 13118

Received: 15/02/2016

Respondent: Mr Chris Hossack

Representation Summary:

Any traveller provision should be in such a location that traveller convoys do not has to access/egress their sites by driving through town roads or small lanes in the GB. ie. when they want to travel they should have quick and easy access to trunk roads. The ideal location for this will be alongside the enterprise park located at the A127 junction with the M25. This would be equally convenient if a council depot facility is the be located nearby to facilitate the servicing and maintenance of such a site.
Traveller sites should not be located near existing settled/permanent/established residential communities or near park land.

Full text:

Any traveller provision should be in such a location that traveller convoys do not has to access/egress their sites by driving through town roads or small lanes in the GB. ie. when they want to travel they should have quick and easy access to trunk roads. The ideal location for this will be alongside the enterprise park located at the A127 junction with the M25. This would be equally convenient if a council depot facility is the be located nearby to facilitate the servicing and maintenance of such a site.
Traveller sites should not be located near existing settled/permanent/established residential communities or near park land

Comment

Draft Local Plan

Representation ID: 13138

Received: 21/02/2016

Respondent: Mrs Alison Heine

Representation Summary:

Support inclusion of policy/ acceptance of high, immediate need
BUT:
Policy is not sound/ will fail to deliver sites to meet large immediate
No idea how sites in Fig 7.5 have been chosen over others.
Allocated sites in Green Belt locations must be inset or removed from the Green Belt as per par 85 NPPF.
Criteria (a) is not fair or realistic-will merely thwart provision as before.
Pressing need for more transit sites is not addressed.
It is unclear how Council will address any need for non travelling Gypsy-Travellers

Full text:

Support inclusion of policy
Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation (not tested against any other assessments yet accounts for more than half of need identified in Brentwood). If ORS assumptions are wrong this could have significant implications for future site provision.

Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon. ORS fail to accept importance of in migration in past from inner London and dismiss it as source of need in future. There is no consideration of European Roma.

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.

Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks. For instance many GTs do not regard a visit to a horse fair as travelling as to them travelling is what they did before they settled down ie living a roadside existence and many will quite properly say they do not want to go back to that lifestyle. I have had complaints over the way ORS turned up unannounced to update need assessment and sneak in questions about status. One client was pressured into answering just as she was dashing off on school run. This is not acceptable.

Policy should however stress need to front load provision as there is a large immediate need.

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Support the allocation of three sites in fig 7.5-but why only these? This is not enough to meet the immediate need. It is far from clear how they were chosen and not others. It is far from clear if you propose to inset from the Green Belt and if not why not? How will they be made permanent if not inset from the GB? They will still fail criteria (a) and national policy test.

Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.

Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Para 7.82-Given the large number of appeals for sites in this district and fact most have only been established on appeal, I do not know how the Council can possibly claim to have good track record of positively considering appropriate windfall sites. There is no obvious consistency in recent decisions and whilst it is welcomed that some have (finally) been made permanent it is far from clear why others have not. There remain far too many sites with temporary/ unauthorised pitches. It is not clear why plots at Lizvale Farm is not listed in Fig 7.5 or the rest of Orchard view given Hope Farm is supported. I am not clear what has happened to Cottage Gardens Beads Hall Lane or whether the Council has, in the alternative, agreed to a replacement house on this site. But if the owner still wants a caravan site this should be included in Fig 7.5 along with the unauthorised pitches at Blackmore and Hunters Green.

Para 7.83 Policy fails to allocate enough to meet the immediate need and fails to indicate broad locations for further provision.

Policy as drafted fails to do what is required. It is not NPPF/PPTS compliant. It will not address the immediate need for sites with no certainty future need will be met either.

More sites need to be put forward to meet the immediate need especially if there is to be reliance on Green belt sites.

Sites need to be inset from the Green Belt so that they stand any chance of being granted permission

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms .

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Given the revised legal definition of GTs in PPTS Annex 1 far more transit provision must be found and delivered if GTs are to be able to maintain a travelling way of life. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .

Object

Draft Local Plan

Representation ID: 13347

Received: 14/03/2016

Respondent: Dr Philip Gibbs

Representation Summary:

[7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.]

Please read the full representation as all the details are important and it is no longer than necessary.

Full text:

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3) Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.
(7) PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.

Support

Draft Local Plan

Representation ID: 13370

Received: 16/03/2016

Respondent: Brentwood Gypsy Support Group

Representation Summary:

Broad support, comment on details, concern at the flawed methodology of current needs assessment by ORS.

Full text:

Brentwood Gypsy Support Group

Chair:Bernadette Reilly
Roman Triangle, 77 Roman Road, Mountnessing, Essex, CM15 OUD Secretary: Prof. T.A Acton, OBE
22 Northend, Warley, Brentwood,
Essex CM14 5LA

The Brentwood Gypsy Support Group, after its meeting yesterday, broadly supports the Draft Local Plan, with its balanced vision of sustainable housing, employment and services in the coming years in Brentwood, and is pleased to see that planning for Gypsy and Traveller sites remains embedded in this plan as part of the mainstream concern of planning and community development. Although we continue vigorously to support some planning applications which have not yet been incorporated into the plan, for the reasons that we outlined in our previous consultation responses of September 2013, we regard the projected numbers as realistic and sustainable. Our statement of 2013 remains our detailed position on the allocation of sites, and we urge continuing regard to that, and re-iterate our willingness to discuss the details and facilitate discussions with the families concerned. As time marches on, however, we would suggest that the figure for the 5-year supply should be given for the likely date of adoption of the policy, so, perhaps a figure of 67 pitches as a target for 2022.

