101A, C & D: there is an opportunity via these sites to retain and enhance bridleway 272_183 which runs through the site, crossing the A127. It is a well-used bridleway which has suffered continued enforcement issues over the last few years and the redevelopment of this site, along with any junction works associated with the Lower Thames Crossing, could ensure a safe route that is practical and workable for both bridleway users and business operations. We reiterate our keenness to have an input at an early stage in the redevelopment of this site so that it can be masterplanned effectively.

No reasonable access to public transport and a pure car based development. Completely contrary to NPPF is all ways.

The recently conducted Green Belt Review shows the area of Dunton Hills to be serving the purposes of the green belt. It is partricularly important as a buffer bewteen London and Basildon. It is the least developed stretch of land in this area and the purpose of the green belt to stop coalescence will be severely harmed by this development.

The A127, A128 and Lower Dunton Road are grossly inadequate in capacity for the use that will be a consequence of this development. There is no central funding for improvements and infrastructure levies from developers will not be adequate to provide sufficient funding. Furthermore, even if road improvements were funded now they could not be implemented in time to support this development. the council should instead be developing sites further North where road infrastructure is already being upgraded.

The C2C rail line has a limit to capacity determined by being only two tracks in this area, and the fact that Fenchurch Street Station cannot easily be enlarged. Other developments in South Essex further East will already take up the possible improvement in capacity on this line making it impossible for new customers of West Horndon Station to be able to use the service into London.

Surface water runnoff from roads and roofs in the new development will all be directed into the Mardyke river. This is already prone to flooding due to the fact that its height is already only 4m above mean sea level around Bulphan. It will be very hard to prevent flooding of the river when the sluice gates at Purfleet are closed at the same time as heavy rain. Any flood defence proposed by the developer will have a finite capacity and will overflow at times of persistent rain. Furthermore the cost of SUDS will use up much of the infrastructure budget from any developer levy leaving little money for road, rail, schools, health centres and affordable housing.

Essex Wildlife Trust have described Dunton Hills as an important wildlife corridor between Thorndon Country Park and Langdon Hills Country Park. It includes ancient woodlands and a Local Wildlife Site. The biodiversity will be harmed by development and no opitons for mitigation can avoid that. the council's obligations to protect wildlife habitats and biodiversity will be breached.

Brentwood Council proposes a traveler and Gypsy site of 30 pitches in Dunton Hills Garden Village. Government guidelines state that 15 ptiches is the maximum manageable size. This oversized proposal will be problematical for both new residents and the traveller community.

Brentwood Council has had no memorandum of understanding with Thurrock Council regarding this development and its MoU with Basildon was shortlived and inconclusive. This is unsatidfactiry given the impact of such a large development on the borders of these boroughs. Brentwood has therefore failed in its Duty to Cooperate.

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.

As Councillor for Warley I've repeatedly asked that, if this area is to redeveloped for business purposes, it must not contain retail units but be solely for business/light industry.
The buildings should be low-rise, modern, elegant, glass which reflects the trees on the perimeter of the site. New landscaping/planting to the south would go some way towards the original agreement with the Highways Authority that this should be re-instated as farmland after the M25 widening works were completed.
This development at the southern gateway to Brentwood should not detract from south Warley and be sympathetic to Great Warley Conservation Area.

Good road access and contained development with increase in employment and businesses.

Highways & Transportation Comment -
Impact on the A127 and B186 requires full traffic assessment. Main access for this site to be J29. The secondary bus access onto B186 Warley Street will require significant highway improvement.
Its location provides primarily car based connections to service centres, and potential sources of employees.
Consideration should also be given to other modes of sustainable transport facilities. It should be noted that the B186 is not conducive to cycling and walking. Significant upgrade of the facilities for pedestrians and cyclists is required.
There is still limited evidence regarding any potential connectivity of the proposed development via sustainable transport measures.
This location is not favourable for sustainable modes of transport to be used to access the site apart from buses which have been briefly mentioned. BBC must ensure that any development in this area has a site wide Travel Plan written and implemented.
There is major employment development planned adjacent to junction 29 of the M25, whilst the outline narrative does indicate that there is potential for bus links to be created, there is no further commitment to what this might look like and how it will be provided.

