I hereby express my objection to the proposed planning of THE DUNTON HILLS GARDEN VILLAGE. It seems absurd to create such a massive project without thinking it all through in great detail before going public. Here are some specific objection points to the proposal:- ● The effect on wildlife ● Schools: We have a hard enough time already finding good enough schools in the area, without creating another housing estate and no more school places. ● Transportation: The A127 is already gridlocked at rush hour times, it would only make matters worse. A128 is also gridlocked in rush hour traffic as most of the good schools all seem to be in that direction BRENTWOOD! The traffic that enters and exits the Ford Dunton site causes extra volumes of traffic at peak times; with the housing estate Dunton Fields that is already being built it WILL only get worse! ● FLOODING!: Everytime it rains the roads get flooded. We will need a proper drainage system that will also cope with the loss of significant soakaway land due to the additional building development. ● Services: Hospital services and doctor surgeries are already oversubscribed, additional provisions need to made for the significant increase in population ● Traveller Pitches: There are already two traveller pitches that reside in the VILLAGE OF DUNTON; this provision seems to be more than adequate. ● Greenbelt: The building on GREENBELT LAND is absolutely UNFORGIVEABLE! The Green corridor to the area around Langdon Hills is one of the most unspoilt areas of Basildon for recreation, wildlife and views and should be preserved for the quality of life of all residents.

I hereby express my objection to the proposed planning of THE DUNTON HILLS GARDEN VILLAGE.
It seems absurd to create such a massive project without thinking it all through in great detail before going public.
Here are some specific objection points to the proposal:-
● The effect on wildlife:
● Schools:
o We have a hard enough time already finding good enough schools in the area, without creating another housing estate and no more school places.
● Transportation:
o The A127 is already gridlocked at rush hour times, it would only make matters worse.
o A128 is also gridlocked in rush hour traffic as most of the good schools all seem to be in that direction BRENTWOOD!
o The traffic that enters and exits the Ford Dunton site causes extra volumes of traffic at peak times; with the housing estate Dunton Fields that is already being built it WILL only get worse!
● FLOODING!
o Everytime it rains the roads get flooded. We will need a proper drainage system that will also cope with the loss of significant soakaway land due to the additional building development.
● Services
o Hospital services and doctor surgeries are already oversubscribed, additional provisions need to made for the significant increase in population
● Traveller Pitches
o There are already two traveller pitches that reside in the VILLAGE OF DUNTON; this provision seems to be more than adequate.
● Greenbelt
o The building on GREENBELT LAND is absolutely UNFORGIVEABLE! The Green corridor to the area around Langdon Hills is one of the most unspoilt areas of Basildon for recreation, wildlife and views and should be preserved for the quality of life of all residents.

Dear Council Leader,

I am a resident of Basildon Borough, a close neighbour to Brentwood, which will be affected by whatever local plan is adopted by Brentwood Council.

As such, I wish to object to your proposed ideas for the Local Plan as follows:

1. Building on Green Belt land. The Green Belt MUST always remain as such, and be protected, with no housing allowed. It is the lungs around Brentwood, Basildon and surrounding areas, but is also part of the lungs of the London metropolitan area.

National planning policy is clear that the Green Belt boundaries should only be altered in exceptional circumstances, and the need for housing does not constitute an exceptional circumstance.

Our local Green Belt is a haven for many varieties of wildlife. To name a few, there are hedgehogs, badgers, foxes, frogs, toads, newts, dormice, slow worms, bats, owls, birds of prey and smaller birds, all of which depend on the undisturbed country areas. They can migrate and inter-breed through the Green Belt corridor, but if parts of it are taken away for housing, populations will become isolated and, only able to inter-breed within a small area, will die out.

2. Any building allowed on Green Belt land will constitute a precedent for the future, and once built on, the Green Belt can never be replaced.

3. Green Belt is also required for peoples' leisure pursuits and for the education of our children. To be able to get out into the local countryside is to improve mental health. The more growth there is in the town, the more these are needed.
There have to be facilities for children to play: There have to be parks, sports facilities, community centres. Not enough of these exist at present, and with land being taken up by housing, where are they to go?

4. All brownfield sites must be used before any Green Belt is even considered - and there are plenty of brownfield sites around London and around the country as a whole. London has a much greater capacity to absorb population increases than the towns and villages around South Essex.

5. The predicted increase in population of the area may well have slowed significantly since the result of the EU referendum in 2016. Net migration to the UK in 2017 showed the largest annual fall since records began. Therefore the predicted growth may not be necessary.

6. I see that a new school is proposed for Dunton Hills, but this would not be sufficient to accommodate the total influx of children and local schools and colleges are already full.

7. A large percentage of workers from Brentwood commute into London to work. Where are you going to find the extra capacity on the already overcrowded trains? How will you create the extra parking needed at the station? What new employment opportunities will there be locally?

8. The influx of people will require at least one new hospital, and GP surgeries and dentists are already overstretched. How is this going to be addressed and where are you going to build the new hospital?
Care homes and retirement homes will need to be built. The current facilities will not be sufficient for any influx.

9. Putting all new migrants to the area in one place, i.e. a housing estate, could create ghettoes and cause conflict.

10. A large increase in population of the borough will irrevocably change the character of the town. Expansion will see all the towns and villages merging into one huge connurbation and we will end up as just another suburb of London.

Dear Sirs,

Thank you for your letter of the 2nd February. We have carefully considered all documents relating to the Brentwood Development Plan.

The Plan which is fatally floored (for numerous reasons) must be re-visited we respectfully suggest to rectify errors and omissions.

The vast majority of building will be on Green Belt and we consider that the majority of houses will not be required in this area. Our observations and objections include the fact that more than 50% of the sites can be deemed de minimis development (where homes to be constructed total less than 5% of total development). Homes on these sites will be marketed in the price band of £1.5million to £2million pounds. Stratospherically beyond the reach of first time buyers or even purchasers assisted by the Bank of Mum and Dad.

Also, one might say fatally, the effect of the development termed Dunton Garden is misdescribed. It should be titled Dunton Pollution for the subsequent increase in vehicle numbers entering the A127 at the junction of the A 128 Brentwood Road. So close to a junction on that arterial road that is already so heavily polluted that Basildon Council intended to introduce a congestion charge. It is patently obvious that the two Councils concerned (Brentwood and Basildon) are in conflict. Basildon says too many vehicles use the A127 that there is a danger to health and Brentwood says let us allow another 10,000 vehicles or so onto this road. We would suggest that to endeavour to reduce the conflict you triple number of medical facilities in the Dunton development , this should assist in meeting demands caused by the dramatic increase in the number of vulnerable people, children and the elderly who will suffer asthma and respiratory disease.