There is some concern that the criteria for choices of site may be interpreted in too sweeping a way, especially criterion (a), the effect of which will depend entirely on further wrangles over what constitutes "inappropriate development" and how green belt boundaries are redrawn in detail. We urge that the re-drawing of boundaries take account of places where derelict land is classed as Green Belt, so inhibiting development which would actually be a planning gain on any reasonable assessment, such as the site at Roman Triangle. We continue to believe that where possible the regularisation of the development of land purchased by Travellers remains the best, and for the council, the most cost-effective opportunistic provision, especially if re-zoning provides more effective guidance to Travellers on where they might buy land. We look forward to the market for caravan sites becoming more like the market for houses, with more predictable planning outcomes, a diminution of the need to rely on appeals, and the possibility of mortgage finance. We urge also that the allowance for spare capacity on the established sites may allow relatives of existing families to come to Brentwood to meet sudden expansion of the need for their work, and may be a more cost-effective way of meeting the need for transit provision than a council-run transit site.

We are concerned, however, over the current Gypsy and Traveller Accommodation Assessment currently being carried out by Opinion Research Services Ltd. For the reasons given in the letter we have previously copied to you, we regard this survey as flawed, and any attempt to remove Gypsy planning status from our members on its or any other basis will be vigorously resisted. We look forward to a continuation of the existing cordial relationship, and to assisting where we can in negotiations over particular sites. We are also concerned that if the same flawed methodology being used by the ORS is used in neighbouring authorities, particularly London boroughs and Basildon, that will result in serious undercounting of people of nomadic habit of life, who will be pushed by evictions towards Brentwood when in fact their economic ties and preferences lie elsewhere. We therefore urge Brentwood not to rely on county-wide accommodation needs assessments if these are not being carried out rigorously, and to urge other authorities that the kind of thorough and serious assessment that Brentwood has relied upon in the past few years is the only kind that works in the long term.

We also urge the council to remember those Gypsies and Travellers in the Brentwood area who remain of nomadic habit of life, but have less of a psychological aversion to bricks and mortar, and use a house as a base for their travels to work and fairs, often in a smaller touring caravan. These Gypsies and Travellers remain part of the self-employed Traveller economy; their capital may be part of what enables their relatives who do have an aversion to bricks and mortar to develop caravan sites. There are many such in Brentwood. The Brentwood Gypsy Support Group definitely does not believe in "outing" Gypsies and Travellers who conceal their ethnic identity (even when they support public anti-Gypsyism). Still less do we regard Gypsies and Travellers who live or move into houses as "letting down the side". But we do look forward to better community awareness and inclusive anti-racist practice that will enable Brentwood's Gypsy and Traveller citizens to become more confident in expressing and sharing their cultural identity and history in our schools, churches, workplaces and public spaces, so that whether people live in a caravan or a house, or partly in one and partly in the other truly does become a personal cultural and lifestyle choice rather than a fraught, politicised controversy. We do see the mainstreaming of issues of Gypsy Site provision in the draft local plan as a very valuable step towards this vision.

Yours faithfully,
Dr. Thomas Acton, OBE

Object

Draft Local Plan

Representation ID: 13438

Received: 17/03/2016

Respondent: Mrs Jean Laut

Representation Summary:

WE have seen recently that a young person was tragically killed trying to cross the A127

It may be critical to ensure the traveller sites are not close to a main road

Full text:

WE have seen recently that a young person was tragically killed trying to cross the A127

It may be critical to ensure the traveller sites are not close to a main road

Object

Draft Local Plan

Representation ID: 13648

Received: 23/03/2016

Respondent: Mrs Helen Gabell

Representation Summary:

See full representation. Dumping large numbers at Dunton, near the already much higher than Brentwood numbers that Basildon is forced to provide, means that a ghetto situation arises. This will cause tension in all communities in the area. Sites should be found elsewhere within the heart of the Brentwood borough, rather than in the isolated position of Dunton, where there are easily accessible facilities. A traveller child died crossing the A127 recently to get to amenities, and if BBC force them to be south of the A127 they will be risking this happening again.

Full text:

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.

Object

Draft Local Plan

Representation ID: 13837

Received: 23/03/2016

Respondent: Mr Joe Gabell

Representation Summary:

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. 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.
Development at Dunton will not provide the travelling community with adequate medical and educational needs.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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


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

Object

Draft Local Plan

Representation ID: 13849

Received: 23/03/2016

Respondent: Mr Harry Gabell

Representation Summary:

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. 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.
Development at Dunton will not provide the travelling community with adequate medical and educational needs.

Full text:

At the age of 20 I don't want to live in the London Borough of South Essex, which is what will happen if this tiny, valuable for so many reasons, piece of Green Belt is buried under concrete, air and noise pollution, as it is one of the few pieces fulfilling its purpose of preventing urban sprawl.

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

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

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

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

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

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

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

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

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

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

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

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

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


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

Object

Draft Local Plan

Representation ID: 13861

Received: 23/03/2016

Respondent: Mr Paul Gabell

Representation Summary:

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. 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.
Development at Dunton will not provide the travelling community with adequate medical and educational needs.

Full text:

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

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

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

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

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

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

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

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

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

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

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

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

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


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

Object

Draft Local Plan

Representation ID: 13877

Received: 23/03/2016

Respondent: mrs zoe chambers

Representation Summary:

Unjustified to dump Brentwood's traveller pitch responsibility on the border of Basildon.

Full text:

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

1. THE SIZE OF THE PROPOSAL

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

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

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

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

2. SEVERE LACK OF SUPPORTING INFRASTRUCTURE - Partiularly secondary schools


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

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

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

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

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

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

4. ACCESS TO NEW DEVELOPMENT

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

5. ADDITIONAL TRAVELLER AND GIPSY SITE

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

Object

Draft Local Plan

Representation ID: 13971

Received: 07/04/2016

Respondent: Mr Robert Morris

Representation Summary:

Object to policy 7.10 for Gyspy and Traveller provision on the following grounds:
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done.

