Policy DM35: Flood Risk

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Comment

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 111

Received: 01/10/2013

Respondent: Woodland Trust

Representation Summary:

The Woodland Trust believes that trees and woodlands can deliver a major contribution to resolving a range of water management issues. They offer opportunities to make positive water use change whilst also contributing to other objectives, such as biodiversity, timber & green infrastructure - see the Woodland Trust publication Woodland actions for biodiversity and their role in water management (pdf) - http://www.woodlandtrust.org.uk/en/about-us/publications/Pages/ours.aspx.

If you wish to discuss any partnership working opportunities in this regard, please contact us.

Full text:

The Woodland Trust believes that trees and woodlands can deliver a major contribution to resolving a range of water management issues. They offer opportunities to make positive water use change whilst also contributing to other objectives, such as biodiversity, timber & green infrastructure - see the Woodland Trust publication Woodland actions for biodiversity and their role in water management (pdf) - http://www.woodlandtrust.org.uk/en/about-us/publications/Pages/ours.aspx.

If you wish to discuss any partnership working opportunities in this regard, please contact us.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 119

Received: 01/10/2013

Respondent: Mrs. Michele Ormond

Representation Summary:

West Horndon has been selected as a strategic site, however West Horndon is in a flood plain. It has flooded in 1958, 1981 and 2012. To build in the proposed sites will put our properties and potentially our lives at risk

Full text:

West Horndon has been selected as a strategic site, however West Horndon is in a flood plain. It has flooded in 1958, 1981 and 2012. To build in the proposed sites will put our properties and potentially our lives at risk

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 199

Received: 02/10/2013

Respondent: Mrs Robyn Dryden

Representation Summary:

I have known flooding to occur in the village and understand the Environment Agency show some of the village to be at risk. I would be concerned that greenfield development could worsen this risk but the draft plan does not consider this with substantiated evidence.

Full text:

1. An allocation of 1,500 new homes would make West Horndon several times larger than it is today. It is hard to see how the character and identity could be maintained and this is not detailed by the plan. The allocation is disproportionate when compared to the size of other existing developments within the borough.

2. I would have thought that such a step change in population would require infrastructure improvements. Although the draft LDP does at least acknowledge this, it is not more than an acknowledgement and has not been considered as a constraint to the village development. An Infrastructure Development Plan is referred to as outstanding or to follow.

3. Two thirds of the new homes are proposed on green built but there is no extraordinary justification for this.I commend a plan that would stop such intrusion but would expect the plan to value this over greenbelt development and accordingly prioritise the change of use over any green belt development whilst making provision for employment areas elsewhere. I live on Station Road and already suffer from vibration and noise of heavy lorries travelling to the industrial estate day and night.
4. I have known flooding to occur in the village and understand the Environment Agency show some of the village to be at risk. I would be concerned that greenfield development could worsen this risk but the draft plan does not consider this with substantiated evidence.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 204

Received: 02/10/2013

Respondent: Mr Paul Dryden

Representation Summary:

Environment Agency flood maps show much of the existing village to be at risk of flooding and there is experience of it occurring recently and historically. Whilst Site 037 is predominantly outside the area at risk of flooding, development on the site without due consideration could increase the flood risk to the existing and proposed development. This would be by reducing the amount of permeable land for rainwater to soak away and also increasing the amount of surface water run-off to be managed. The draft proposal does not address the issue of how flood risk will be affected and mitigated.

Full text:

There are elements of the Draft Local Development Plan that I support but my concerns for West Horndon as a Professional Engineer and resident are sufficiently great that I object to the Draft LDP. In general I support the change of use of Site 020 and Site 021 but emphatically object to development of Site 037. The draft LDP is not robust in justifying development on green belt land and lacks necessary supporting evidence.

My grounds for objection are thus:
O1. The total of 1,500 new dwellings proposed would approximately triple the size of West Horndon. Maintaining the character of the village would be incompatible with such a disproportionate allocation of new homes.
O2. The development of Site 037 would be on Green Belt land which is protected to prevent urban sprawl. This is in direct conflict with the Draft LDP's Strategic Objective SO7 to "Safeguard the Green Belt". In addition, the Draft LDP has not set out exceptional circumstances that justify the loss of this land. Permitting such a development may set a precedent for future development of West Horndon and surrounding areas.