Economic Comment -
ECC is supportive of bringing forward new high quality employment areas, which can create a genuinely new offer for Essex. However ECC have significant concerns about the deliverability of the site (see earlier comments in this Appendix).
BBC could be exposed to significant risk in terms of achieving employment land targets. If this site is delayed or fails to deliver, given that the next largest new commercial allocation only accounts for 12% of the overall target.
Consideration needs to be given to both private and public transport links to the town centre and other key areas in order to ensure there is an adequate supply and access to skills/talent to support potential jobs created by the site.
Concerns that this out-of-town development is the only sizeable proposal for job creation, with little commercial space remaining in/near the town centre, what alternatives are proposed if this venture is not successfully delivered?

The consultation document proposes a large number of possible sites for the development of residential and business properties. The supporting evidence on critical strategic infrastructure is poor; indeed they are described as "interim" and leave many issues not assessed. Of these the flood risk assessment for the area of West Horndon is a key missing assessment. West Horndon is recovered fen land and as such has poor natural drainage which was made much worse when in the 1800s the railway line was constructed. Subsequent industrial and residential development has only made matters even worse. Over many years there have been a number of significant incidents with properties being seriously flooded. Following floods in the early 1980s surface water drainage was improved but the risk is still significant and during the winters of both 2012 and 2013 properties were once again flooded. The NPPF is very clear (paragraphs 94 & 100 - 103) that any development must take full account of flood risk before development is considered. Given the lack of detailed flood risk assessment it is impossible for anyone to come to a view on the use of any of the sites in the West Horndon area because they cannot understand the flood risk. Thus, I question if this consultation is valid given the public are being asked to comment on something that no one can take an informed view of because of the lack of supporting evidence. The spatial strategy identifies the A127 corridor as an appropriate location for the development of new homes and business and employment opportunities. At first sight this is a reasonable approach, however there is no supporting evidence that infrastructure in the corridor could cope with the additional load such development would create. Currently the A127 is at or over capacity much of the time as is the C2C railway line. Given that other local authorities are proposing development that would need to be supported by the transport infrastructure of the A127 corridor there is no clear evidence that it will be possible to upgrade the current road and rail systems to cope with the additional housing/business development being proposed in this consultation document. I should point out that the rail line is only two tracks and Fenchurch Street station only has 4 platforms. It is hard to conceive that a significant increase in capacity can be created as there is no physical room for more platforms at Fenchurch Street and the line west of Upminster runs through dense residential development and thus the opportunity for upgrade must be minimal. Similarly, the A127 (which is only two lanes in each direction) west of Upminster also runs through residential areas thus increasing the number of lanes to increase capacity must be questionable. While I recognise the upgrade of strategic transport infrastructure is not within the remit of BBC, developing a Local Development Plan (LDP) in the absence of information about the critical infrastructure is a nonsense. The LDP should make it clear that any proposal is totally dependent on appropriate infrastructure upgrades being planned and implemented concurrently with the proposed development. I also point out that the trains from Brentwood and Shenfield are on the new Cross-Rail line and thus the capacity is significantly improved. There are plans to upgrade much of the A12 to three lanes in each direction - so with respect to transport infrastructure corridors it is the A12 corridor that would seem most appropriate to consider for residential and business development opportunities than the A127 corridor. This site, south of the Grade 2 listed East Horndon Hall is being proposed for development as an industrial site. This land is Green Belt and thus any development is inappropriate. The NPPF clearly states that for development to take place in the Green Belt very exceptional circumstances need to be demonstrated. None are. This land is also subject to flooding - it regularly has standing surface water and acts as a storage buffer which prevents flooding of the surrounding land including residential areas. The planning application 17/01597/EIASO which first proposed this site for development as a business park includes a surface water flood assessment which only looks at a superficial level at the site itself. This is contrary to the NPPF (paragraph 102) which requires a flood risk assessment that demonstrates that any such development does not increase flood risk elsewhere. Given the history of flooding in this area (properties were flooded, and the main road blocked in December 2012) this site is clearly inappropriate for any development. These now aging industrial sites are appropriate for redevelopment and redevelopment to residential (or part residential) use is appropriate for this brown field land. In broad outline I support these sites being redeveloped. However, there are a number of concerns that must be taken into account. 1. Access - the current access arrangement date back to the late 1930s when the site was first built. The amount of traffic in those days was significantly lower than today. The current land use means that much of the traffic is large HGV lorries which are large and easy to see. Redevelopment to mixed residential and business use will increase the number of cars and light van traffic which will increase the risk of accidents. There already a large number of small shunt accidents in the vicinity of the entrance to this site. Thus, it is imperative that before any redevelopment takes place vehicle and pedestrian access is properly resolved; 2. West Horndon is a rural community and the development must be sympathetic to this. This site is quoted as being 17.06ha. Given that rural residential development should be at about 30 properties per hectare the 580 quoted seems to be very much at the top end of the appropriate number; 3. Although West Horndon is identified as a transport hub on account of the Railway Station, access is only east/west so most residents will definitely need cars. It is imperative that the design of the site is such that car parking is at a higher level than is normal for transport hub locations. West Horndon already has significant residential parking problems and this redevelopment must not make that worse. Thus, the design and number of properties must be able accommodate sufficient parking. Design is for the normal planning process, but I would suggest that for the strategic purposes of the LDP the number of properties should not exceed 500 - reduced as necessary according to how much of the site remains in business employment usage. Broadly I support the development of these sites for employment. They are situated close to the M25 as a major transport link and their use especially for enterprises which use large amounts of HGV traffic would be welcomed as that would reduce HGV traffic through residential areas like the village of West Horndon. There are potential issues about access to these sites for staff working there, there is at present no public transport access. This detail will need to be dealt with at the full planning application stage. This area is Green Belt and thus development seems inappropriate. However, I do recognise that Brentwood is ~89% greenbelt and that opportunities for non-green belt development are limited. Given the strategic housing allocation central Government is imposing on BBC this area probably needs to be considered as an option. I point out that green belt to the north of the Borough is open and that development in such areas could be undertaken to make an isolated village(s). The Dunton Hills site is almost the last green belt gap between Upminster (London) and Southend thus the development of this site would basically create continuous development between London and Southend. This would seem to be contrary to the principles set out in the NPPF. I also question the ability to construct sufficient transport infrastructure to support the development, but I can find no assessments examining this situation in appropriate detail. However, given the situation BBC finds its self in Dunton Hills Garden Village (DHGV) may be the least worst option to meet the strategic housing allocation. If this is to proceed it must be done in such a way that the impact on the surrounding area and communities is limited to a minimum. To this end the western side of the site needs to be restricted and turned into a buffer zone e.g. by creating a woodland. This would have the effect of visual separation between the two villages and would also mitigate some of the potential flood risk that the development would create. It would also make future attempts to expand the development and join the two villages much more difficult. This approach is consistent with the guidance in the NPPF for change of use of green belt land. I suggest that the site map is modified to make it clear that there must be a buffer zone between the DHGV and the A128. If this development does proceed it will generate traffic between it and the railway station in West Horndon. Parking is already a problem in the village of West Horndon and it is essential that means to minimise and manage this are sought and incorporated at the very outset of planning. The current plan suggest that the required G&T site are developed and located adjacent to new residential developments as they are constructed. My understanding from the results previous consultations is that G&T communities prefer sites to be away from business and residential areas. Indeed, one G&T site situated just north of the A127/A128 junction has to my knowledge not been used in over 30 years. I understand this is because it is too close to other developments. This aspect of the site plan allocation needs a total rethink.