Full text:

Please indicate which section(s) of the Draft Local Plan you are commenting on (where applicable please clearly state the Policy reference or paragraph number):
Brentwood Gypsy and Travellers policy (policy 7.10)
I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds:
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done.
Para 2.45
Little consideration has been given to providing sufficient new schools, health services or the emergency services. Basildon hospital cannot cope with the current population and I understand that there are no plans to provide additional funding or to expand the current facilities. There is real danger to lives now as the hospital cannot cope. A continued population increase and a growing elderly population will put incredible strain on services. GP appointments are currently standing at 10-14 days.
8.48
The C2C line has seen a progressive increase in passengers over the past few years resulting in the disastrous new timetable being implemented. There is talk of providing more trains in 2019 but there are only two lines in/out of London so there is a limit to the capacity.

(1) Infrastructure
The A127, A13 and adjoining roads cannot cope with the traffic now.
Numerous developments have taken place and are in the process of being built in the local area which is seeing an impact on increased traffic, strain on schools and amenities.
(2) Building on Green Belt
All possible options to utilise brownfield land and should be considered before putting forward proposals to utilise the Green Belt.
(3) Pollution
I have not seen any information on the local pollution from vehicles. Studies should be in place to measure the current levels which I would guess exceed permitted European emission levels. An increase in traffic will further exacerbate the issue.
(4) Flood Risk
Development of Dunton Hills and West Horndon will pose a very high risk of flooding especially through its onward effect on the Mardyke River.
Removal of trees/vegetation will reduce the ability of the area to absorb rainfall. The altitude of the land is mostly around 40m. The A127 presents a barrier to drainage systems because it is lower lying land of approx. 20m. Therefore, most of the surface water will have to be drained towards the South and West via the Mardyke tributary and into the Mardyke itself.
The development of the Dunton Hills area would dramatically increase the risk of flooding. The cost to implement the necessary flood defences would be astronomical.
Gypsy pitches
(5) Wrap-up
Councils should be made to build on brownfield and not Green Belt. Once the land is gone it is gone forever. From the National Planning Policy Framework it states 'The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.' I implore you to honour this policy.

Object

Draft Local Plan

Representation ID: 14027

Received: 14/03/2016

Respondent: Dr Philip Gibbs

Representation Summary:

[7.79 Provision for another 42 pitches is required by 2018. The only provision identified is for 6 pitches and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.]

Please read the full representation as all the details are important and it is no longer than necessary.

Full text:

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3) Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.
(7) PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.

Object

Draft Local Plan

Representation ID: 14030

Received: 14/03/2016

Respondent: Dr Philip Gibbs

Representation Summary:

Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.

Full text:

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3) Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.
(7) PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.

Object

Draft Local Plan

Representation ID: 14031

Received: 14/03/2016

Respondent: Dr Philip Gibbs

Representation Summary:

PPTS section 13 states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable

Full text:

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3) Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.
(7) PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.

Object

Draft Local Plan

Representation ID: 14032

Received: 14/03/2016

Respondent: Dr Philip Gibbs

Representation Summary:

PPTS secion 13 states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.

Full text:

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3) Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.
(7) PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.

Object

Draft Local Plan

Representation ID: 14033

Received: 14/03/2016

Respondent: Dr Philip Gibbs

Representation Summary:

PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.

Full text:

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3) Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.
(7) PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.

Object

Draft Local Plan

Representation ID: 14034

Received: 14/03/2016

Respondent: Dr Philip Gibbs

Representation Summary:

PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.

Full text:

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within "Dunton Hills Garden Village". Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3) Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide - says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation.
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.
(7) PPTS Annex 1 section 1 defines "gypsies and travellers" to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.

Comment

Draft Local Plan

Representation ID: 14045

Received: 16/03/2016

Respondent: Brentwood Gypsy Support Group

Representation Summary:

Would suggest that the figure for the 5-year supply should be given for the likely date of adoption of the policy, so, perhaps a figure of 67 pitches as a target for 2022.

Full text:

Brentwood Gypsy Support Group

Chair:Bernadette Reilly
Roman Triangle, 77 Roman Road, Mountnessing, Essex, CM15 OUD Secretary: Prof. T.A Acton, OBE
22 Northend, Warley, Brentwood,
Essex CM14 5LA

The Brentwood Gypsy Support Group, after its meeting yesterday, broadly supports the Draft Local Plan, with its balanced vision of sustainable housing, employment and services in the coming years in Brentwood, and is pleased to see that planning for Gypsy and Traveller sites remains embedded in this plan as part of the mainstream concern of planning and community development. Although we continue vigorously to support some planning applications which have not yet been incorporated into the plan, for the reasons that we outlined in our previous consultation responses of September 2013, we regard the projected numbers as realistic and sustainable. Our statement of 2013 remains our detailed position on the allocation of sites, and we urge continuing regard to that, and re-iterate our willingness to discuss the details and facilitate discussions with the families concerned. As time marches on, however, we would suggest that the figure for the 5-year supply should be given for the likely date of adoption of the policy, so, perhaps a figure of 67 pitches as a target for 2022.

There is some concern that the criteria for choices of site may be interpreted in too sweeping a way, especially criterion (a), the effect of which will depend entirely on further wrangles over what constitutes "inappropriate development" and how green belt boundaries are redrawn in detail. We urge that the re-drawing of boundaries take account of places where derelict land is classed as Green Belt, so inhibiting development which would actually be a planning gain on any reasonable assessment, such as the site at Roman Triangle. We continue to believe that where possible the regularisation of the development of land purchased by Travellers remains the best, and for the council, the most cost-effective opportunistic provision, especially if re-zoning provides more effective guidance to Travellers on where they might buy land. We look forward to the market for caravan sites becoming more like the market for houses, with more predictable planning outcomes, a diminution of the need to rely on appeals, and the possibility of mortgage finance. We urge also that the allowance for spare capacity on the established sites may allow relatives of existing families to come to Brentwood to meet sudden expansion of the need for their work, and may be a more cost-effective way of meeting the need for transit provision than a council-run transit site.