O3. Environment Agency flood maps (available online) show much of the existing village to be at risk of flooding and there is experience of it occurring recently and historically. Whilst Site 037 is predominantly outside the area shown by the EA to be at flood risk, development on the site without due consideration could increase the flood risk to the existing and proposed development. This would be by reducing the amount of permeable land for rainwater to soak away and also increasing the amount of surface water run-off to be managed. The draft proposal does not address the issue of how flood risk will be affected and mitigated.
O4. Such a marked increase in housing in West Horndon would require a robust appraisal of the current infrastructure's capacity and requirements for upgrade. An Infrastructure Delivery Plan is referred to by the Draft LDP but is noted as 'forthcoming'.
O5. Whilst West Horndon has a railway station, there are presently no plans to increase the level of service for the village. Elsewhere in the borough, Shenfield and Brentwood stations are set to benefit from improved services by the Crossrail project yet they are currently assigned a lower proportion of the housing target.
O6. Whilst I am aware of the need for additional housing in the borough, this should not be at the expense of existing residential areas and where possible it should improve the quality of living to those existing areas whilst also providing a high standard for the new dwellings. There are already other areas within the borough with inappropriate land uses amongst residential areas, such as the Wates Way Industrial Estate in Brentwood and Kestrel Park in Shenfield.

My comments of support are thus:
S1. The change of use of Site 021 and Site 020 to residential would benefit the village, as the draft LDP states. The current use is in conflict with the residential areas. As a resident of Station Road I am persistently disturbed by noise and vibration as heavy goods vehicles pass by on their way to and from the industrial estates. The vibration is particularly intrusive and can be felt throughout my house as large vehicles pass during both day and night.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 495

Received: 02/10/2013

Respondent: West Horndon Parish Council

Agent: SJK Planning

Representation Summary:

7. Inadequate consideration has been given to flood risk. West Horndon has been subject to at least three serious flooding incidents since substantial development of the village took place in the mid-1950s (1958, 1981 and 2012). Each of these incidents followed very heavy rain.

Any development on the land identified 037 has significant potential to increase flood risk. This has not been properly assessed and thus its significance is unknown. Development on this land must be rejected until it can be demonstrated that any increase in flood risk is insignificant both in the area of the development and surrounding locations.

Full text:

See attached

Attachments:

Comment

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 753

Received: 22/08/2013

Respondent: Mr. Robert W. Fletcher

Representation Summary:

There have recently been problems with flooding adjacent to Norton Road and Elston Close from the water course from Fryerning Lane, which goes along the boundary of the site going under the High Street by Bellmead and emerging to the East of this site. Care must be taken to ensure any flood risk here is dealt with. I have spoken to the EA regarding the problems and restricted access to the water course by the Elston Close development and they are to look at the site.

Full text:

I visited your exhibition at Seymour Field, Ingatestone on the 9 August and took copies of documents and had a useful discussion regarding a number of points relating to Ingatestone & Fryerning. I have subsequently downloaded the documents and had another study of the plans and text. On the whole I support the plan, and believe it is good to raise these issues at a borough and parish level at regular intervals. I am particularily interested in encouraging more sustainable transport in the area and would comment on the two preferred options for development that relate to Ingatestone:

Ingatestone Garden Centre - 130 dwellings
Although this site is in Mountnessing PC area it does of course have an impact on Ingatestone centre and its facilities. On the grounds that there are constant calls for additional car parking in Ingatestone to support local shops and businesses I would expect that a further 130 dwellings would have some useful financial impact on Ingatestone, bearing in mind the need to ensure that access to doctors' etc. are looked at. Bearing in mind the location some thought should be given to improving walking and cycling access to Ingatestone Station and village centre and also to Mountnessing and beyond to the proposed Crossrail site in Alexander Lane, Shenfield, via the A12 and B1002. 130 properties would also of course have a positive financial impact on Mountnessing PC although it would be sad to lose the garden centre.