Nobody of course knows when the vehicles arrive at the junction onto the A127 whether they will head left right or continue along the A128. However, this increase in traffic coupled with traffic from other sites including industrial/employment areas along the stretch of road leading to the junction with the M25 will no doubt increase levels of health harming pollutants that will overtake the whole area to include villages of Herongate and Ingrave and possibly even Brentwood town itself. It should be remembered that Schools and Care Homes are sited along the A128. The proposed development at Dunton completely ignores 2 critical facts (a) unless ALL housing is zoned as social housing the whole development will b unaffordable to first time purchasers.
Having tracked house prices in the Horndon area since the year 2000 a conservative estimate of house prices by 2030 would project to be £ 1million to £ 1.5 million pounds. Importantly (b) the only way these properties could be occupied by first time buyers would be through shared or joint ownership viz : with an aged parent or relative living in the property with a young couple which leads to further potential pollution additional victim and probably additional car owner , together with added strain on medical facilities.

Also and just as importantly the effect of the UK leaving the EU has not been factored into the Plan. We have yet to discover the number of residents in Brentwood who are dual nationals and entitled to reside in countries outside the UK. Taking into account medical, health and pharmacy workers, care home personnel and members of the professions together with retail outlet owners and their employees we estimate the number at between 3,000 and 4,000 (including dependents). The number for the whole of the UK exceeds five million(and rising). If negotiations with the EU lead to an adverse effect on the UK economy dual citizens will leave and settle in EU member states or indeed other countries of the World.

The Plan to concrete over the Green Belt and Farmland will have been proven to have been unnecessary yet lasting harm will have been inflicted on the people and their environment.

It is a fact that Developers are guilty of land banking, sitting on land where Planning Permission has been granted but failing to build, purely to increase profit through increase in land values.. Within the last 10 years these sites, if built upon, would have provided in excess of 800,000 homes in this Country. How many would have been affordable homes is a matter of conjecture, because the developers often inform Councils that they cannot afford to develop a site with the number of social units imposed, Councils are pressured to reduce the number of social dwellings planned originally.

Even when sites are developed the Builders are ensuring there are hardly any affordable houses built (see Report Guardian 5th March 2018). In Manchester none of the 14,667 homes in big developments granted Planning Permission in the last 2 years are set to be "affordable", Planning documents show - in direct contravention of its own rules and the Government's definition. In Sheffield where house prices grew faster last year than in any other UK city (but we would suggest Brentwood and Ingatestone would be closely behind). Only 97 out of 6,943 approved by Planners in 2016 and 2017 met the Government's affordable definition. That says homes must either be offered for social rent (often known as Council housing), or rented at no more than 80% of the local market rate. In Nottingham where the Council aims for 20% of new housing to be affordable just 3.8% of the units given the green light by Council Planners meet the definition. If Brentwood is not strict with developers the results will be the same as those mentioned (supra).

The Development Companies are responsible for shortage of housing in certain area, by drip feeding dwellings onto the market to increase house prices. This prevents , in particular, first time buyers from gaining a foot on the housing ladder. The dramatic decline in home ownership amongst the young does not lie with Parents or Grandparents but with people who control the supply of social housing.

The reasons set out in this communication should, we hope, send the Council (indeed all Councils) to review their respective Plans. They might consider halving the intended housing units to be built whilst leaving in position all infrastructure planned with medical facilities doubled to ensure all citizens timely access to health care and other amenities.

Yours faithfully,

Dear Sirs,

Thank you for your letter of the 2nd February. We have carefully considered all documents relating to the Brentwood Development Plan.

The Plan which is fatally floored (for numerous reasons) must be re-visited we respectfully suggest to rectify errors and omissions.

The vast majority of building will be on Green Belt and we consider that the majority of houses will not be required in this area. Our observations and objections include the fact that more than 50% of the sites can be deemed de minimis development (where homes to be constructed total less than 5% of total development). Homes on these sites will be marketed in the price band of £1.5million to £2million pounds. Stratospherically beyond the reach of first time buyers or even purchasers assisted by the Bank of Mum and Dad.

Also, one might say fatally, the effect of the development termed Dunton Garden is misdescribed. It should be titled Dunton Pollution for the subsequent increase in vehicle numbers entering the A127 at the junction of the A 128 Brentwood Road. So close to a junction on that arterial road that is already so heavily polluted that Basildon Council intended to introduce a congestion charge. It is patently obvious that the two Councils concerned (Brentwood and Basildon) are in conflict. Basildon says too many vehicles use the A127 that there is a danger to health and Brentwood says let us allow another 10,000 vehicles or so onto this road. We would suggest that to endeavour to reduce the conflict you triple number of medical facilities in the Dunton development , this should assist in meeting demands caused by the dramatic increase in the number of vulnerable people, children and the elderly who will suffer asthma and respiratory disease.

Nobody of course knows when the vehicles arrive at the junction onto the A127 whether they will head left right or continue along the A128. However, this increase in traffic coupled with traffic from other sites including industrial/employment areas along the stretch of road leading to the junction with the M25 will no doubt increase levels of health harming pollutants that will overtake the whole area to include villages of Herongate and Ingrave and possibly even Brentwood town itself. It should be remembered that Schools and Care Homes are sited along the A128. The proposed development at Dunton completely ignores 2 critical facts (a) unless ALL housing is zoned as social housing the whole development will b unaffordable to first time purchasers.
Having tracked house prices in the Horndon area since the year 2000 a conservative estimate of house prices by 2030 would project to be £ 1million to £ 1.5 million pounds. Importantly (b) the only way these properties could be occupied by first time buyers would be through shared or joint ownership viz : with an aged parent or relative living in the property with a young couple which leads to further potential pollution additional victim and probably additional car owner , together with added strain on medical facilities.

Also and just as importantly the effect of the UK leaving the EU has not been factored into the Plan. We have yet to discover the number of residents in Brentwood who are dual nationals and entitled to reside in countries outside the UK. Taking into account medical, health and pharmacy workers, care home personnel and members of the professions together with retail outlet owners and their employees we estimate the number at between 3,000 and 4,000 (including dependents). The number for the whole of the UK exceeds five million(and rising). If negotiations with the EU lead to an adverse effect on the UK economy dual citizens will leave and settle in EU member states or indeed other countries of the World.