We are concerned, however, over the current Gypsy and Traveller Accommodation Assessment currently being carried out by Opinion Research Services Ltd. For the reasons given in the letter we have previously copied to you, we regard this survey as flawed, and any attempt to remove Gypsy planning status from our members on its or any other basis will be vigorously resisted. We look forward to a continuation of the existing cordial relationship, and to assisting where we can in negotiations over particular sites. We are also concerned that if the same flawed methodology being used by the ORS is used in neighbouring authorities, particularly London boroughs and Basildon, that will result in serious undercounting of people of nomadic habit of life, who will be pushed by evictions towards Brentwood when in fact their economic ties and preferences lie elsewhere. We therefore urge Brentwood not to rely on county-wide accommodation needs assessments if these are not being carried out rigorously, and to urge other authorities that the kind of thorough and serious assessment that Brentwood has relied upon in the past few years is the only kind that works in the long term.

We also urge the council to remember those Gypsies and Travellers in the Brentwood area who remain of nomadic habit of life, but have less of a psychological aversion to bricks and mortar, and use a house as a base for their travels to work and fairs, often in a smaller touring caravan. These Gypsies and Travellers remain part of the self-employed Traveller economy; their capital may be part of what enables their relatives who do have an aversion to bricks and mortar to develop caravan sites. There are many such in Brentwood. The Brentwood Gypsy Support Group definitely does not believe in "outing" Gypsies and Travellers who conceal their ethnic identity (even when they support public anti-Gypsyism). Still less do we regard Gypsies and Travellers who live or move into houses as "letting down the side". But we do look forward to better community awareness and inclusive anti-racist practice that will enable Brentwood's Gypsy and Traveller citizens to become more confident in expressing and sharing their cultural identity and history in our schools, churches, workplaces and public spaces, so that whether people live in a caravan or a house, or partly in one and partly in the other truly does become a personal cultural and lifestyle choice rather than a fraught, politicised controversy. We do see the mainstreaming of issues of Gypsy Site provision in the draft local plan as a very valuable step towards this vision.

Yours faithfully,
Dr. Thomas Acton, OBE

Comment

Draft Local Plan

Representation ID: 14047

Received: 16/03/2016

Respondent: Brentwood Gypsy Support Group

Representation Summary:

There is some concern that the criteria for choices of site may be interpreted in too sweeping a way, especially criterion (a). We urge that the re-drawing of boundaries take account of places where derelict land is classed as Green Belt, so inhibiting development which would actually be a planning gain on any reasonable assessment, such as the site at Roman Triangle.

Full text:

Brentwood Gypsy Support Group

Chair:Bernadette Reilly
Roman Triangle, 77 Roman Road, Mountnessing, Essex, CM15 OUD Secretary: Prof. T.A Acton, OBE
22 Northend, Warley, Brentwood,
Essex CM14 5LA

The Brentwood Gypsy Support Group, after its meeting yesterday, broadly supports the Draft Local Plan, with its balanced vision of sustainable housing, employment and services in the coming years in Brentwood, and is pleased to see that planning for Gypsy and Traveller sites remains embedded in this plan as part of the mainstream concern of planning and community development. Although we continue vigorously to support some planning applications which have not yet been incorporated into the plan, for the reasons that we outlined in our previous consultation responses of September 2013, we regard the projected numbers as realistic and sustainable. Our statement of 2013 remains our detailed position on the allocation of sites, and we urge continuing regard to that, and re-iterate our willingness to discuss the details and facilitate discussions with the families concerned. As time marches on, however, we would suggest that the figure for the 5-year supply should be given for the likely date of adoption of the policy, so, perhaps a figure of 67 pitches as a target for 2022.

There is some concern that the criteria for choices of site may be interpreted in too sweeping a way, especially criterion (a), the effect of which will depend entirely on further wrangles over what constitutes "inappropriate development" and how green belt boundaries are redrawn in detail. We urge that the re-drawing of boundaries take account of places where derelict land is classed as Green Belt, so inhibiting development which would actually be a planning gain on any reasonable assessment, such as the site at Roman Triangle. We continue to believe that where possible the regularisation of the development of land purchased by Travellers remains the best, and for the council, the most cost-effective opportunistic provision, especially if re-zoning provides more effective guidance to Travellers on where they might buy land. We look forward to the market for caravan sites becoming more like the market for houses, with more predictable planning outcomes, a diminution of the need to rely on appeals, and the possibility of mortgage finance. We urge also that the allowance for spare capacity on the established sites may allow relatives of existing families to come to Brentwood to meet sudden expansion of the need for their work, and may be a more cost-effective way of meeting the need for transit provision than a council-run transit site.

We are concerned, however, over the current Gypsy and Traveller Accommodation Assessment currently being carried out by Opinion Research Services Ltd. For the reasons given in the letter we have previously copied to you, we regard this survey as flawed, and any attempt to remove Gypsy planning status from our members on its or any other basis will be vigorously resisted. We look forward to a continuation of the existing cordial relationship, and to assisting where we can in negotiations over particular sites. We are also concerned that if the same flawed methodology being used by the ORS is used in neighbouring authorities, particularly London boroughs and Basildon, that will result in serious undercounting of people of nomadic habit of life, who will be pushed by evictions towards Brentwood when in fact their economic ties and preferences lie elsewhere. We therefore urge Brentwood not to rely on county-wide accommodation needs assessments if these are not being carried out rigorously, and to urge other authorities that the kind of thorough and serious assessment that Brentwood has relied upon in the past few years is the only kind that works in the long term.

