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.
The Environment Agency flood map shows that the location for the development of Dunton Hills Garden Village is at a high risk of surface water flooding in several areas. It is a critical drainage area. This means that it presently absorbs large amounts of water including water that runs off from surrounding areas. Removal of trees and other vegetation will reduce the ability of the area to absorb rainfall. Rain that falls on roof tops and road surfaces will be quickly channelled through surface drains needed to prevent flooding in the new development area.
The altitude of the land is mostly around 40m. The A127 presents a barrier to drainage systems because it is at a lower altitude of about 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.
It will be necessary to take into account events of extreme rainfall when up to 50mm can fall in a period of 24 hours. At times of persistent rain that are common during the winter in this area this could continue over periods of several days. Rain falling on 250 hectares of developed land will have to be managed via the drainage system. SuDS will not be sufficient to mitigate the risk to the wider area along the Mardyke. This could amount to 100,000 m3 of extra rain water in a day. It is estimated that the Mardyke River has a typical capacity of 50,000 m3 per day and is already prone to flooding causing inundations around West Horndon and Tilbury.
The development of the Dunton Hills area will thus multiply by a significantly factor the amount of water entering an area that is already the scene of many past floods. Mitigation will require an extensive system of flood defences and pumping stations at enormous cost. This will have to be done before building starts and will require agreements between Thurrock and Essex that are likely to be difficult to reach agreement on. There is a danger therefore that development will go ahead without any new flood defences and nothing will be done until the first major flooding event has already happened.
In my opinion the cost and uncertainty over the ability to control the flood risk makes the Dunton Hills Garden Village development unacceptable in its own right.

The Dunton area is already prone to flooding, and building thousands of houses on it will only make this worse.

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.

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

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

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

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


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

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

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

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

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

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

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

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

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

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

See attached

Draft Local Plan Consultation - January 2016

Thank you for consulting Thames Water on the above document. Thames Water are the statutory sewerage undertaker for the western areas of the Borough and the statutory water undertaker for a small area of the Borough and are hence a "specific consultation body" in accordance with the Town & Country Planning (Local Planning) Regulations 2012.

Policy 10.13: Flood Risk

Thames Water fully support Policy 10.13 on flood risk and in particular requirement (e) for development to avoid flood risk by:

"(e) demonstrating that the applicant has contacted the sewerage provider to identify whether the sewerage network has adequate capacity both on and off site to serve the development and to assess the need to contribute to any additional off site connections
for the development. Where capacity is identified as insufficient, development will only be permitted if it is demonstrated that improvements will be completed prior to occupation of the development."

Development of sewerage infrastructure cannot be delivered through CIL or S106 contributions approach covered by Policy 10.7. As such Thames Water consider that this policy is necessary to ensure that any infrastructure upgrades required to the sewerage network are delivered ahead of the occupation of development.

To ensure that there is clarity over the requirements of the policy the following additional supporting text could be included:

"The Local Planning Authority will seek to ensure that there is adequate wastewater infrastructure to serve all new developments. Developers will be required to demonstrate that there is adequate capacity both on and off the site to serve the development and that it would not lead to adverse amenity impacts for existing or future users in the form of internal and external sewer flooding or pollution of land and water courses.

In some circumstances this may make it necessary for developers to carry out appropriate appraisals and reports to ascertain whether the proposed development will lead to overloading of existing waste water infrastructure. Where there is a capacity constraint the Local Planning Authority should require the developer to provide detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered."

Policy 10.14: Sustainable Drainage

Thames Water fully support policy 10.14 on sustainable drainage. Thames Water will seek to ensure that SuDS are prioritised and implemented for developments of all sizes, and support policies on surface water flow reduction from brownfield sites that will ease pressure on the sewer network regardless of the size of the development and type of SuDS implemented.

Recognising that SuDS are only one of a number of competing considerations for developers when drafting their designs, and for local planning authorities when determining applications, we have reviewed the approach we take with local planning authorities and developers. We aim to:

- Engage with developers, local planning authorities and lead local flood authorities at the earliest possible opportunity when a development is known to be likely, working collaboratively wherever possible to ensure sewer flood risk is taken into account from the outset. This will help all parties understand the extent of any work needed before a development can proceed, and the costs.

- Provide local planning authorities with clear advice; proactively highlighting areas where foul water and surface water from new developments would pose an increased risk of floods from sewers, so that the impact of new developments is reflected in planning decisions.

- Adopt a more proactive approach by designing, funding, building, adopting and maintaining SuDS ourselves, in some circumstances with contributions from other parties where appropriate to make the scheme viable.

A copy of our policy on SuDS is attached for information.