Land at Bellmead, Ingatestone - 16 dwellings
This is interestingly only the BBC land at the bottom of Bellmead and not the whole site, including the land beyond The Crown Inn, which was the subject of a past application. On this basis I envisage a development along the lines of nearby Elston Close, off High Street, which has resident's parking, both for cars and cycles. I would like to see a footway and/or cycleway link through Bellmead, from High Street, to Fairfield and the railway station and beyond. The pathway to the station is at present under improvement, as was suggested at a previous Local Plan meeting I attended a few years back. Moving the slightly hazardous current pedestrian crossing in Market Place to The Bell would mean that AES pupils could be directed in a much safer route to the station, plus the benefits to local public transport routes this would have for the residents, businesses and visitors to the village. Some thought should be given to adequate direction signs to aid visitors from the station, which was suggested by a Year 7 group of pupils from the AES Ingatestone a few years ago. I therefore cannot see any call for additional off-street parking at this site being justified as it is small and there are more pertinent improvements required to walking and cycling access. New cycle parking just off the High Street has just been installed by the Community Association (the first in the village centre itself!) and the Parish Council have been asked to look at additional sites at the Library, Bellmead and Market Place. The Crown Inn has recently been sold and I am not sure what the position is regarding the land beyond it which goes down to the water course or that at the back of the old workhouse cottages in the High Street but access to any other development would be severely restricted should this smaller site be built as proposed.

There have recently been problems with flooding adjacent to Norton Road and Elston Close from the water course from Fryerning Lane, which goes along the boundary of the site going under the High Street by Bellmead and emerging to the East of this site. Care must be taken to ensure any flood risk here is dealt with. I have spoken to the EA regarding the problems and restricted access to the water course by the Elston Close development and they are to look at the site.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 867

Received: 26/09/2013

Respondent: Environment Agency

Representation Summary:

Supportive of the inclusion of a flood risk policy, but consider amendments [as attached] are necessary to ensure the policy complies with the NPPF.

3rd paragraph of policy should be re-worded [see attached for wording]

Rewording is necessary to ensure that only Essential Infrastructure which can pass the Exception Test, and Water Compatible development, is allowed in Flood Zone 3b (functional flood plain). This change will ensure the policy is consistent with Table 3 of the Technical Guidance to the NPPF and therefore 'sound'.

This policy would also benefit from an addition to the text [see attached]

Full text:

See attached

Attachments:

Support

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 877

Received: 26/09/2013

Respondent: Anglian Water

Representation Summary:

We are particularly supportive of Policies DM35: Flood Risk, DM36: Sustainable Drainage.

Full text:

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Attachments:

Comment

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 947

Received: 01/10/2013

Respondent: Thames Water

Agent: Savills UK

Representation Summary:

Support requirement for applicants to contact sewerage providers to assess the foul sewer network capacity. However, the policy as worded would not be effective in ensuring development does not increase the risk of sewer flooding because the requirement only applies within functional flood plains.

It is suggested that item d of the policy is revised, see attached for details. Additional supporting text should also be provided in support of the policy, see attached for details.

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1034

Received: 02/10/2013

Respondent: Mr M Ashley

Representation Summary:

The Environmental Agency lists areas 020, 021 and 037 as being on flood plain as borne out by the most recent flooding incidents in 2012. The village suffers from flooding or near flooding on a regular basis in this area with no plans to remove the risk of further flooding once the development has been started it will only get worse.