The Plan to concrete over the Green Belt and Farmland will have been proven to have been unnecessary yet lasting harm will have been inflicted on the people and their environment.

It is a fact that Developers are guilty of land banking, sitting on land where Planning Permission has been granted but failing to build, purely to increase profit through increase in land values.. Within the last 10 years these sites, if built upon, would have provided in excess of 800,000 homes in this Country. How many would have been affordable homes is a matter of conjecture, because the developers often inform Councils that they cannot afford to develop a site with the number of social units imposed, Councils are pressured to reduce the number of social dwellings planned originally.

Even when sites are developed the Builders are ensuring there are hardly any affordable houses built (see Report Guardian 5th March 2018). In Manchester none of the 14,667 homes in big developments granted Planning Permission in the last 2 years are set to be "affordable", Planning documents show - in direct contravention of its own rules and the Government's definition. In Sheffield where house prices grew faster last year than in any other UK city (but we would suggest Brentwood and Ingatestone would be closely behind). Only 97 out of 6,943 approved by Planners in 2016 and 2017 met the Government's affordable definition. That says homes must either be offered for social rent (often known as Council housing), or rented at no more than 80% of the local market rate. In Nottingham where the Council aims for 20% of new housing to be affordable just 3.8% of the units given the green light by Council Planners meet the definition. If Brentwood is not strict with developers the results will be the same as those mentioned (supra).

The Development Companies are responsible for shortage of housing in certain area, by drip feeding dwellings onto the market to increase house prices. This prevents , in particular, first time buyers from gaining a foot on the housing ladder. The dramatic decline in home ownership amongst the young does not lie with Parents or Grandparents but with people who control the supply of social housing.

The reasons set out in this communication should, we hope, send the Council (indeed all Councils) to review their respective Plans. They might consider halving the intended housing units to be built whilst leaving in position all infrastructure planned with medical facilities doubled to ensure all citizens timely access to health care and other amenities.

Yours faithfully,

Short of actually building homes in a neighbouring borough, this proposal seems calculated to maximise impact on the neighbouring borough of Basildon with minimising impact on the existing communities of Brentwood. It thus seems to be the embodiment of the nimby mentality. The population of Basildon and surrounding areas already suffer with both significant road congestion on the A127 and A13, and overcrowding of C2C trains which this proposal will only increase; although of course the good people of Brentwood are hardly likely to notice being well served by the A12 and separate Greater Anglia trains into London. There is a lack of capacity at both Laindon or West Horndon stations for additional commuter car parking. The A128 northbound from the proposed development area into Brentwood is, of course, already heavily congested. I would thus like to see significant improvement in transport links from the proposed development area including: 1. The A128 to become a dual carriageway from the proposed development into Brentwood Town Centre to allow these new Brentwood residents to access Brentwood services. 2. An extra lane on the A127 in each direction as far as the M25 to cope with additional commuter traffic. 3. A new railway station between Laindon and West Horndon to support commuting into London accompanied by increased capacity of train services i.e. more frequent services, or more coaches on each service.

I strongly oppose the plan put forward by Brentwood borough council to build thousands of houses on green belt land adjacent to the A127. Besides the basic principle that you will destroy desperately needed green belt land and all the wildlife which survives there, there is also the considerable traffic and pollution increase which will be suffered by all residents of west Horndon, Basildon and all points east of the development. Whilst Brentwood is enjoying the benefits of millions of pounds being spent on improving the A12 no money will be spent on the A127 which already suffers horrendous traffic during morning and evening rush hours. Also let's talk infrastructure, clearly you intend to build these houses as far from Brentwood town as possible so these new residents would obviously resort to using Basildon train stations, schools, hospitals etc all of which are already in desperate over capacity. Basildon hospital is constantly on black alert, most of the children in west Basildon already have to travel miles to get to a secondary school as there are none available in this area. Primary schools are stretched beyond limits. Commuters, C2C have already stated in writing that under no circumstances would they build a new station to service the residents, so they will need to drive to a local train station, none of which can take anymore cars. You intend to build traveller pitches again disposing of your problem as far from Brentwood as possible. There are large areas of Brentwood which could be used to reach your housing targets but you clearly prefer to put this on others doorsteps. I will object strongly at every level possible to your continued attempt to ruin the communities surrounding Brentwood.

This email is to show my objection to the proposal of the new Dunton garden suburb .I am apposed to any building on the green belt also the infrastructure as it exists is inadequate and you are not taking into consideration the flooding implications this imposes on other areas eg Thurrock especially the Mydyke area.
Please submit this to the consultation