Site Specific Comments

On the basis of the information contained within the draft Local Plan in relation to site allocations Thames Water has reviewed the potential impacts on existing infrastructure. Comments on the sites are attached to this response. The impact of development on wastewater infrastructure will also depend on the timing of delivery and point of connection to the network together with development elsewhere within the catchment.

In order to ensure that the water supply and drainage requirements of development proposals are understood and that any upgrade requirements are identified, all developers should be encouraged to contact Thames Water Developer Services in advance of the submission of planning applications.
Thames Water recommend that developers engage with them at the earliest opportunity to establish the following:

* The developments demand for water supply infrastructure both on and off site and can it be met;
* The developments demand for wastewater infrastructure both on and off site and can it be met; and
* The surface water drainage requirements and flood risk of the development both on and off site and can it be met.

Site ID: 50155
Site Name: 001A & 001B - Land North Of Highwood Close including St Georges Court
Waste Response: We have concerns regarding Wastewater Services in relation to this site. Specifically, the wastewater network capacity in this area is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a capacity constraint the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. At the time planning permission is sought for development at this site we are also highly likely to request an appropriately worded planning condition to ensure the recommendations of the strategy are implemented ahead of occupation of the development. It is important not to under estimate the time required to deliver necessary infrastructure. For example: local network upgrades can take around 18 months to 3 years to design and deliver.

Site ID: 37055
Site Name: 003 - Wates Way Industrial Estate, Ongar Road, Brentwood
Waste Response: We have concerns regarding Wastewater Services in relation to this site. Specifically, the wastewater network capacity in this area is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a capacity constraint the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. At the time planning permission is sought for development at this site we are also highly likely to request an appropriately worded planning condition to ensure the recommendations of the strategy are implemented ahead of occupation of the development. It is important not to under estimate the time required to deliver necessary infrastructure. For example: local network upgrades can take around 18 months to 3 years to design and deliver.

Site ID: 37063
Site Name: 013B - Warley Training Centre, Essex Way, Warley
Waste Response: We have concerns regarding Wastewater Services in relation to this site. Specifically, the wastewater network capacity in this area is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a capacity constraint the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. At the time planning permission is sought for development at this site we are also highly likely to request an appropriately worded planning condition to ensure the recommendations of the strategy are implemented ahead of occupation of the development. It is important not to under estimate the time required to deliver necessary infrastructure. For example: local network upgrades can take around 18 months to 3 years to design and deliver.

Site ID: 48737
Site Name: 022 - Land At Honeypot Lane, Brentwood
Waste Response: We have concerns regarding Wastewater Services in relation to this site. Specifically, the wastewater network capacity in this area is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a capacity constraint the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. At the time planning permission is sought for development at this site we are also highly likely to request an appropriately worded planning condition to ensure the recommendations of the strategy are implemented ahead of occupation of the development. It is important not to under estimate the time required to deliver necessary infrastructure. For example: local network upgrades can take around 18 months to 3 years to design and deliver.

Site ID: 50159
Site Name: 032 - Land East Of Nags Head Lane, Brentwood
Waste Response: On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

Site ID: 37064
Site Name: 039 - Westbury Road Car Park, Westbury Road, Brentwood
Waste Response: On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

Site ID: 37065
Site Name: 040 - Chatham Way/Crown Street Car Park, Brentwood
Waste Response: On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

Site ID: 37067
Site Name: 041 - Land at Hunter House, Western Road, Brentwood
Waste Response: On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

Site ID: 50156
Site Name: 044 & 178 - Land At Priests Lane, Brentwood
Waste Response: We have concerns regarding Wastewater Services in relation to this site. Specifically, the wastewater network capacity in this area is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a capacity constraint the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. At the time planning permission is sought for development at this site we are also highly likely to request an appropriately worded planning condition to ensure the recommendations of the strategy are implemented ahead of occupation of the development. It is important not to under estimate the time required to deliver necessary infrastructure. For example: local network upgrades can take around 18 months to 3 years to design and deliver.

Site ID: 50158
Site Name: 099 - Victoria Court, Victoria Road, Brentwood
Waste Response: On the information available to date we do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

Site ID: 37077
Site Name: 100 - Baytree Centre, Brentwood
Waste Response: We have concerns regarding Wastewater Services in relation to this site. Specifically, the wastewater network capacity in this area is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a capacity constraint the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. At the time planning permission is sought for development at this site we are also highly likely to request an appropriately worded planning condition to ensure the recommendations of the strategy are implemented ahead of occupation of the development. It is important not to under estimate the time required to deliver necessary infrastructure. For example: local network upgrades can take around 18 months to 3 years to design and deliver.

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