We also urge the council to remember those Gypsies and Travellers in the Brentwood area who remain of nomadic habit of life, but have less of a psychological aversion to bricks and mortar, and use a house as a base for their travels to work and fairs, often in a smaller touring caravan. These Gypsies and Travellers remain part of the self-employed Traveller economy; their capital may be part of what enables their relatives who do have an aversion to bricks and mortar to develop caravan sites. There are many such in Brentwood. The Brentwood Gypsy Support Group definitely does not believe in "outing" Gypsies and Travellers who conceal their ethnic identity (even when they support public anti-Gypsyism). Still less do we regard Gypsies and Travellers who live or move into houses as "letting down the side". But we do look forward to better community awareness and inclusive anti-racist practice that will enable Brentwood's Gypsy and Traveller citizens to become more confident in expressing and sharing their cultural identity and history in our schools, churches, workplaces and public spaces, so that whether people live in a caravan or a house, or partly in one and partly in the other truly does become a personal cultural and lifestyle choice rather than a fraught, politicised controversy. We do see the mainstreaming of issues of Gypsy Site provision in the draft local plan as a very valuable step towards this vision.

Yours faithfully,
Dr. Thomas Acton, OBE

Comment

Draft Local Plan

Representation ID: 14050

Received: 16/03/2016

Respondent: Brentwood Gypsy Support Group

Representation Summary:

We are concerned, however, over the current Gypsy and Traveller Accommodation Assessment currently being carried out by Opinion Research Services Ltd. We regard this survey as flawed, and any attempt to remove Gypsy planning status from our members on its or any other basis will be vigorously resisted. We are also concerned that if the same flawed methodology being used by the ORS is used in neighbouring authorities, particularly London boroughs and Basildon, that will result in serious undercounting of people of nomadic habit of life. Urge Brentwood not to rely on county-wide accommodation needs assessments.

Full text:

Brentwood Gypsy Support Group

Chair:Bernadette Reilly
Roman Triangle, 77 Roman Road, Mountnessing, Essex, CM15 OUD Secretary: Prof. T.A Acton, OBE
22 Northend, Warley, Brentwood,
Essex CM14 5LA

The Brentwood Gypsy Support Group, after its meeting yesterday, broadly supports the Draft Local Plan, with its balanced vision of sustainable housing, employment and services in the coming years in Brentwood, and is pleased to see that planning for Gypsy and Traveller sites remains embedded in this plan as part of the mainstream concern of planning and community development. Although we continue vigorously to support some planning applications which have not yet been incorporated into the plan, for the reasons that we outlined in our previous consultation responses of September 2013, we regard the projected numbers as realistic and sustainable. Our statement of 2013 remains our detailed position on the allocation of sites, and we urge continuing regard to that, and re-iterate our willingness to discuss the details and facilitate discussions with the families concerned. As time marches on, however, we would suggest that the figure for the 5-year supply should be given for the likely date of adoption of the policy, so, perhaps a figure of 67 pitches as a target for 2022.

There is some concern that the criteria for choices of site may be interpreted in too sweeping a way, especially criterion (a), the effect of which will depend entirely on further wrangles over what constitutes "inappropriate development" and how green belt boundaries are redrawn in detail. We urge that the re-drawing of boundaries take account of places where derelict land is classed as Green Belt, so inhibiting development which would actually be a planning gain on any reasonable assessment, such as the site at Roman Triangle. We continue to believe that where possible the regularisation of the development of land purchased by Travellers remains the best, and for the council, the most cost-effective opportunistic provision, especially if re-zoning provides more effective guidance to Travellers on where they might buy land. We look forward to the market for caravan sites becoming more like the market for houses, with more predictable planning outcomes, a diminution of the need to rely on appeals, and the possibility of mortgage finance. We urge also that the allowance for spare capacity on the established sites may allow relatives of existing families to come to Brentwood to meet sudden expansion of the need for their work, and may be a more cost-effective way of meeting the need for transit provision than a council-run transit site.

We are concerned, however, over the current Gypsy and Traveller Accommodation Assessment currently being carried out by Opinion Research Services Ltd. For the reasons given in the letter we have previously copied to you, we regard this survey as flawed, and any attempt to remove Gypsy planning status from our members on its or any other basis will be vigorously resisted. We look forward to a continuation of the existing cordial relationship, and to assisting where we can in negotiations over particular sites. We are also concerned that if the same flawed methodology being used by the ORS is used in neighbouring authorities, particularly London boroughs and Basildon, that will result in serious undercounting of people of nomadic habit of life, who will be pushed by evictions towards Brentwood when in fact their economic ties and preferences lie elsewhere. We therefore urge Brentwood not to rely on county-wide accommodation needs assessments if these are not being carried out rigorously, and to urge other authorities that the kind of thorough and serious assessment that Brentwood has relied upon in the past few years is the only kind that works in the long term.

We also urge the council to remember those Gypsies and Travellers in the Brentwood area who remain of nomadic habit of life, but have less of a psychological aversion to bricks and mortar, and use a house as a base for their travels to work and fairs, often in a smaller touring caravan. These Gypsies and Travellers remain part of the self-employed Traveller economy; their capital may be part of what enables their relatives who do have an aversion to bricks and mortar to develop caravan sites. There are many such in Brentwood. The Brentwood Gypsy Support Group definitely does not believe in "outing" Gypsies and Travellers who conceal their ethnic identity (even when they support public anti-Gypsyism). Still less do we regard Gypsies and Travellers who live or move into houses as "letting down the side". But we do look forward to better community awareness and inclusive anti-racist practice that will enable Brentwood's Gypsy and Traveller citizens to become more confident in expressing and sharing their cultural identity and history in our schools, churches, workplaces and public spaces, so that whether people live in a caravan or a house, or partly in one and partly in the other truly does become a personal cultural and lifestyle choice rather than a fraught, politicised controversy. We do see the mainstreaming of issues of Gypsy Site provision in the draft local plan as a very valuable step towards this vision.

Yours faithfully,
Dr. Thomas Acton, OBE

Comment

Draft Local Plan

Representation ID: 14112

Received: 21/02/2016

Respondent: Mrs Alison Heine

Representation Summary:

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms.

Full text:

Support inclusion of policy
Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation (not tested against any other assessments yet accounts for more than half of need identified in Brentwood). If ORS assumptions are wrong this could have significant implications for future site provision.

Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon. ORS fail to accept importance of in migration in past from inner London and dismiss it as source of need in future. There is no consideration of European Roma.