When the East of England New Homes policy was introduced to Brentwood residents we were asked to comment on it. We were informed how many new homes were being proposed for Brentwood and asked what number we thought would be appropriate. My pragmatic, and I believe fair, answer was as many as brown fill sites in our area would accommodate. Since then my preference for building on brown fill and other sites, situated in our town, has reversed for two reasons - the first, a negative one, the second, a positive. Four or five years ago, following the development of the Highwood and Little Highwood hospital sites, one of the two single handed G.P.s working on there retired leaving 1500 patients without a doctor. I was at this time, and continue to be, a member of the patient participation group at my doctors' practice in the town. I learnt that my practice had offered to take over the practice on the Highwood Hospital site provided it was not out of pocket, ie the PPG (as it was at the time) would pay for the rent and upkeep of the surgery and for staffing it, as another G.P. would have to be employed - the PPG refused to accept the costs insisting that the patients could be absorbed onto the lists of local G.P.s. Our practice manager contacted our P.P.G. members, as a matter of urgency, to ask us if we should close our list to new patients, as the other local practices had. With there being a two to three week wait for a non-urgent G.P. appointment, even then, the answer was a resounding yes. It was only then, when 1500 patients were bereft of a G.P., that the P.P.G. agreed to the terms offered by my practice. I find this attitude to the provision of an important local service alarming and I am fearful for the wellbeing of the residents of Brentwood if new homes are built within close proximity of the town, whether it be on brown fill sites or other areas, as currently proposed. It goes without saying that this could be the tip of the iceberg as other important services such as schools could suffer from local overdevelopment. This makes no mention of the obvious increase in traffic that we have seen and will have to endure further, if these developments go ahead and because of the stop/start nature of the vehicles in these traffic jams, the increase in pollution and resulting health problems. On a positive note, I was very impressed with the plans for the Dunton Garden Village. With its integrated infrastructure this will offer tremendous advantages, in so many ways, over developing the town and its nearby environs. One small example of this would be the provision of locality shops and I believe it is interesting to note that, despite being enlarged, the Sainsburys car park still gets very full and can be quite a dangerous place both for drivers and pedestrians. I strongly believe that a number of satellite developments, such as Dunton Garden Village, will offer the best solution to the need for new homes in our area despite these settlements having to be developed on green belt land which I understand some of the proposed sites are anyway. I am also confident that fewer people would be affected by this type of development as these sites will be in less populated areas and, because of their self reliance, there would be less traffic coming into Brentwood which would be a big benefit for so many residents living in and close to the town. There will no doubt be a great deal of "nimbyism" over any proposal, but for my part my wife and I have often discussed our indifference to the field between where we live in Viking Way and the A12 being built on as, on the one hand we would lose some open land, which I believe was at one time designated as green belt, but buildings on it would shelter us from some of the road noise from the A12 - this has been measured and found to be above an acceptable level but in these times of austerity nothing has been done about it. On the subject though, it does strike me as being a strange choice for development as nine or ten years ago, when Brentwood Council was charged with finding sites for travellers (I believe the scheme was dropped following a change of government), the field in question was under consideration for such a site but it was removed from the list because it was considered to be unsafe for travellers to live there as it represented a health hazard owing to the levels of pollution from the A12. To summarise, the planners could follow what seems to be happening at present and develop the area in and around Brentwood town even further, squeezing out a large number of green areas, creating an infrastructure pushed beyond its capacity and creating traffic chaos along with the accompanying health risks from pollution. The alternative would be radical and would represent "thinking outside the box". It would upset fewer residents, in total, and give rise to less of the problems highlighted above, giving rise to all residents finding Brentwood a more pleasant place to live compared with the alternative. I firmly believe developing more sites like the Dunton Garden Village would be the best choice for Brentwood and, more importantly, its residents. I guess it comes down to the quality of life that it is considered appropriate for Brentwood residents, old and new. This could be maintained for those currently living in Brentwood and a really good quality of life could be afforded to the newcomers. Alternatively, it could be diminished for all of us.

With Reference to BBC draft local plan headed Dunton Hills Garden Village. I strongly object to Brentwood Councils plans as described under the title of Dunton Hills Garden Village and I consider inappropriate development that it should not be taken any further. These are my reasons are my objections: The land in question is within the Green Belt, which is designed to prevent urban sprawl by keeping the area open and free from inappropriate development. It is proposed to build the Dunton Hills Garden Village on land that is essentially a critical stretch of Green Belt land because it is close to Brentwood Council's boundary with Basildon Council. Therefore, this development contravenes Green Belt policy and will decimate the rural character of the area. The infrastructure of the surrounding area is already stretched to capacity and cannot support such a huge development. The A128 and A127 roads, closest to this development and their connecting roads are totally inadequate for such a huge development. They are already subject to heavy congestion and restricted traffic flows, especially at the start and end of the working day when traffic is at its heaviest. These roads cannot sustain the increase of traffic generated by the building of 2,500 houses with the possibility of expanding the development at a later date. This development would set a precedent for similar development on Green Belt land. This development would have a catastrophic negative affect on the habitat of the wildlife in this area.

I am writing in connection with the public consultation on the proposals for the Dunton Hills Garden Village, part of your Local Plan. As a resident within the Dunton area, residing within the Basildon Council area, and having weighed up the pros and cons of the proposals, I feel strongly compelled to register my opposition to the plans for the Dunton Hills Garden Village. One of my most pressing concerns, as member of the Essex Wildlife Trust and a lifelong wildlife and nature enthusiast, is the fact that the plans will consume valuable Green Belt land. This in itself is wholly unacceptable and totally unnecessary. Green Belt preservation MUST be taken into account when meeting housing quotas and creating Local Plans. Only in exceptional circumstances can large swathes of valuable countryside be removed. The circumstances surrounding the Dunton Village Garden Suburb are certainly NOT exceptional. My partner and I moved to the Dunton area for rest and peace. For me personally, nature therapy has proved significantly curative. Scientific evidence abounds backing the benefits of spending time in natural environments. Of course this is just one aspect. Another is biodiversity. Biodiversity is essential in boosting our ecosystems which in turn have considerable impact upon factors of national importance, such as crop harvests. Biodiversity is the cornerstone of natural sustainability for every form of life. Removing Green Belt land and the vital habitats it provides for plants, trees and animals leads to ecosystem instability, loss of valuable species and ultimately, climate change. Surely with some creative thinking, there is an alternative solution that does not involve the destruction of the beauty and heritage for which the UK is affectionately known? It is time to start thinking laterally and to stop disregarding what is of true importance. The thought of losing a significant proportion of our beautiful countryside in the name of commercial development, where is has been proved and evidence presented that endangered species are dwelling, is incredibly upsetting. It is simply unacceptable. Another area of concern is of course the pressure on our local infrastructure. It seems strange that 'Brentwood Enterprise Park' is actually going to be situated in and putting pressure on the local infrastructure of Basildon Borough Council. And of course eating up our valuable Green Belt land. It is currently enough of a challenge to get a doctor's appointment or to see a consultant at a local hospital. Accident and emergency waiting times are excessive already. The roads are busy enough, and our local transport network is under too much pressure. In other words, we have enough burdens upon our current infrastructure. I would appreciate it if you would please record my comments and opposition to the proposals for the Dunton Hills Garden Village.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