Full text:

Object to:
Primarily - CP4: West Horndon Opportunity Area & Supporting Documents
plus the following in connection with impact on West Horndon;
S2: Amount & Distribution of Residential Development
CP3: Strategic Sites 020 / 021 / 037
DM11: New Development in the Green Belt
DM17: Wildlife and Nature Conservation
DM24: Affordable Housing
DM28: Gypsy and Traveller Provision
DM35: Flood Risk
Appendix 3: Housing Trajectory

Comments (please use additional sheet if required):
The Brentwood Borough Local Plan 2015-2030 and supporting documents are in sufficiently detailed with information to justify the disproportionate allocation of 43% of the borough housing requirement and 70% of Gypsy and Traveller pitches to be allocated to the village of West Horndon. These numbers will treble the current size of the village whilst decimating a large area of Green Belt. We as villagers did not receive the promised feedback from the 2011 consultation and previously discounted areas of Greenfield have now been put back into the LDP without explanation despite strong resident opposition to Green Belt development. The character of the village will be irreparably damaged by such a huge development and change our village status to a small town with none of the amenities. I am being expected to make a decision on the future of my neighbourhood with limited information which is wholly unacceptable.

The LDP fails to state how and when the local road, education, health, rail and utility infrastructure will be improved to accommodate such an aggressive development and from where the necessary funding has been secured. It would be irresponsible to proceed without detailed planning for such vital associated services. There is no further rail capacity available and the route does not provide access to our borough. The housing trajectory shows a staged construction of houses yet there is no evidence of a demand for house building in the area as potential sites have been left undeveloped in Station Road and on the Elliott's site for several years. Affordable and social housing is not ideally situated in rural areas such as West Horndon and the new development is unlikely to comprise of properties similar to the family homes that dominate the village demographic. Traffic at its peak causes congestion along Station road when trying to exit onto the already dangerous and packed A128. (numerous accidents have occurred at this junction before and after highways made changes and adding further traffic will raise the risks further )
The LDP gives no consideration to the wider implications from other developments in the vicinity, such as the DP World port and proposed A2 Thames crossing, both of which will dramatically increase traffic in the area and place further burdens on the Borough's infrastructure without the additional traffic from the proposed West Horndon development. There are only two routes into Brentwood from West Horndon (A128 / Warley) and access to the area will be gridlocked.
Green Belt development is designed to halt the sprawl of London and should only be in exceptional cases. In the evidence documents on the BBC website the projected population increase for Brentwood is primarily migratory. I see absolutely no reason why the Green Belt should be threatened by movement of people which, by its very nature, can settle on non green belt locations. The wildlife in the area will be adversely affected by the proposed development on Green Belt and I must question whether investigation has been made into protected species which inhabit the area such as Great Crested Newts as there is no mention in the LDP.
The Environmental Agency lists areas 020, 021 and 037 as being on flood plain as borne out by the most recent flooding incidents in 2012. The village suffers from flooding or near flooding on a regular basis in this area with no plans to remove the risk of further flooding once the development has been started it will only get worse. There is no evidence that this factor has been considered in the LDP and to site traveller and gypsy pitches on a flood plain is unacceptable.
I do not believe that the LDP is sound or robust enough to be considered in its present form and appears to be a rash decision to fulfil government targets. I acknowledge that progress must be made and that some development may be necessary and this should be made in smaller numbers to keep the village in its status. However, much more investigation needs to be undertaken by the council and the views of the community considered in depth before any decisions are made that will affect us in the long term.

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1508

Received: 01/10/2013

Respondent: John Grahame

Representation Summary:

In Core Policies CP2c it states that development should not take place on green belt land that is used for food product or at risk of flooding. The green belt land that is north of the factory estate has all of these so I cannot see why it has been chosen for housing. West Horndon has been flooded a number of times in the past and building on this land can only increase the possibility of flooding in the future. Any flood relief scheme would increase the possibility of flooding south of the railway towards Bulphan.

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1522

Received: 01/10/2013

Respondent: J.W.E Grahame

Representation Summary:

In Core Policies CP2c it states that development should not take place on green belt land that is used for food product or at risk of flooding. The green belt land that is north of the factory estate has all of these so I cannot see why it has been chosen for housing. West Horndon has been flooded a number of times in the past and building on this land can only increase the possibility of flooding in the future. Any flood relief scheme would increase the possibility of flooding south of the railway towards Bulphan.

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1531

Received: 01/10/2013

Respondent: Claire Hendle

Representation Summary:

In Core Policies CP2c it states that development should not take place on green belt land that is used for food product or at risk of flooding. The green belt land that is north of the factory estate has all of these so I cannot see why it has been chosen for housing. West Horndon has been flooded a number of times in the past and building on this land can only increase the possibility of flooding in the future. Any flood relief scheme would increase the possibility of flooding south of the railway towards Bulphan.