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.

Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks. For instance many GTs do not regard a visit to a horse fair as travelling as to them travelling is what they did before they settled down ie living a roadside existence and many will quite properly say they do not want to go back to that lifestyle. I have had complaints over the way ORS turned up unannounced to update need assessment and sneak in questions about status. One client was pressured into answering just as she was dashing off on school run. This is not acceptable.

Policy should however stress need to front load provision as there is a large immediate need.

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Support the allocation of three sites in fig 7.5-but why only these? This is not enough to meet the immediate need. It is far from clear how they were chosen and not others. It is far from clear if you propose to inset from the Green Belt and if not why not? How will they be made permanent if not inset from the GB? They will still fail criteria (a) and national policy test.

Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.

Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Para 7.82-Given the large number of appeals for sites in this district and fact most have only been established on appeal, I do not know how the Council can possibly claim to have good track record of positively considering appropriate windfall sites. There is no obvious consistency in recent decisions and whilst it is welcomed that some have (finally) been made permanent it is far from clear why others have not. There remain far too many sites with temporary/ unauthorised pitches. It is not clear why plots at Lizvale Farm is not listed in Fig 7.5 or the rest of Orchard view given Hope Farm is supported. I am not clear what has happened to Cottage Gardens Beads Hall Lane or whether the Council has, in the alternative, agreed to a replacement house on this site. But if the owner still wants a caravan site this should be included in Fig 7.5 along with the unauthorised pitches at Blackmore and Hunters Green.

Para 7.83 Policy fails to allocate enough to meet the immediate need and fails to indicate broad locations for further provision.

Policy as drafted fails to do what is required. It is not NPPF/PPTS compliant. It will not address the immediate need for sites with no certainty future need will be met either.

More sites need to be put forward to meet the immediate need especially if there is to be reliance on Green belt sites.

Sites need to be inset from the Green Belt so that they stand any chance of being granted permission

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms .

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Given the revised legal definition of GTs in PPTS Annex 1 far more transit provision must be found and delivered if GTs are to be able to maintain a travelling way of life. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .

Comment

Draft Local Plan

Representation ID: 14113

Received: 21/02/2016

Respondent: Mrs Alison Heine

Representation Summary:

Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation.
Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks.
Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon.

Full text:

Support inclusion of policy
Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation (not tested against any other assessments yet accounts for more than half of need identified in Brentwood). If ORS assumptions are wrong this could have significant implications for future site provision.

Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon. ORS fail to accept importance of in migration in past from inner London and dismiss it as source of need in future. There is no consideration of European Roma.

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.

Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks. For instance many GTs do not regard a visit to a horse fair as travelling as to them travelling is what they did before they settled down ie living a roadside existence and many will quite properly say they do not want to go back to that lifestyle. I have had complaints over the way ORS turned up unannounced to update need assessment and sneak in questions about status. One client was pressured into answering just as she was dashing off on school run. This is not acceptable.

Policy should however stress need to front load provision as there is a large immediate need.

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Support the allocation of three sites in fig 7.5-but why only these? This is not enough to meet the immediate need. It is far from clear how they were chosen and not others. It is far from clear if you propose to inset from the Green Belt and if not why not? How will they be made permanent if not inset from the GB? They will still fail criteria (a) and national policy test.

Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.

Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Para 7.82-Given the large number of appeals for sites in this district and fact most have only been established on appeal, I do not know how the Council can possibly claim to have good track record of positively considering appropriate windfall sites. There is no obvious consistency in recent decisions and whilst it is welcomed that some have (finally) been made permanent it is far from clear why others have not. There remain far too many sites with temporary/ unauthorised pitches. It is not clear why plots at Lizvale Farm is not listed in Fig 7.5 or the rest of Orchard view given Hope Farm is supported. I am not clear what has happened to Cottage Gardens Beads Hall Lane or whether the Council has, in the alternative, agreed to a replacement house on this site. But if the owner still wants a caravan site this should be included in Fig 7.5 along with the unauthorised pitches at Blackmore and Hunters Green.

Para 7.83 Policy fails to allocate enough to meet the immediate need and fails to indicate broad locations for further provision.

Policy as drafted fails to do what is required. It is not NPPF/PPTS compliant. It will not address the immediate need for sites with no certainty future need will be met either.

More sites need to be put forward to meet the immediate need especially if there is to be reliance on Green belt sites.

Sites need to be inset from the Green Belt so that they stand any chance of being granted permission

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms .

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Given the revised legal definition of GTs in PPTS Annex 1 far more transit provision must be found and delivered if GTs are to be able to maintain a travelling way of life. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .

Comment

Draft Local Plan

Representation ID: 14114

Received: 21/02/2016

Respondent: Mrs Alison Heine

Representation Summary:

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.
Policy should however stress need to front load provision as there is a large immediate need.
Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only 17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.
Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Full text:

Support inclusion of policy
Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation (not tested against any other assessments yet accounts for more than half of need identified in Brentwood). If ORS assumptions are wrong this could have significant implications for future site provision.

Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon. ORS fail to accept importance of in migration in past from inner London and dismiss it as source of need in future. There is no consideration of European Roma.

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.

Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks. For instance many GTs do not regard a visit to a horse fair as travelling as to them travelling is what they did before they settled down ie living a roadside existence and many will quite properly say they do not want to go back to that lifestyle. I have had complaints over the way ORS turned up unannounced to update need assessment and sneak in questions about status. One client was pressured into answering just as she was dashing off on school run. This is not acceptable.

Policy should however stress need to front load provision as there is a large immediate need.

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Support the allocation of three sites in fig 7.5-but why only these? This is not enough to meet the immediate need. It is far from clear how they were chosen and not others. It is far from clear if you propose to inset from the Green Belt and if not why not? How will they be made permanent if not inset from the GB? They will still fail criteria (a) and national policy test.

Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.

Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Para 7.82-Given the large number of appeals for sites in this district and fact most have only been established on appeal, I do not know how the Council can possibly claim to have good track record of positively considering appropriate windfall sites. There is no obvious consistency in recent decisions and whilst it is welcomed that some have (finally) been made permanent it is far from clear why others have not. There remain far too many sites with temporary/ unauthorised pitches. It is not clear why plots at Lizvale Farm is not listed in Fig 7.5 or the rest of Orchard view given Hope Farm is supported. I am not clear what has happened to Cottage Gardens Beads Hall Lane or whether the Council has, in the alternative, agreed to a replacement house on this site. But if the owner still wants a caravan site this should be included in Fig 7.5 along with the unauthorised pitches at Blackmore and Hunters Green.

Para 7.83 Policy fails to allocate enough to meet the immediate need and fails to indicate broad locations for further provision.

Policy as drafted fails to do what is required. It is not NPPF/PPTS compliant. It will not address the immediate need for sites with no certainty future need will be met either.

More sites need to be put forward to meet the immediate need especially if there is to be reliance on Green belt sites.

Sites need to be inset from the Green Belt so that they stand any chance of being granted permission

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms .

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Given the revised legal definition of GTs in PPTS Annex 1 far more transit provision must be found and delivered if GTs are to be able to maintain a travelling way of life. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .

Comment

Draft Local Plan

Representation ID: 14123

Received: 21/02/2016

Respondent: Mrs Alison Heine

Representation Summary:

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

Full text:

Support inclusion of policy
Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation (not tested against any other assessments yet accounts for more than half of need identified in Brentwood). If ORS assumptions are wrong this could have significant implications for future site provision.

Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon. ORS fail to accept importance of in migration in past from inner London and dismiss it as source of need in future. There is no consideration of European Roma.

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.

Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks. For instance many GTs do not regard a visit to a horse fair as travelling as to them travelling is what they did before they settled down ie living a roadside existence and many will quite properly say they do not want to go back to that lifestyle. I have had complaints over the way ORS turned up unannounced to update need assessment and sneak in questions about status. One client was pressured into answering just as she was dashing off on school run. This is not acceptable.

Policy should however stress need to front load provision as there is a large immediate need.

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Support the allocation of three sites in fig 7.5-but why only these? This is not enough to meet the immediate need. It is far from clear how they were chosen and not others. It is far from clear if you propose to inset from the Green Belt and if not why not? How will they be made permanent if not inset from the GB? They will still fail criteria (a) and national policy test.

Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.

Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Para 7.82-Given the large number of appeals for sites in this district and fact most have only been established on appeal, I do not know how the Council can possibly claim to have good track record of positively considering appropriate windfall sites. There is no obvious consistency in recent decisions and whilst it is welcomed that some have (finally) been made permanent it is far from clear why others have not. There remain far too many sites with temporary/ unauthorised pitches. It is not clear why plots at Lizvale Farm is not listed in Fig 7.5 or the rest of Orchard view given Hope Farm is supported. I am not clear what has happened to Cottage Gardens Beads Hall Lane or whether the Council has, in the alternative, agreed to a replacement house on this site. But if the owner still wants a caravan site this should be included in Fig 7.5 along with the unauthorised pitches at Blackmore and Hunters Green.

Para 7.83 Policy fails to allocate enough to meet the immediate need and fails to indicate broad locations for further provision.

Policy as drafted fails to do what is required. It is not NPPF/PPTS compliant. It will not address the immediate need for sites with no certainty future need will be met either.

More sites need to be put forward to meet the immediate need especially if there is to be reliance on Green belt sites.

Sites need to be inset from the Green Belt so that they stand any chance of being granted permission

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms .

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Given the revised legal definition of GTs in PPTS Annex 1 far more transit provision must be found and delivered if GTs are to be able to maintain a travelling way of life. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .

Comment

Draft Local Plan

Representation ID: 14124

Received: 21/02/2016

Respondent: Mrs Alison Heine

Representation Summary:

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .

Full text:

Support inclusion of policy
Policy should safeguard all existing sites esp whilst there is a need for more sites.
Support the fact need is expressed as a minimum fig as there are issues/ concerns with the ORS 2014 assessment, in particular the use of a low 2% for household formation (not tested against any other assessments yet accounts for more than half of need identified in Brentwood). If ORS assumptions are wrong this could have significant implications for future site provision.

Policy should be committed to careful monitoring of ORS assumptions in particular ability of London authorities to deliver enough sites and how soon. ORS fail to accept importance of in migration in past from inner London and dismiss it as source of need in future. There is no consideration of European Roma.

It is unclear why policy refers to a 5 year supply for 2013-2018. By the time policy is adopted the 5 year supply is more likely to be 2017-2022 is 59 plus 8 ie 67 pitches.

Until and unless the Gov provides an explanation as to what the new definition in PPTS means then no revisions should be made to any need assessment. The 2016 update survey by ORS should not be relied on unless and until it is explained to those interviewed what is meant by travelling and a nomadic way of life and what policy now seeks. For instance many GTs do not regard a visit to a horse fair as travelling as to them travelling is what they did before they settled down ie living a roadside existence and many will quite properly say they do not want to go back to that lifestyle. I have had complaints over the way ORS turned up unannounced to update need assessment and sneak in questions about status. One client was pressured into answering just as she was dashing off on school run. This is not acceptable.

Policy should however stress need to front load provision as there is a large immediate need.

Criteria (a) is wholly unacceptable and unrealistic and will continue to be relied on to thwart provision. Inappropriate development will by definition give rise to unacceptable harm when judged against PPTS/NPPF as made clear in para 7.81. This policy seems set to fail from the outset.

criteria (b) is also unreasonable as few sites are well related to services until/ unless land is found in and close to settlements.

criteria (e) will be used to object to most new sites as in the past.

Support the allocation of three sites in fig 7.5-but why only these? This is not enough to meet the immediate need. It is far from clear how they were chosen and not others. It is far from clear if you propose to inset from the Green Belt and if not why not? How will they be made permanent if not inset from the GB? They will still fail criteria (a) and national policy test.