Objection to proposed Dunton Hills Garden Village
I object to these proposals for the following reasons.
Green Belt
The proposed site of Dunton Hills Garden Village lies on a critical stretch of green belt between Basildon and Upminster. It prevents coalescence of London with Basildon and towns to the east out to Southend. Dunton Hills is currently the least developed part of this green belt area. Much of the rest already has small clusters of houses and industrial sites. With additional development around West Horndon, and an enterprise park by the A127/M25 junction, Dunton Hills Garden Village is likely to trigger further development in the area. This could also extend into Thurrock and North of the A127.
The Brentwood Green Belt review shows that Dunton Hills meets the purpose of the green belt (as defined in the NPPF) in multiple ways, yet it is being developed before other areas of Brentwood that are less important.
Road Infrastructure
Dunton Hills Garden Village will be built next to the A127 which is already well documented as a congested route. The road will already suffer under the pressure of some 90,000 homes to be built further East. Building Dunton Hills Garden Village near this route will make any future planned upgrade of the road more difficult.
Other roads running perpendicular to the A127 are also inadequate for this development. In particular it is expected that residents of Dunton Hills Garden Village will frequently need to travel towards the Borough's central town of Brentwood along the A128. This road passes through the villages of Ingrave and Herongate where speed is restricted and minor accidents are frequent. This road falls far short of coping with the existing load and cannot possibly cater for the additional traffic of another 4,000 homes.
It is argued by Brentwood Council that by concentrating development all in one place it will be easier to fund improvements to infrastructure such as roads. This is not true because the funds available from infrastructure levies will not be sufficient and will be used up on other needs such as health care, schools, flood defence etc. The A127 is not a trunk road so it cannot get central government funding. Essex County does not have funding because it is investing in roads further North such as the A120.
Even if funding could be found to improve roads in the vicinity of Dunton Hills, the timescale for implementing such improvements would be too long. This contrasts with the situation along the A12 corridor where plans to widen the road to three lanes are already well funded and well advanced.
Rail Infrastructure
Dunton Hills Garden Village will be situated next to the C2C line which runs from Shoeburyness into London Fenchurch Street. Like the A127 this rail link already anticipates extra load from other developments to the East. It's capacity can be increased a little with longer carriages and improved signalling, but beyond that there are harder limits set by the fact that it has only two tracks for most of its length and Fenchurch Street Station itself is too small.
Again this contrasts with the situation along the A12 corridor through Brentwood which is benefiting from huge investment in Crossrail. The government would not have approved such an upgrade if they did not anticipate that it would increase capacity on that line and should therefore help unlock housing development to the centre and North of the borough.
Flooding
Surface water from roads and roofs in Dunton Hills Garden Village will be channelled rapidly into the Mardyke River that runs through Thurrock. Much of the area surrounding this river has been hit by the river flooding in the past, including West Horndon, Bulphan and settlements further downstream as far as Purfleet.
The developer proposes a SUDS system to mitigate the flood risk but this could be overwhelmed in times of persistent rain. Furthermore the cost of flood systems will absorb funding needed for other infrastructure to support the huge development.
Wildlife
Dunton Hills is the largest remaining pocket of countryside in the area that still has an unchanged landscape going back to at least Anglo-Saxon times. This is characterised by field boundaries marked by ditches and lines of Oak trees with water features such as ponds that were present on the earliest detailed maps of the area from the 19th century. The ditches, hedgerows, ponds and ancient woodland are home to established populations of rare wildlife. Although it is not designated as a nature reserve or conservation area, the Essex Wildlife Trust have characterised Dunton Hills as an important wildlife corridor between the Langdon Hills and Thorndon Country Parks.
The area along the Mardyke tributary is designated as a Local Wildlife Site with ancient woodlands. In the original Dunton Garden Suburb plans this area was to be left as a green buffer, but with the increase in the number of houses planned there will now be housing development up to the edge of the Local Wildlife Site. The pressure from people walking and domestic animals will drive the rarest wildlife out of this area. No amount of mitigation or biodiversity offsetting can compensate for the inevitable loss of wildlife habitat.
Ineffective Development
Brentwood Borough's need for housing is centred on its own main town where there is a severe lack of affordable housing. Instead of providing adequate new development across the borough and in areas with easier access to it's employment areas, Brentwood has decided to build nearer to towns like Basildon. As a result house prices in Brentwood which are already too high are likely to soar beyond the reach of everyone except the very rich. It will become impossible for the borough to house its key workers and the area is therefore likely to suffer from a lack of teachers and nurses in particular.
Pollution
The area around the A127 has already recorded excesses of NO2 pollution from cars. Other air quality factors such as particles are not monitored here but are known to be excessive in nearby Stanford-Le-Hope. The Thames crossing route will also increase air pollution that will be blown across this area. Further sources of pollution from the garden village could be damaging to health in the area.
Hospitals
Orsett hospital is being demolished for housing to be replaced with smaller medical centres. Accident and emergency cover in the area is likely to be further strained. Already Basildon and Thurrock hospital is on black alert or worse on over 50% of days. Instead of plans to increase capacity we have plans to combine services to save costs. The healthcare in the area is likely to be degraded by such over-development of the area.
Travellers and Gypsies
Brentwood plans a huge traveller site of 30 pitches in the Dunton Hills area which will sit next to housing communities. In past policy the government has recommended that the maximum manageable size for traveller sites is 15 pitches. Brentwood has chosen to place more than half of its assessed need for traveller pitches south of the A127 in concentrated pockets. It seems unlikely that this will suit the needs of either the traveller community or the permanent community.

With the current economic situation and vast budget cuts to Local Authorities/Borough Councils - How would this proposal be funded?
With a proposal to develop so many homes plus Travellers pitches realistically there will be more than 1 person per house/pitch. how would the infrastructure be prepared and developed to accommodate this? and who would fund this?
With major cuts to Council budgets and in turn vast redundancies of council workers - who would be supporting this? will the councils be re-employing people in a time of cuts to front line services?
How would the real issue of flooding be addressed? Building on green land at the bottom of a hill with a road that frequently floods is a real concern? Who would pay for the additional grand works and frequent repairs for homes in an area which is prone to flooding?
Who will pay for the new roads? - the Dunton road does not have pathways and is already in grave need of repair? With the identified area being so far away from any services the occupants would have no option but to drive? How would a minimum of 6,000 cars be supported to navigate the roads and commute when the A127 is already at a standstill each morning and evening?
Realistically with the distance from local amenities how would another "Jaywick" situation be prevented?
How would the additional Sewage be addressed and who would pay for this? There would be a need for a new sewage plant - who would fund?
With additional houses will local parking be addressed? Where would all there visitors park? On the Dunton road? The Dunton road does not even allow for 2 width cars to pass in normal circumstances?
How will the issue of School/nursery spaces be addressed and who will fund this?
There is already no senior school in the area - who will fund the senior school be funded?
Will a new Dunton Train Station be required? Who will fund this?
Bus services? Not everyone drives - how and who would fund for the repair of the roads, removal the bridge on Dunton road for a bus route?
How would crime be addressed - Laindon police Station is closed - who will fund for this to be reopened and staffed?
How would employment be addressed? Cars/bus routes would be required to access the jobs/Job Centre - who will fund this?
The current roads are already full of pot holes - will these be fixed first and if so who will pay?
Hospitals - Basildon Hospital is already bursting and unable to cope, there are no parking spaces - with the only guarantee of a space to arrive by ambulance - who will fund for the hospital to improve and accommodate these additional people? An additional car park would also be required? Basildon Hospital has no plans for expansion - if this development was to go ahead this is jeopardising people's health and well-being - who would put on additional services to fund the additional health and mental issues which will arrive?
Dr surgeries - with the current situation for obtaining an appointment and referrals' to specialist services - who will fund the new Doctors surgery and specialist surgery provisions?
Additional Parking spaces for Basildon Town Centre will need to be developed as it is already at maximum capacity - who would pay for this?
With the amount of infrastructure which needs to be developed to even realistically comprehend this development it is unachievable and would take approx. 20 years - who would pay?
Would Basildon Council Tax increase to fund this? In a borough which already experiences huge amounts of deprivation with stretched services - how can this be considered a solution?
In regard to the travellers pitches - where are the services for the travellers - who would fund this? With the green belt land within the proposed area - who would fund someone to monitor for this for illegal set up of additional pitches? will we end up with another Crays Hill Dale farm situation? If yes who will fund for this to be addressed?
The area proposed is precious greenbelt - home to endangered species, where would they go? Who will pay for them to be rehomed? Is this proposal legal due to the area being green belt with endangered species bats, water voles, great crested newts etc

Considering this is a Brentwood proposal this will mainly effect Basildon residents... you can't just move the issue onto someone's doorstep when there are already thousands of homes being built within basildon.

With the current economic situation and vast budget cuts to Local Authorities/Borough Councils - How would this proposal be funded?
With a proposal to develop so many homes plus Travellers pitches realistically there will be more than 1 person per house/pitch. how would the infrastructure be prepared and developed to accommodate this? and who would fund this?
With major cuts to Council budgets and in turn vast redundancies of council workers - who would be supporting this? will the councils be re-employing people in a time of cuts to front line services?
How would the real issue of flooding be addressed? Building on green land at the bottom of a hill with a road that frequently floods is a real concern? Who would pay for the additional grand works and frequent repairs for homes in an area which is prone to flooding?
Who will pay for the new roads? - the Dunton road does not have pathways and is already in grave need of repair? With the identified area being so far away from any services the occupants would have no option but to drive? How would a minimum of 6,000 cars be supported to navigate the roads and commute when the A127 is already at a standstill each morning and evening?
Realistically with the distance from local amenities how would another "Jaywick" situation be prevented?
How would the additional Sewage be addressed and who would pay for this? There would be a need for a new sewage plant - who would fund?
With additional houses will local parking be addressed? Where would all there visitors park? On the Dunton road? The Dunton road does not even allow for 2 width cars to pass in normal circumstances?
How will the issue of School/nursery spaces be addressed and who will fund this?
There is already no senior school in the area - who will fund the senior school be funded?
Will a new Dunton Train Station be required? Who will fund this?
Bus services? Not everyone drives - how and who would fund for the repair of the roads, removal the bridge on Dunton road for a bus route?
How would crime be addressed - Laindon police Station is closed - who will fund for this to be reopened and staffed?
How would employment be addressed? Cars/bus routes would be required to access the jobs/Job Centre - who will fund this?
The current roads are already full of pot holes - will these be fixed first and if so who will pay?
Hospitals - Basildon Hospital is already bursting and unable to cope, there are no parking spaces - with the only guarantee of a space to arrive by ambulance - who will fund for the hospital to improve and accommodate these additional people? An additional car park would also be required? Basildon Hospital has no plans for expansion - if this development was to go ahead this is jeopardising people's health and well-being - who would put on additional services to fund the additional health and mental issues which will arrive?
Dr surgeries - with the current situation for obtaining an appointment and referrals' to specialist services - who will fund the new Doctors surgery and specialist surgery provisions?
Additional Parking spaces for Basildon Town Centre will need to be developed as it is already at maximum capacity - who would pay for this?
With the amount of infrastructure which needs to be developed to even realistically comprehend this development it is unachievable and would take approx. 20 years - who would pay?
Would Basildon Council Tax increase to fund this? In a borough which already experiences huge amounts of deprivation with stretched services - how can this be considered a solution?
In regard to the travellers pitches - where are the services for the travellers - who would fund this? With the green belt land within the proposed area - who would fund someone to monitor for this for illegal set up of additional pitches? will we end up with another Crays Hill Dale farm situation? If yes who will fund for this to be addressed?
The area proposed is precious greenbelt - home to endangered species, where would they go? Who will pay for them to be rehomed? Is this proposal legal due to the area being green belt with endangered species bats, water voles, great crested newts etc

Considering this is a Brentwood proposal this will mainly effect Basildon residents... you can't just move the issue onto someone's doorstep when there are already thousands of homes being built within basildon.

With the current economic situation and vast budget cuts to Local Authorities/Borough Councils - How would this proposal be funded?
With a proposal to develop so many homes plus Travellers pitches realistically there will be more than 1 person per house/pitch. how would the infrastructure be prepared and developed to accommodate this? and who would fund this?
With major cuts to Council budgets and in turn vast redundancies of council workers - who would be supporting this? will the councils be re-employing people in a time of cuts to front line services?
How would the real issue of flooding be addressed? Building on green land at the bottom of a hill with a road that frequently floods is a real concern? Who would pay for the additional grand works and frequent repairs for homes in an area which is prone to flooding?
Who will pay for the new roads? - the Dunton road does not have pathways and is already in grave need of repair? With the identified area being so far away from any services the occupants would have no option but to drive? How would a minimum of 6,000 cars be supported to navigate the roads and commute when the A127 is already at a standstill each morning and evening?
Realistically with the distance from local amenities how would another "Jaywick" situation be prevented?
How would the additional Sewage be addressed and who would pay for this? There would be a need for a new sewage plant - who would fund?
With additional houses will local parking be addressed? Where would all there visitors park? On the Dunton road? The Dunton road does not even allow for 2 width cars to pass in normal circumstances?
How will the issue of School/nursery spaces be addressed and who will fund this?
There is already no senior school in the area - who will fund the senior school be funded?
Will a new Dunton Train Station be required? Who will fund this?
Bus services? Not everyone drives - how and who would fund for the repair of the roads, removal the bridge on Dunton road for a bus route?
How would crime be addressed - Laindon police Station is closed - who will fund for this to be reopened and staffed?
How would employment be addressed? Cars/bus routes would be required to access the jobs/Job Centre - who will fund this?
The current roads are already full of pot holes - will these be fixed first and if so who will pay?
Hospitals - Basildon Hospital is already bursting and unable to cope, there are no parking spaces - with the only guarantee of a space to arrive by ambulance - who will fund for the hospital to improve and accommodate these additional people? An additional car park would also be required? Basildon Hospital has no plans for expansion - if this development was to go ahead this is jeopardising people's health and well-being - who would put on additional services to fund the additional health and mental issues which will arrive?
Dr surgeries - with the current situation for obtaining an appointment and referrals' to specialist services - who will fund the new Doctors surgery and specialist surgery provisions?
Additional Parking spaces for Basildon Town Centre will need to be developed as it is already at maximum capacity - who would pay for this?
With the amount of infrastructure which needs to be developed to even realistically comprehend this development it is unachievable and would take approx. 20 years - who would pay?
Would Basildon Council Tax increase to fund this? In a borough which already experiences huge amounts of deprivation with stretched services - how can this be considered a solution?
In regard to the travellers pitches - where are the services for the travellers - who would fund this? With the green belt land within the proposed area - who would fund someone to monitor for this for illegal set up of additional pitches? will we end up with another Crays Hill Dale farm situation? If yes who will fund for this to be addressed?
The area proposed is precious greenbelt - home to endangered species, where would they go? Who will pay for them to be rehomed? Is this proposal legal due to the area being green belt with endangered species bats, water voles, great crested newts etc

Considering this is a Brentwood proposal this will mainly effect Basildon residents... you can't just move the issue onto someone's doorstep when there are already thousands of homes being built within basildon.

I object to these proposals because the development will greatly affect the Basildon infrastructure, much more so than it will affect the Brentwood infrastructure. The major roads in Basildon are already heavily congested, particularly at peak times, and they certainly can't cope with any more traffic, let alone the amount of traffic a development of this size will incur. As the proposed development is so close to the Basildon boundary, it is also likely to have a major impact on our hospital, GP surgeries, schools etc. These facilities are struggling to cope at the moment, so definitely wouldn't be able to manage with even more people needing to use them. As I understand it, the development will be on green belt land which, if built, would destroy lots of wildlife, flora and fauna etc. At present, this is a magnificent area of unspoilt beauty which needs to be left alone.

See attached.

In regards to Spatial Strategy: We object to the strategy to rely on a new settlement to deliver such a large proportion of growth for the Borough, particularly within the first five years from adoption. Instead we suggest greater variation in the portfolio of land available for residential development and in particular a greater number of smaller site allocations. Smaller allocations increase the flexibility that is in supply, attract smaller house building companies who will not be present upon larger strategic sites, ensure that there is variation in the timescales over which sites can be delivered and provide the consumer (i.e. the future resident) with choice about where they live. Smaller sites are more deliverable over the early years of the Plan period since they typically require less investment in infrastructure, are within single ownership and have less complex issues to address at planning application stage. This is in contrast to larger strategic sites which are often reliant on significant infrastructure improvements, comprise multiple ownerships, require complex legal agreements and typically take much longer to deliver. We support the spatial strategy, as set out at paragraph 31, to focus upon the sequential use of land, which prioritises using brownfield land and to only release Green Belt land after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations. This is in line with the NPPF (paragraphs 17 and 111). It is also in accordance with the draft policies in the new NPPF consultation proposals March 2018; Chapter 11 reinforces and strengthens this aim. However, we do not consider that the capacity of brownfield sites has been fully explored. The Site Assessment Methodology and Summary of Outcomes (January 2018) states that the approach was to prioritise using brownfield land first and then consider growth in settlements in terms of their relative sustainability linked to services and facilities. However, the process actually discounts sites where they are considered to be in an unsustainable location, which included sites in the Green Belt with no connecting boundary to an existing urban area, before considering the potential to exploit brownfield land. This has resulted in sites such as site 183 being discounted prior to any assessment of the positive benefits of the re-use of this brownfield site and whether the location is sufficiently sustainable or can be made sustainable. Specifically, in relation to this site, it is already serviced by water, sewerage and electricity so sufficient infrastructure is already available. residents of the site would have opportunities to make sustainable journeys on foot, by cycle and by car-sharing. The unnamed road outside the site frontage is classified as a Public Bridleway; accommodating pedestrians, cyclists and horse riders. This provides a pleasant walking route between the site and village of Ingrave. There are also a number of Public Footpaths in the vicinity of the site which provide access to nearby towns and villages such as Brentwood, Shenfield and Billericay which offer a wider range of local amenities. The nearest school is approximately 1.5 miles walking distance and the site is approximately 2 miles from the station at Shenfield, soon to accommodate Crossrail. Paragraph 32 of the NPPF requires that: "...the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure". On this basis, it is considered that the site is sufficiently sustainable to support a small to mid-sized residential development. In regards to Dunton Hills Garden Village: We object to this policy to propose a new settlement to deliver 2,500 dwellings during the plan period to meet a significant proportion the Borough's housing needs. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged. We consider there to be both generic and site-specific constraints to delivery. Delivery of this strategic allocation is crucial to being able to demonstrate and maintain a five-year supply in the early Plan period, meaning the Plan fails the tests of soundness as set out in paragraph 182 of the NPPF. It is considered that such a significant reliance on a single site within a Local Plan is not a sustainable approach to meet housing need and is one that has been heavily criticised by a number of Inspectors at recent Local Plan Examinations, for example nearby Uttlesford District Council. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that average planning approval period and delivery of first dwelling (i.e. from the date of the validation of the planning application) for sites of over 2,000 dwellings was just under seven years. This compares to just under just under five and a half years for sites of between 500 - 999 dwellings, just over four years for sites of 100 - 499 dwellings and just under three years for sites up to 99 dwellings. Adopting the lag of seven years and a Plan adoption date before the end of 2019 would mean there would be no deliveries on site until 2026. There are no circumstances that suggest that Dunton Hills Garden Village can deliver more quickly than the seven years recommended by the above research. As such, we object to the reliance on this site for such a large proportion of the Borough need and consider that a greater number of smaller sites should be allocated to allow for flexibility and earlier delivery. In regards to Housing Need: We object to the planned housing need on the basis that it is insufficient to meet the Borough's needs. Paragraph 47 of the NPPF requires local planning authorities to boost significantly the supply of housing. It expects evidence to be used to ensure that the Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area, as far as is consistent with the other policies set out in the NPPF. The consultation document assumes a housing need of circa 380 dwellings per annum or 7,600 dwellings across the plan period (2013-33). However, the Department for Communities and Local Government consultation on the methodology for a standardised approach to calculating local housing need in England demonstrates a housing need of 454 dwellings per annum in Brentwood Borough, an increase of 74 dwellings per year over the planned figure. Whilst it is appreciated that under the current timetable the Borough are expecting to take advantage of the transitional provisions in the draft NPPF currently open for consultation, the Plan should nevertheless take account of Governments direction of travel. A cursory 'overprovision' of only 663 dwellings does not do enough to account for the significant upward housing pressure in the Borough. Whilst the transitional provisions currently open for consultation in the draft NPPF suggest that any plans submitted this year will be examined under the old (current) NPPF, the Brentwood Local Plan is still at a relatively early stage of production. We also consider the current timetable, which allows only six months to consider representations to the current consultation and publicise and submit the Regulation 19 Plan, to be extremely ambitious. As such, the deadline to take advantage of the transitional provisions could well be missed. In this instance, the Council will have to go back to Regulation 18 stage to consider the new housing need. However, planning for the higher housing need at this stage will enable for the Plan to continue to examination, even if this deadline is missed. The "fallback position", should the Council need to accommodate this significant increase in housing need, is consideration of whether the delivery of Dunton Hills Garden Village could be accelerated to increase its dwelling yield within the plan period. However, this has not been fully explored and, as set out in our comments in relation to the Dunton Hills allocation, the current anticipated delivery is ambitious, making accelerated delivery wholly unrealistic. Failing to meet the objectively assed needs for the Borough results in the Plan falling foul of paragraphs 47 and 182 of the NPPF. It cannot be positively prepared to meet objectively assessed requirements and therefore cannot be considered sound. Notwithstanding the above objection to the quantum of the housing need, we also object to the proposed strategy to deliver this need. Figures 8 and 9 demonstrates how the housing need will be met. These show an intention to deliver 663 dwellings in excess of the identified need of 7,600 dwellings. However, this includes both a windfall allowance and "Forecast Forward - additional completions and permissions between 1st April 2017 and 31st March 2018". Both of these figures are uncertain and taken together total 757 which exceeds the 'overprovision' of 663 dwellings. The plan does not appear to include any non-implementation allowance, therefore, in order to meet the objectively assessed need every single extant consent, allocation, permitted development, plus the "forecast forward" and windfall allowance must come forward during the plan period in order to meet the minimum need requirement. As such, this policy lacks flexibility and cannot be relied upon to be deliverable or effective over the plan period and as such does not satisfy the tests of soundness, as set out in paragraph 182 of the NPPF. In regards to Settlement Heirachy: Whilst we support the classification of Ingave as a "Category 3 - Large Village", we object to the inconsistent treatment
of this settlement in comparison to other settlements occupying the same level in the hierarchy. For example, the other Large Villages of Kelvedon Hatch, Blackmore and Hook End/Tipps Cross (previously a smaller village) have been allocated development. However, neither Ingrave and Herongate (now linked), Wyatts Green nor Mountnessing, have been allocated any development. Mountnessing has already accommodated some development though existing permissions on previously developed sites, but the same is not true for Ingrave. The moratorium of growth in these villages is contrary to the NPPF states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities (paragraph 55). The new draft NPPF goes further, stating that Plans should identify opportunities for villages to grow and thrive especially where this will support local services (paragraph 80). Allocation of additional land for housing at Ingrave would not only meet local, settlement specific housing needs to address localised affordability issues but also retain the working age population in the village to ensure the viability and vitality of local shops and services.

See attached.

Thank you for allowing Persimmon Homes the opportunity to comment on

1. Brentwood Local Plan: Preferred Site Allocations Local Plan (to 2033)
2. Supporting evidence base

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the Essex and wider Eastern region. Persimmon Homes are a developer with significant experience of market and planning issues in the area, as well as being a 'user' of the Development Plan.

Persimmon Homes are a Member of the House Builders Federation (HBF), the principal representative body of the house building industry in England and Wales. Persimmon Homes, together with other Members, have inputted into the HBF's representations.

The below comprises Persimmon Homes representation to the Preferred Site Allocations Local Plan.

Duty to Co-operate & London

Despite the Emerging London Plan expectation that London will deliver 65,000 each
year from 2019-2029, there will be a need for LPAs with strong commuting and
migratory links with London, such as Brentwood, to consider how it can address
unmet housing needs arising from the capital. It is considered that further evidence is needed in regard to the exercising of the Duty to Co-operate and the extent to which Brentwood should assist London meet its needs both prior and post 2029.

Essex

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

Housing Needs

We agree with the HBF that Brentwood should look at the implications of the Governments published draft standard methodology. It is the intention of Government to introduce the standard methodology for housing needs. To advance a sound plan and one that seeks to address the Housing Crisis, the draft Plan should factor in the emerging government advice and policies. We consider it appropriate that given the significant affordability issues that the Council applies an uplift of at least 40%.

The Government's proposed standardised objectively assessed housing needs methodology indicates a need for Brentwood to deliver a capped figure of 454 dwellings per annum. It is considered that the plan should seek to address this figure. This would give rise to an extra 1,480 homes during the plan period.

Housing delivery

There is presently a distinct lack of published supporting technical studies in relation to the Dunton Hills Garden Village as proposed in the Local Plan. Furthermore, there is insufficient evidence of co-operation with and a joint vision Basildon & Thurrock Council's with regards the Garden Village, how it will be delivered having regards to the neighbouring authorities aspirations for growth in this area.

It is noted that the Council are exploring whether Dunton Hills Garden Village could increase delivery from 2500 to 2033 to c4,000. It is considered that this work should have been undertaken in advance of the consultation and the findings inform the Preferred Options.

The draft plan is heavily reliant upon sites that currently have beneficial uses,
including;
* Ford Offices 117A / 117B,
* Railway Station car park ref: 002,
* William Hunter Way car park ref 102,
* West Horndon Industrial Estate 020, 021 152.

Whilst Local Plans need to be aspirational, they also need to be realistic. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. Sites with current beneficial uses, if deliverable, are likely to be more difficult and therefore slower to deliver. They will have established use values that will influence whether they are brought forward for residential development. In addition, brownfield site are likely to be subject to additional costs in terms of relocating businesses, demolition, and remediation that may impact viability. The Council need to robustly assess its assumptions with regard the extent to which sites with current beneficial uses will be deliverable and can viably contribute towards meeting housing need, including that for affordable housing.

We are concerned that the Local Plan is too heavily reliant upon sites that may not deliver and if they do, may not assist in terms of boosting housing land supply or deliver the levels of affordable housing needed.

We hope these representations are of assistance in taking the plan forward to the
next stage of plan preparation.

See attached.