The Woodland Trust appreciates the opportunity to comment on the Brentwood Draft Local Plan Preferred Site Allocations consultation.
As the UK's leading woodland conservation charity, the Trust aims to protect native woods, trees and their wildlife for the future. Through the restoration and improvement of woodland biodiversity and increased awareness and understanding of important woodland, these aims can be achieved. We own over 1,250 sites across the UK, covering around 23,000 hectares (57,000 acres) and we have 500,000 members and supporters.
Ancient woodland is defined as an irreplaceable natural resource that has remained constantly wooded since AD1600. The length at which ancient woodland takes to develop and evolve (centuries, even millennia), coupled with the vital links it creates between plants, animals and soils accentuate its irreplaceable status. The varied and unique habitats ancient woodland sites provide for many of the UK's most important and threatened fauna and flora species cannot be re-created and cannot afford to be lost. As such, the Woodland Trust aims to prevent the damage, fragmentation and loss of these finite irreplaceable sites from any form of disruptive development.
The Trust is concerned about a number of site allocations included in the Brentwood Draft Local Plan as they could lead to the damage and loss of ancient woodland.
Planning policy
National Planning Policy Framework (NPPF) paragraph 118 states that "planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss."
The draft revised National Planning Policy Framework, published on 5th March 2018, further outlines the Government's commitment to improving protection for ancient woodland through the planning system. It states that "development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland) should be refused, unless there are wholly exceptional reasons and a suitable mitigation strategy exists." This wording is a clear recognition from the Government of ancient woodland's importance and better need for protection.
Natural England's standing advice for Ancient Woodland and Veteran Trees1 states:
"Trees and woodland classed as 'ancient' or 'veteran' are irreplaceable. Ancient woodland takes hundreds of years to establish and is considered important for its wildlife, soils, recreation, cultural value, history and contribution to landscapes."
Impacts on ancient woodland
Approximately one quarter of priority UK BAP species are associated with woodland habitats. Forests, woods, and trees make a significant contribution to biodiversity, and ancient sites are recognised as being of particular value. Due to their longevity, ancient woodlands are more species rich, and are often refuges for specialist woodland species that struggle to colonise new areas.
Development in ancient woodland can lead to long-term changes in species composition, particularly ground flora and sensitive fauna, i.e. nesting birds, mammals and reptiles. Majorly adverse impacts would occur as a result of the removal of large areas of woodland, much of which contains high quality, valuable trees, to make way for the construction of this proposal.
When land use is changed to a more intensive use such as in this situation plant and animal populations are exposed to environmental impacts from outside of the woodland. In particular, the habitats will become more vulnerable to the outside influences, or edge effects, that result from the adjacent land's change of use. These detrimental edge effects can result in changes to the environmental conditions within the woodland and consequently affecting the wood's stable conditions. Detrimental edge effects have been shown to penetrate woodland causing changes in ancient woodland characteristics that extend up to three times the canopy height in from the forest edges.
Creation of new areas of woodland or buffer zones around semi-natural habitats, and more particularly ancient woodland, will help to reduce and ameliorate the impact of damaging edge effects, serving to improve their sustainability. The size of the buffer is dependent on the intensity of land use in the intervening matrix between ancient woods.
Natural England's standing advice for Ancient Woodland and Veteran Trees states:

"Development can affect ancient woodland and veteran trees, and the wildlife they support, when it takes place on the site, or nearby. You can assess the potential impacts using this assessment guide and use this to help you with planning decisions.
(https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences).
Direct impacts of development on ancient woodland or veteran trees include:
* damaging or destroying all or part of them (including their soils, ground flora, or fungi)
* damaging roots and understorey (all the vegetation under the taller trees)
* damaging or compacting soil around the tree roots
* polluting the ground around them
* changing the water table or drainage of woodland or individual trees
* damaging archaeological features or heritage assets
Nearby development can also have an indirect impact on ancient woodland or veteran trees and the species they support. These can include:
* breaking up or destroying connections between woodlands and veteran trees
* reducing the amount of seminatural habitats next to ancient woodland
* increasing the amount of pollution, including dust
* increasing disturbance to wildlife from additional traffic and visitors
* increasing light pollution
* increasing damaging activities like flytipping and the impact of domestic pets
* changing the landscape character of the area"
Development must be kept as far as possible from ancient woodland, with a buffer area maintained between the ancient woodland and any development boundary. An appropriate buffer area will depend on the local circumstances and Natural England recommend "leaving an appropriate buffer zone of semi-natural habitat between the development and the ancient woodland (depending on the size of development, a minimum buffer should be at least 15 metres)."
The size of a number of the site allocations suggests that large scale development could potentially take place. The minimum 15m buffer recommendation to all development is not effective in ensuring that ancient woodland within and/or adjacent to site allocations is not affected by potential future development. Buffers should be constructed on a case-by-case basis rather than a 'one size fits all' approach.
Conclusion
The Trust is concerned about the potentially adverse impacts that the proposed site allocations will have in relation to areas of ancient woodland within and/or adjacent to site allocations. Ancient woodland should not be included in areas that are allocated for development, whether for residential, leisure or community purposes as this leaves them open to the impacts of development.
The Woodland Trust objects to the inclusion of the below site allocations in the Brentford Draft Local Plan as they are likely to cause damage and/or loss to areas of ancient woodland within or adjacent to their boundaries. For this reason we believe the sites in the table below are unsound and should not be taken forward. We will maintain our objection until there is a commitment to either avoiding ancient woodland or providing suitable buffers to development. Secondary woodland should also be retained to ensure that ecological networks are maintained and enhanced.
We hope you find our comments to be of use to you. The Woodland Trust is happy to provide any additional information or support regarding the protection of ancient woodland. If you require any further information regarding points raised within this document, then please do not hesitate to contact us.

081 Council Depot,
The Drive,
Warley
Brentwood
CM13 3BH Brentwood Housing - 2.98 ha
Masterplan opportunities (potential for mixed use) when considered along with adjoining sites 117A and 117B. Adjacent to AW on eastern boundary Type - ARW
Name - Barrack Wood aka Harts/Kents Woods
Size - 37.711702 ha
Grid ref - TQ596917

117A & 117B Ford Offices,
Eagle Way,
Warley
Brentwood
CM13 3BW Brentwood Housing and employment - 8.09 ha
Masterplan opportunities (potential for mixed use) when considered along with adjoining sites 117A and 117B.
AW on eastern boundary. Approx. 12m buffer of woodland (non-AW). Type - ARW
Name - Harts/Kents Woods
Size - 37.711702 ha
Grid ref - TQ596917

083 Land west of Warley Hill,
Pastoral Way
Warley
CM14 5HJ Brentwood Housing - 2.21 ha AW 37m to West of site Type - ASNW
Name - Clements Wood
Size - 1.490825 ha
Grid ref - TQ588921

263 Land east of Chelmsford Road,
Shenfield Brentwood Housing - 9.85 ha
Opportunity to create a masterplan along with adjoining proposed allocations (site refs: 158, 034, 087, 235 and 276). Adjacent to AW on south eastern boundary (length approx. 292m) Type - ASNW
Name - Arnold's Wood
Size - 1.56641 ha
Grid ref - TQ621961

034, 087, 235 and 276 Officer's Meadow,
Land off Alexander Lane,
Shenfield Brentwood Housing - 24.44 ha
Opportunity to create a masterplan along with adjoining proposed allocations (site refs: 158 and 263) Contains AW on eastern side of the site. Whole of this part of Arnold's Wood included to provide contiguous site with Site ref. 263 Type - ASNW
Name - Arnold's Wood
Size - 1.56641 ha
Grid ref - TQ621961

200 Dunton Hills Garden Village Brentwood Mixed Use - New Garden Village community including housing, employment, specialist accommodation, local shops and supporting infrastructure. 257 ha Contains AW Type - ASNW
Name - None
Size - 3.084541 ha
Grid ref - TQ645894


101A Brentwood Enterprise Park (Former Brentwood Employment - 35.47 ha Adjacent to AW on Type - ASNW
Name - Hobbs Hole

1: Any development in the West Horndon area must not be on the flood plain area's ie East Horndon Hall designated employment area.
2: New industrial estate near M25 junction has only road links no public transport to site. This junction is notorious for being jammed leaving the site stranded ,god forbid emergency services being unable to get to the site.
3: To Large a percentage of the plan is south of the A127 not nearly enough near new cross rail infrastructure.
4:Dunton garden suburb can only work if it does not rely only on the A127 as this road is at full capacity now. Public transport link essential other than road.

My main comment relates to the proposed employment site the Brentwood Enterprise Park. If my interpretation of the local development plan and the plan outlining the Lower Thames Crossing proposed route are both correct the formation of the Enterprise Park would be impossible given the proposed route of the new Lower Thames Crossing takes the site. I note that Brentwood failed to respond to the recent Lower Thames Crossing consultation. I am already concerned about the lack of employment opportunities in the plan and this would affect this even further.

Secondly I express my concern on the amount of development that takes place alongside the A1023. This is already a congested route more so when there is an incident on the A12. I cannot see how all of this development can take place with the A1023 as the main access and egress. I would urge you to reconsider this level of development taking place alongside this route. The developments which would be reliant on this road:

Eagle & Child 20 units
Crescent Drive - 55 units
Land east of Chelmsford Road, Shenfield - 215 units
Officer's Meadow, land off Alexander Lane, Shenfield - 510 units
Land North of A1023 Chelmsford Road, Shenfield - 100 units

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.

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