Full text:

See attached

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1537

Received: 01/10/2013

Respondent: D. Lessons

Representation Summary:

DM32 states that "It is widely acknowledged that green infrastructure and open space has a major role to play in mitigating against and adapting to climate change....Through the provision of green corridors the policy can help overcome habitat fragmentation and improve the ability of the natural. This paragraph would seem to suggest that, particularly in a flood plain, a "green corridor" would help to alleviate flooding. This argument is contrary to the BBC Local Plan proposal to take away some of that "green corridor" in West Horndon, which currently alleviates flooding in the village.

Full text:

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Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1567

Received: 01/10/2013

Respondent: Mr. David Gale

Representation Summary:

DM35, paragraph 4.160 states that "Areas at risk of fluvial flooding in the Borough are mainly rural, and include low lying areas south of the A127 west and east of West Horndon". This contradicts what BBC has said in paragraph (c) of CP2 ("... areas where development should not take place . . . risk of flooding).

Full text:

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Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 1991

Received: 02/10/2013

Respondent: Mr. Roland Tipler

Representation Summary:

The whole area is on a 'Flood Plain' and the extra houses would make the area more liable to flooding. We have had (2) floods in the village 1958 and 1982.

Full text:

The Doctor here is located in a converted 3 bed house which would not cope. The existing Doctors do not have more than 33 hours of surgery time which is insufficient now.

The whole area is on a 'Flood Plain' and the extra houses would make the area more liable to flooding. We have had (2) floods in the village 1958 and 1982.

Attachments:

Object

Local Plan 2015-2030 Preferred Options for Consultation

Representation ID: 3407

Received: 01/10/2013

Respondent: Mrs Sally Lyon

Representation Summary:

West Horndon, according to the Environment Agency website is shown to be at risk of flooding and indeed as recently as 2012 there was flooding in the village. Has the Council carried out any assessment of the flood risk?

Full text:

1. My primary objection is use of green belt land which I feel is inappropriate, given the limited amount of open spaces around the village. I moved to West Horndon because of the feel of open spaces, having lived in very built up areas before. I also understand that it is Government policy that exceptional circumstances must exist to justify the loss of green belt land and I believe they recently expanded on this by saying that demand for housing is unlikely to be good reason enough to use green belt land.

2. I do not feel that West Horndon can cope with an influx of such a huge amount of dwellings. There is already considerable traffic going through the village both during the day and in the evenings. Our doctor's surgery is an off-shoot of the surgery in South Ockenden and as such has very limited opening hours - eg it is now closed on Tuesday afternoons to allow the doctors to spend more time at Ockenden. It is hard enough as it is to get an appointment - and I cannot see how it would cope with extra people living in the village. We are not very well served by public transport in the village. There is an infrequent bus service which does not run on a Sunday and you really need a car here, thus adding to the amount of traffic. The railway station only serves routes to London or to Southend etc, and does not cover getting around the Borough, eg to Brentwood.

3. Reverting back to my point about traffic in the village, the surrounding roads would be hard pressed to cope with additional cars. The A127 is always very busy, particularly during peak hours, with frequent traffic queues and hold-ups and with additional cars, this will impact also onto the A128.

4. West Horndon, according to the Environment Agency website is shown to be at risk of flooding and indeed as recently as 2012 there was flooding in the village. Has the Council carried out any assessment of the flood risk?

5. The scale of the proposed development by almost trebling the size of the village would have the effect of creating a new area which could no longer be classed as a village. I do not feel the Council has properly explained why West Horndon should accept such a large amount of new dwellings and why the Council deem it a suitable site for such a large development. From what I have read and heard, the Council haven't assessed whether West Horndon has the necessary infrastructure for such an increase in its size, eg utilities, telecoms (we have the slowest broadband here), waste etc etc.

6. There is also no clear indication in the outline proposals of where the travellers sites will be and this is also a concern.