Dunton Hills can not be relied on to meet immediate need for 59 pitches to 2018 of which only17 have been granted. It is not clear how quickly Dunton Hills can be delivered and how.

Policy must identify suitable sites for the immediate need and a 5 year supply ie 2016-2021 minimum.

Para 7.82-Given the large number of appeals for sites in this district and fact most have only been established on appeal, I do not know how the Council can possibly claim to have good track record of positively considering appropriate windfall sites. There is no obvious consistency in recent decisions and whilst it is welcomed that some have (finally) been made permanent it is far from clear why others have not. There remain far too many sites with temporary/ unauthorised pitches. It is not clear why plots at Lizvale Farm is not listed in Fig 7.5 or the rest of Orchard view given Hope Farm is supported. I am not clear what has happened to Cottage Gardens Beads Hall Lane or whether the Council has, in the alternative, agreed to a replacement house on this site. But if the owner still wants a caravan site this should be included in Fig 7.5 along with the unauthorised pitches at Blackmore and Hunters Green.

Para 7.83 Policy fails to allocate enough to meet the immediate need and fails to indicate broad locations for further provision.

Policy as drafted fails to do what is required. It is not NPPF/PPTS compliant. It will not address the immediate need for sites with no certainty future need will be met either.

More sites need to be put forward to meet the immediate need especially if there is to be reliance on Green belt sites.

Sites need to be inset from the Green Belt so that they stand any chance of being granted permission

Criteria for windfall sites need to be positive and fair. If sites can not be found in settlements then it is wholly unfair to include criteria (a) as this is a contradiction in terms .

There is no consideration of transit sites or how provision will be made. 2014 GTAA identified need for just two transit sites in Essex-bound to be woefully inadequate. Given the revised legal definition of GTs in PPTS Annex 1 far more transit provision must be found and delivered if GTs are to be able to maintain a travelling way of life. Brentwood is exceptionally well placed for Travellers coming to SE for work. Provision should be made along main transport corroders.

It is not clear how provision will be made for non travelling Gypsy Travellers ie those who fail the legal definition in Annex 1 PPTS either because they do not have a driving licence or are to young to legally tow a caravan, are too old to travel, are too infirm to travel, or are unable to travel for work due to caring responsibilities or for other reasons, yet may still retain a cultural preference to live in caravans with their own families and community and whose needs have to be addressed by Equalities Act 2010 .

Support

Draft Local Plan

Representation ID: 14263

Received: 19/03/2016

Respondent: Ms. Doreen Acton

Representation Summary:

I would like to register my support for the latest Brentwood Council's Planning policy for Gypsy / Travellers.

Full text:

I would like to register my support for the latest Brentwood Council's Planning policy for Gypsy / Travellers.

Attachments:

Object

Draft Local Plan

Representation ID: 14380

Received: 14/04/2016

Respondent: Thurrock Borough Council

Representation Summary:

The draft Local Plan recognises the recent changes made to legislation relating to Travellers and states that further work is being carried out to establish the number of Gypsy and Traveller pitches required within the Brentwood area. Thurrock Council is concerned however, that whilst Brentwood's local plan identifies the issues there may be un-met needs arising from neighbouring authorities for the provision to accommodate Gypsies and Travellers, and there is no acknowledgement of this within the Local Plan documents or implications for Duty to Cooperate.

It is considered that local authorities in Essex should acknowledge and have assessed the needs and requirements of Travelling Showpeople in the preparation of their local plans. It is recognised that Travelling Showpeople have become concentrated in a number of local authorities including Thurrock. Thurrock Council would wish to engage under the Duty to Cooperate with other authorities in Essex including Brentwood to ensure that there is appropriate provision for future needs and requirements of Travelling showpeople.

Full text:

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.

Attachments:

Comment

Draft Local Plan

Representation ID: 14533

Received: 19/04/2016

Respondent: Mr and Mrs Lighterness

Representation Summary:

It appears that the current 'view' (probably to meet government guide lines) is to squeeze such sites into existing spaces and gaps across the borough. Young people, struggling to buy or rent property, older people who have worked hard to establish their homes are expected to accept the sudden arrival of a caravan next door - a family who pitch for free. Whilst I understand the need to help all to a basic level of 'life', the Travellers site is rarely used as a Springboard into housing. The current Travellers zone at Blackmore should continue to be utilized and balanced with a similar site at Dunton Garden Village.

Full text:

See attached

Attachments:

Object

Draft Local Plan

Representation ID: 14719

Received: 21/04/2016

Respondent: Mr Brian Worth

Representation Summary:

The initial estimated 20 traveller pitches at Dunton Hills Garden Village is out of proportion to the much smaller allocations elsewhere. West Horndon Parish would be taking a disproportionate amount of the total pitch requirements of 67.

No indication has been given as to where the 20 pitches are to be located. NPPF states that the use of Green Belt for traveller/gipsy sites is classed as inappropriate development.

Such a site would harm the character and appearance of the Parish and result in an unacceptable visual impact. House prices in the area would plummet. The events of Dale Farm have proved how a supposed limit of a legal number of pitches can mushroom out of control.

Existing traveller sites are situated in locations away from developed areas because the travellers have chosen these secluded locations for compatibility with their lifestyle. Their wishes should be respected by allocating similar sites unbounded by other development.

Full text:

See attached.

Attachments:

Object

Draft Local Plan

Representation ID: 14724

Received: 20/04/2016

Respondent: Mr Joseph Manning

Agent: RPS Planning & Development

Representation Summary:

We object to the Local Plan in its entirety as 'unsound' with respect to the consideration of and provision for travelling showpeople community. We note that there is only one single reference to travelling showpeople in the draft Local Plan in its entirety, which relates to a title of a document (the GTAA). We would consider that the draft Local Plan, as it stands, is 'unsound' in this context as a result of this glaring omission.

Full text:

See attached

Attachments: