Ideal area for growth and development near an existing small hamlet.

The Council is broadly supportive of the proposed housing allocations within the draft Plan but suggests that Brentwood Borough Council should satisfy itself and the Inspector that the cumulative impacts of planned and unplanned growth on local and strategic infrastructure can and will be mitigated, both within Brentwood Borough and across South Essex as a whole. In particular, the extent and location of growth proposed should not place undue pressure on the strategic highway network, including the A127, unless adequate mitigation or improvements can be secured. Brentwood Borough Council must ultimately demonstrate that the level of growth planned is both deliverable and sustainable

f. provision for new multi-functional green infrastructure, including public open space, "to deliver a measurable net gain in biodiversity"

The policy should include a clear statement on delivering a measurable net gain in biodiversity.

Amend Policy R02 B. e. as follows -

provide well-connected internal road layouts which allow for good accessibility including for passenger transport;

3. Effective
4. Consistent with National Policy.

ECC welcome that BBC has recognised the importance of ensuring that this site allocation should provide well-connected road layouts which allow for good accessibility. However, such a size of development should also be seeking to ensure that such layouts can accommodate passenger transport. This would be consistent with other policies contained within the Local plan including Policy BE14, and in line with paragraph 102 of the NPPF.

Criterion B. e. of Policy R02 should therefore include reference to passenger transport.

GIven that this is an (underutilised) brownfield site, this seems like a sensible development, provided that it is of a suitably high density to reflect its proximity to West Horndon railway station. Also, it is vital that the displacement of the employment/industrial use is NOT utilised to justify inappropriate development elsehwere.

I urge Brentwood Borough Council to rethink its current proposals and to come up with a revised plan that spreads the housing needs more fairly and equally across the Borough so that no one community is impacted so severely as in the current Plan.

The proposed development within the Plan is highly concentrated within the A127 Corridor. This scale and concentration proposed will irrevocably harm the landscape, environment and Green Belt within this area (at a disproportionate level than the wider Borough).
Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor. Thurrock Council in particular is considering a site for 10,000 + homes on land adjacent to West Horndon village, which would in effect turn the village into a large town. The Plan does not take account of this. The Plan states that the area would remain surrounded by countryside but this would not be the case.
In my opinion a sustainable level of development within the A127 Corridor is limited to the development proposed at site RO2 (the West Horndon Industrial Estates). Even at this level however it would require a significant amount of infrastructure expenditure to ensure it is sustainable.

My family and I enjoy village life and want our village to remain a village however, appropriate development here (at the appropriate density and style to complement the existing village) to this maximum would improve the lives of West Horndon residents. It would still however double the size of our village, which in my opinion is the maximum that West Horndon could sustain and should be asked to contribute.

Throughout the development of the Plan, potentially viable alternative sites have been ignored. I believe the initial rejection of further growth in the A12 Corridor, or any material development in the North of the Borough, is not founded on sound analysis or hard evidence.

Given the scale of development proposed, the original "problems" identified including the need for new infrastructure are relevant wherever the development is sited. Greater diversification of the identified housing need will assist in improving deliverability, feasibility and the impact on local transport networks. In particular no account seems to have been taken of the A12 upgrade or Crossrail.

The C2C rail line only has two tracks, whereas Shenfield has four and the trains are already well above capacity at peak times. The roads around the village (A127, A128) are characterised by standstills and queues in both the morning and evening peaks.

An additional 500 cars (assuming just 1 per property) would have a very material impact on already severely strained and congested roads. It is therefore just not feasible for these roads to cope with the proposed development at Dunton Hills Garden Village and the proposed development by other councils, even with investment. It is also impossible to see how the train capacity could be upgraded sufficiently.

I also strongly challenge that the land around West Horndon village is suitable for development because of the flood risk, which is already a problem in the village and would create significant issues when considering larger scale development around the village.

For all of the above reasons I urge Brentwood Borough Council to rethink its current proposals and to come up with a revised plan that spreads the housing needs more fairly and equally across the Borough so that no one community is impacted so severely as in the current Plan.

I urge Brentwood Borough Council to rethink its current proposals and to come up with a revised plan that spreads the housing needs more fairly and equally across the Borough so that no one community is impacted so severely as in the current Plan.

The proposed development within the Plan is highly concentrated within the A127 Corridor. This scale and concentration proposed will irrevocably harm the landscape, environment and Green Belt within this area (at a disproportionate level than the wider Borough).
Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor. Thurrock Council in particular is considering a site for 10,000 + homes on land adjacent to West Horndon village, which would in effect turn the village into a large town. The Plan does not take account of this. The Plan states that the area would remain surrounded by countryside but this would not be the case.
In my opinion a sustainable level of development within the A127 Corridor is limited to the development proposed at site RO2 (the West Horndon Industrial Estates). Even at this level however it would require a significant amount of infrastructure expenditure to ensure it is sustainable.

My family and I enjoy village life and want our village to remain a village however, appropriate development here (at the appropriate density and style to complement the existing village) to this maximum would improve the lives of West Horndon residents. It would still however double the size of our village, which in my opinion is the maximum that West Horndon could sustain and should be asked to contribute.

Throughout the development of the Plan, potentially viable alternative sites have been ignored. I believe the initial rejection of further growth in the A12 Corridor, or any material development in the North of the Borough, is not founded on sound analysis or hard evidence.

Given the scale of development proposed, the original "problems" identified including the need for new infrastructure are relevant wherever the development is sited. Greater diversification of the identified housing need will assist in improving deliverability, feasibility and the impact on local transport networks. In particular no account seems to have been taken of the A12 upgrade or Crossrail.

The C2C rail line only has two tracks, whereas Shenfield has four and the trains are already well above capacity at peak times. The roads around the village (A127, A128) are characterised by standstills and queues in both the morning and evening peaks.

An additional 500 cars (assuming just 1 per property) would have a very material impact on already severely strained and congested roads. It is therefore just not feasible for these roads to cope with the proposed development at Dunton Hills Garden Village and the proposed development by other councils, even with investment. It is also impossible to see how the train capacity could be upgraded sufficiently.

I also strongly challenge that the land around West Horndon village is suitable for development because of the flood risk, which is already a problem in the village and would create significant issues when considering larger scale development around the village.

For all of the above reasons I urge Brentwood Borough Council to rethink its current proposals and to come up with a revised plan that spreads the housing needs more fairly and equally across the Borough so that no one community is impacted so severely as in the current Plan.

I urge Brentwood Borough Council to rethink its current proposals and to come up with a revised plan that spreads the housing needs more fairly and equally across the Borough so that no one community is impacted so severely as in the current Plan.

The proposed development within the Plan is highly concentrated within the A127 Corridor. This scale and concentration proposed will irrevocably harm the landscape, environment and Green Belt within this area (at a disproportionate level than the wider Borough).
Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor. Thurrock Council in particular is considering a site for 10,000 + homes on land adjacent to West Horndon village, which would in effect turn the village into a large town. The Plan does not take account of this. The Plan states that the area would remain surrounded by countryside but this would not be the case.
In my opinion a sustainable level of development within the A127 Corridor is limited to the development proposed at site RO2 (the West Horndon Industrial Estates). Even at this level however it would require a significant amount of infrastructure expenditure to ensure it is sustainable.

My family and I enjoy village life and want our village to remain a village however, appropriate development here (at the appropriate density and style to complement the existing village) to this maximum would improve the lives of West Horndon residents. It would still however double the size of our village, which in my opinion is the maximum that West Horndon could sustain and should be asked to contribute.

Throughout the development of the Plan, potentially viable alternative sites have been ignored. I believe the initial rejection of further growth in the A12 Corridor, or any material development in the North of the Borough, is not founded on sound analysis or hard evidence.

Given the scale of development proposed, the original "problems" identified including the need for new infrastructure are relevant wherever the development is sited. Greater diversification of the identified housing need will assist in improving deliverability, feasibility and the impact on local transport networks. In particular no account seems to have been taken of the A12 upgrade or Crossrail.

The C2C rail line only has two tracks, whereas Shenfield has four and the trains are already well above capacity at peak times. The roads around the village (A127, A128) are characterised by standstills and queues in both the morning and evening peaks.

An additional 500 cars (assuming just 1 per property) would have a very material impact on already severely strained and congested roads. It is therefore just not feasible for these roads to cope with the proposed development at Dunton Hills Garden Village and the proposed development by other councils, even with investment. It is also impossible to see how the train capacity could be upgraded sufficiently.

I also strongly challenge that the land around West Horndon village is suitable for development because of the flood risk, which is already a problem in the village and would create significant issues when considering larger scale development around the village.

For all of the above reasons I urge Brentwood Borough Council to rethink its current proposals and to come up with a revised plan that spreads the housing needs more fairly and equally across the Borough so that no one community is impacted so severely as in the current Plan.

I urge Brentwood Borough Council to rethink its current proposals and to come up with a revised plan that spreads the housing needs more fairly and equally across the Borough so that no one community is impacted so severely as in the current Plan.

The proposed development within the Plan is highly concentrated within the A127 Corridor. This scale and concentration proposed will irrevocably harm the landscape, environment and Green Belt within this area (at a disproportionate level than the wider Borough).
Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor. Thurrock Council in particular is considering a site for 10,000 + homes on land adjacent to West Horndon village, which would in effect turn the village into a large town. The Plan does not take account of this. The Plan states that the area would remain surrounded by countryside but this would not be the case.
In my opinion a sustainable level of development within the A127 Corridor is limited to the development proposed at site RO2 (the West Horndon Industrial Estates). Even at this level however it would require a significant amount of infrastructure expenditure to ensure it is sustainable.

My family and I enjoy village life and want our village to remain a village however, appropriate development here (at the appropriate density and style to complement the existing village) to this maximum would improve the lives of West Horndon residents. It would still however double the size of our village, which in my opinion is the maximum that West Horndon could sustain and should be asked to contribute.

Throughout the development of the Plan, potentially viable alternative sites have been ignored. I believe the initial rejection of further growth in the A12 Corridor, or any material development in the North of the Borough, is not founded on sound analysis or hard evidence.

Given the scale of development proposed, the original "problems" identified including the need for new infrastructure are relevant wherever the development is sited. Greater diversification of the identified housing need will assist in improving deliverability, feasibility and the impact on local transport networks. In particular no account seems to have been taken of the A12 upgrade or Crossrail.

The C2C rail line only has two tracks, whereas Shenfield has four and the trains are already well above capacity at peak times. The roads around the village (A127, A128) are characterised by standstills and queues in both the morning and evening peaks.

An additional 500 cars (assuming just 1 per property) would have a very material impact on already severely strained and congested roads. It is therefore just not feasible for these roads to cope with the proposed development at Dunton Hills Garden Village and the proposed development by other councils, even with investment. It is also impossible to see how the train capacity could be upgraded sufficiently.

I also strongly challenge that the land around West Horndon village is suitable for development because of the flood risk, which is already a problem in the village and would create significant issues when considering larger scale development around the village.

For all of the above reasons I urge Brentwood Borough Council to rethink its current proposals and to come up with a revised plan that spreads the housing needs more fairly and equally across the Borough so that no one community is impacted so severely as in the current Plan.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

Dear Sir/Madam,

I write to provide my opinion on the recently updated Local Development Plan which has been published.

I am a resident of West Horndon which is part of the major redevelopment you would like to carry out in the South of the Borough. As I mentioned in my previous response in August 2013 there is no sign of any joined up thinking or obvious forethought in your redevelopment proposals. The plan to initiate Dunton Garden Village as the major residential housing problem solution is obviously a poorly thought out attempt to shove the problem as far away from Brentwood as possible. As you must surely be aware the A128 and A127 are already extremely congested and at the limit of sustainability. There are no plans to improve the A128 despite advanced plans for a second Thames Crossing which can only worsen the situation. Placing a small town of 500 plus houses directly on these roads is a disastrous idea, especially with all the road improvements taking place on the A12 corridor. Where is the joined up thinking in our Borough Council Planning Department? The same again with railway connectivity. The West Horndon to Fenchurch Street line is already at capacity with no scheduled improvements planned in the near future. However, at Shenfield there will be the Elizabeth Line connection and major developments planned but obviously only for the elite selected few. The big housing area is at the wrong side of Brentwood obviously!! There is an obvious error here isn't there? To put all this housing stock so far away and joined to this major transport hub by the already congested A128 road is frankly very poor planning. The improved transport will only benefit Shenfield and local areas nearby.

Bus transport in West Horndon is already poor service and the village children now have to be funded by parents to get to school... This is a very poor state of affairs which will be made worse by the 300 extra houses planned for this village. To live in West Horndon you must have a car but the already badly congested A127 and A128 make travel anywhere difficult and the Dunton Village proposal will make this situation far worse. This is an appalling transport strategy.

As you should be very aware West Horndon and Dunton are adjacent to Basildon and Thurrock Boroughs. Both Boroughs are also considering the Dunton area for their own housing expansion needs so Dunton Village could end up as Dunton Town. Both councils have stated that there has been very limited consultation about perceived infrastructure or transport planning and do not seem to be very much in favour of Brentwood Borough future local development proposals. This is at odds with the statement in your LDP about local joint consultations with neighbouring boroughs. Again, this is symptomatic of a lack of joined up thinking in the planning process.

No surveys or work have been carried out prior to the issue of the LDP with reference to the flooding. West Horndon and Dunton are in a geographical dip between higher ground in all directions. In the past we have experienced several floods including my own property. It is not sensible to put all this additional housing in flood prone areas and to consider doing this without even basic land surveys is poor practise to say the very least.

In your proposal you mention people altering the gardens to accommodate off-road parking is hazardous because of rainwater re-direction but you have no future plans to even begin investigation into building a substantial number of houses on a flood plain risk area! Again poor planning.

In previous neighbourhood consultations Brentwood residents have stated their priorities which were:-
a) protection of the green belt
b) protection of local character
c) Re-use of existing buildings in Brentwood Town Hutton and Pilgrims Hatch

It seems that the residents views only matter if they comply with the councils wishes but can be ignored if they do not.

The Local Development plan rides rough-shod over residents views as you plan to build a small town in the GreenBelt, because it is far away from Brentwood Town and is much easier than re-using brownfield sites throughout the borough which residents want done and specifically requested their feedback to the council. This plan will also change the local character as it will put a small town in Dunton and change West Horndon from a small village into a small town used as a stopping off point for the Dunton Town residents. This is a major hypocrisy to the espoused Borough statement of a Borough of Villages. Obviously this does not apply South of Brentwood Town.

The Green Belt around West Horndon and Dunton is meant to prevent the urban sprawl of London creeping along the A127 and A13 corridors. This is the most important part of the green belt in the whole country due to the extreme pressure on housing needs in the South East of England. To state that the Green Belt area around the A12/Shenfield area is somehow more important or of greater character is risible and frankly insults the intelligence. The A12 improvements have already affected that part of the Green Belt whereas the area around West Horndon is so far unaffected but will be completely ripped apart by this local plan. This was the major point mentioned in residents feedback to the Council and should be the number one priority. It is the councils job as elected officials to carry out the wishes of residents not to completely ignore them when it does not fit into the Councils plans. Infringement of the Green Belt should be the very last option not the easy get out!

What happened to the original spatial Option One for centralised growth in and around Brentwood Town Centre with re-use of Brownfield sites and expansion of the Town?

What happened to spatial Option Two for a transport corridor led growth along the A12 and A128 area of the Borough?

Were they just planning pie in the sky and a bit too difficult to carry out with a much easier option being to move the problem somewhere else a bit farther away?

This Local Development Plan represents a poorly thought out strategy reflecting a lack of joined up thinking. It bears no consideration of residents wishes but shows a desire to move the problems elsewhere. There is a distinct lack of consideration for the ideals of Village Life.

There has been little consideration given to the effects on neighbouring Boroughs or residents of areas affected by the poorly thought out proposals.

Over the whole consultation period scant regard has been paid to residents feedback because it does not fit in with the Council Planning Departments way of thinking.

All in all a very poor plan which we, the Borough residents do not want.

Regards

Typed by Joanne Craske
Dictated by Kevin Craske.

1.0 Introduction
1.0.1 Thank you for consulting the Basildon & Brentwood Clinical Commissioning Group (CCG) and the Mid and South Essex Sustainability and Transformation Partnership (STP) on the above emerging Local Development Plan (LP) Document.
1.1 In reviewing the context, content and recommendations of the LP Document and its current phase of progression, the following comments are with regard to the Healthcare provision on behalf of the STP
2.0 Existing Healthcare Position in the Emerging Plan Area
2.1 The LP Document covers the administrative area of Brentwood.
2.2 Currently, within the administrative area, healthcare provision incorporates a total of 9 GP Practices, 13 pharmacists, 9 dental surgeries, 10 Opticians, 2 community clinics and 2 community hospitals.
2.3 These are the healthcare services available that this Local Plan must take into account in formulating future strategies.

1.0 Introduction
1. These representations have been prepared by Navigus Planning on behalf of West Horndon Parish Council ('the Parish Council') in respect of the Brentwood Borough Council (BBC) Local Plan Regulation 19 Consultation ('the Reg 19 Plan').
2. The principal matter that these representations address is the allocation of Dunton Hills Garden Village (Policy RO1) and specifically the soundness of that allocation, as required by paragraph 35 of the National Planning Policy Framework (NPPF). In particular, the Parish Council is of the opinion that the Reg 19 Plan has not been justified because it hasn't been based on appropriate and proportionate evidence and is not consistent with national policy.
3. It is important to make clear that the Parish Council supports the allocation of the land at West Horndon Industrial Estate (Policy RO2) for residential, care home and appropriate employment uses.
2.0 Previous representations
4. The Parish Council's representations dated 22nd March 2016 to the Draft Local Plan raised a number of issues. It is the opinion of the Parish Council that the points made have not been addressed; indeed very little has changed in the Reg 19 Plan in light of representations made by any parties. The Parish Council wishes therefore to make clear that the representations it made on the Draft Local Plan are still outstanding and still represent matters that require addressing for the Reg 19 Plan to be considered to be sound.
3.0 Transport strategy
5. The spatial strategy in the Reg 19 Plan focuses on three main driving forces, one of which is 'Transit-oriented Growth'. Paragraph 3.11 notes that one of its 'connectivity axes' is the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station. It states that:
"Focusing growth along these axes will ensure that future development is sustainable, maximising the benefits of transport infrastructure. While some investment to improve the transport network will be inevitable, this growth strategy ensures economies of scale are reached, with the critical mass of development making it more viable for such investment to occur."
6. Whilst it is questionable as to whether growth along a road corridor can ever constitute sustainable development given the detrimental effects of increased car use on climate change and air pollution, the stated principle is supported. However, the Parish Council has concerns that the spatial strategy which is then presented fails to adequately justify or demonstrate what improvements are going to be needed to the transport network and whether the costs - which have not been properly scoped out - can be addressed by investment which can reasonably be expected to come from development and other sources. In this regard, it is important to be clear that Brentwood borough is not the only local authority area along the A127 Corridor. Basildon, Thurrock, Castle Point, Rochford and Southend-on-Sea are also planning for growth and will also be relying on the A127 Corridor to support increased movement by all modes. Yet the Reg 19 Plan fails to properly consider this.
3.1 Road infrastructure
7. In answering the question 'What key issues should be considered in developing the transport evidence base to support the Local Plan?', national Planning Practice Guidance states that one such key issue is the need to, "consider the cumulative impacts of existing and proposed development on transport networks" (Paragraph: 003 Reference ID: 54-003-20141010).
8. The Transport Assessment which accompanies the Reg 19 Plan is the key piece of transport evidence used to demonstrate that the spatial strategy and growth proposed in the Plan can be supported by the strategic and local highway network. It includes a Reference Case Model which, as is stated in the Executive Summary, "...includes trips developments within neighbouring authorities, as well as additional background trips associated with population growth predictions for future years." Therefore, as far as the A127 Corridor is concerned, the Reference Case only considers the wider impact of growth in Basildon and Thurrock districts but excludes growth in Castle Point, Rochford or Southend-on-Sea. In considering what baseline information should inform a transport assessment, national Planning Practice Guidance states:
"The transport assessment should be produced at a Local Plan level in partnership with all relevant transport and planning authorities, transport providers and key stakeholders, for example, the Local Economic Partnership. It may be appropriate for the transport assessment to cover an area wider than the Local Plan at least initially given the size of some travel to work areas (this would be similar to the Strategic Housing Market Assessment). This process should help to identify any potential measures that may be required to mitigate negative impacts." (Paragraph: 005 Reference ID: 54-005-20141010)
9. In this regard, the Brentwood Transport Assessment fails to fully take into account the impacts of traffic coming from the eastern parts of the Corridor. The impact of this omission is demonstrated by other work which has assessed the wider impacts. Indeed, the Transport Assessment states that it takes account of the A127 Economic Plan , published in 2014. It states that paragraph 1.2.5 that:
"Where information is available, this has been used to inform the modelling. The final outcomes from the study are not yet known and continued joint working with ECC [Essex County Council] and other neighbouring authorities will be important, so any outcomes from this study can feed through to the corridor study and consideration given to demonstrate this within a Statement of Common Ground with the highway authorities and neighbouring authorities."
Map 1: Summary of transport impacts of 2014 Economic Plan modelling along A127 Corridor
[Please find the map in attached document]
10. Whilst the Brentwood Transport Assessment focuses on specific junctions and the requirements of growth in the Local Plan and neighbouring districts, the 2014 Economic Plan assesses flows along sections of the A127 from Southend to the M25. In this regard it is more explicitly considering the number of vehicles on the A127 during peak periods and how this affects the flow of traffic. Figure 1 in the Economic Plan (shown in Map 1 above) notes that, almost along its entirety, the A127 is close to or above capacity. Figure 2 (also shown in Map 1) notes that, with the planned growth which informed the modelling, it would be above capacity for almost its entire length. Moreover, the entire stretch from Rayleigh through to the M25 would be between 28% and 50% above capacity. It is clear that, as assessed in the 2014 Economic Plan, significant mitigation would be required along the A127 to address the levels of growth fed into the modelling.
11. Since this time, the levels of growth being planned for, or required to be planned for, in the A127 Corridor authorities, has increased substantially from those used to inform the 2014 Economic Plan. Table 1 shows that, based on emerging local plans or objectively assessed need figures, the growth levels being planned for have increased by 88% compared with the 2014 position:
Table 1: Comparison of growth used to inform 2014 transport modelling and current levels of growth being planned for
[Please find table 1 in attached document]
12. If the 2014 Forecast Congestion Reference showed that the A127 would be significantly above capacity, then the near doubling of growth is likely to result in a significant worsening of this position. The outputs of the Brentwood Transport Assessment, whilst acknowledging the importance of the A127 Economic Plan work which it notes is still ongoing, fail to take into account this evidence.
13. It should be noted that this analysis does not take into account the impacts of either the Lower Thames Crossing or proposed employment growth over the plan period.
14. It is the view of the Parish Council that the Transport Assessment is not sufficiently robust to take into account the cumulative impacts of planned growth on the A127, as required by National Planning Practice Guidance.
15. When looking in isolation at the results of the Transport Assessment in respect of the potential solution to mitigate congestion at the A127/A128 Brentwood Road/A128 Tilbury Road junction serving Dunton Hills Garden Village (DHGV) and East Horndon Hall allocation, it is noted that paragraph 9.4.8 summarises the results as follows:
"During the PM peak, however, the arm shows a degree of saturation of 95%, although this is over capacity, the operation of this junction has improved significantly."
16. Whilst it is not disputed that the identified mitigation will improve the position, the fact is that the junction will still be over-capacity. When it is borne in mind that the wider impacts of growth along the A127 Corridor have not been taken into account, then the degree to which it will be over-capacity is certain to increase. A strategy predicated on growth which, despite a focus on sustainable transport, results in road junctions being over capacity, is not sustainable.
17. The Transport Assessment identifies a total of 8 junctions that require significant mitigation across the borough. The Brentwood Infrastructure Delivery Plan (IDP) schedule gives a 'headline estimate' of £4m to address local highway network improvements. The Parish Council considers it extremely unlikely that it will cost an average of just £0.5m per junction to put in place the necessary mitigation measures at these junctions. Moreover, as is noted in paragraph 10.5.3 of the Transport Assessment, "Requirements for each of the proposals was identified and any physical constraints identified, no investigation to land ownership or costs involving the moving of Statutory Undertakers and Utility Apparatus was undertaken."
18. As Map 1 showed, the forecast delays on the A127 are significant and our analysis shows that these have been informed by growth figures well below those that are being planned for. It is not only mitigation at junctions which is required but solutions to expand capacity on the A127 itself. The degree to which individual junction improvements will mitigate the impact of the overall volume of traffic on the A127 at peak period is likely to be limited. At page 11 of the A127 Corridor for Growth Study states that, "The number of side-roads and accesses along the A127 tend to restrict any benefit from traditional capacity improvement measures, such as additional lanes." Therefore it is not considered likely that such solutions will be possible.
19. The need to address the significant strategic impacts of growth along the A127 has been recognised through the establishment of an A127 Economic Growth Corridor Task Force in November 2018. As is noted in its launch presentation, options for consideration include re-trunking of the road and the Group has had "positive discussions with Highways England and the Department for Transport" on this. If successful, this would open up opportunities for funding through the Roads Investment Strategy (RIS). This highlights a key point, namely that the current A127 does not qualify for RIS funding. Once the true cost of mitigation of the junctions along the A127 to address Local Plan growth has fully taken into account the cost of land acquisition and utilities, the bill is likely to be much higher than the 'headline' £4m and will require funding from other sources. In this regard, the decision over whether the A127 is re-trunked becomes critical to the delivery of the growth strategy, not only for the Brentwood Reg 19 Plan but for the emerging local plans of the other authorities along the route. At this stage, no progress has been made in this regard therefore this cannot be part of the evidence base which justifies the deliverability of the proposals in the Reg 19 Plan along the A127 Corridor.
20. Paragraph 108 of the NPPF states that:
"In assessing sites that may be allocated for development in plans...it should be ensured that... any significant impacts from the development on...highway safety, can be cost effectively mitigated to an acceptable degree."
21. The Transport Assessment only makes a single mention of highway safety, at paragraph 1.2.5, referring to the A127 Corridor for Growth Study by stating that:
"... there are individual pieces of work which are currently at various stages of planning and development, which are focussed on interchange capacity and/or safety improvements. Where information is available, this has been used to inform the modelling."
22. Page 11 of the A127 Study states that:
"The collisions caused by being an over-capacity road are not simple to address...The junctions identified as being problematic are the A128 Halfway House, B148 Dunton, A132 Nevendon and the A176 Upper Mayne junctions".
23. These are the junctions that are critical to the delivery of the DHGV and East Horndon Hall allocation (which, as an employment allocation, will create significant levels of HGV traffic accessing the junction) yet the evidence base to consider not only capacity but highway safety has not been adequately completed or aligned.
3.2 Sustainable transport movement
24. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on rail, and to a lesser extent, bus cycling and walking infrastructure, to reduce levels of car use by effecting modal shift for as many journeys as possible. In many respects, the success of the strategy is predicated on this modal shift yet nowhere in the evidence base does it suggest what the required increases in rail and bus patronage, cycling and walking are.
25. In assessing sustainable modes of travel, the Transport Assessment makes reference to Department for Transport (DfT) evidence on travel plans variously from 2005, 2007 and 2010, much of which based its outputs on data gathered between 2004 and 2008. These are extremely dated evidence sources framed within a totally different historical policy context, so to rely on them to support a plan being consulted on in 2019 lacks credibility. Even if one does take the lessons learned from this historical evidence, it is clear that the ability to affect significant modal shift in Brentwood borough is expected by the Transport Assessment to be very limited. Paragraph 7.3.9 of the Transport Assessment states that, "This seems a proportionate and pragmatic approach and the reduction in trips is at a level which should be achievable in the future in the context of the modelling". It then presents in Tables 7.5 and 7.6 the assumed numbers of car driver trips once 'sustainable measures' have been applied. In summary:
* In the morning peak, there would be a reduction of 239 car driver trips out of a total of 22,499 trips (1.06%)
* In the evening peak there would be a reduction of 194 car driver trips out of a total of 22,484 trips (0.86%)
26. This is not considered to represent a sustainable movement strategy therefore the Reg 19 Plan cannot be considered to be justified because it does not represent a reasonable strategy.
27. We now consider each of the sustainable transport modes in turn, as far as they relate to growth at DHGV and West Horndon.
3.3 Rail infrastructure
28. The transit-oriented growth strategy that underpins the Reg 19 Plan relies heavily on the rail network to enable the increased resident and worker population to travel by train. It recognises that a significant proportion of people commute out to London on the rail network every day (Figure 3.7 in the IDP notes that the proportion of residents in Brentwood commuting by rail is high).
29. A key part of the strategy focuses on West Horndon station, with the strategy expecting the new residents in West Horndon and DHGV to use this station when travelling by train. Figure 3.8 in the IDP summarises the number of users of the station over the period 2010 to 2015. It then states at paragraph 3.38 that, "West Horndon Station's growth levels are very modest." This may be true as far as entries and exits to and from the station when compared with other stations on the Anglian mainline (Shenfield, Ingatestone, Brentwood and Chelmsford) but this makes no acknowledgement of how busy the train are. As is shown by the photo in Figure 1, the C2C trains serving West Horndon during the morning peak at present are heavily congested:
Figure 1: Photo of typical train congestion on London-bound trains from West Horndon station in the morning peak, March 2019
[Please find the photo in attached document]
30. Local commuters report that trains arriving between 06.54 and 09.02 always have standing room only. In total this includes 9 trains which travel to London Fenchurch Street Station each morning. It is clear that a growth strategy predicated on increased train usage requires an increase in the capacity of the trains on the London, Tilbury and Southend line to London Fenchurch Street Station. This is endorsed by the Transport Assessment which, when considering the West Horndon public transport interchange at the station, states at paragraph 7.2.26 that:
"An increased capacity on the existing train service will be central to the new cycling, walking and bus movements of the new residents and employees accessing the four sites."
31. Despite this, there are no identified plans for investment in increased passenger rail capacity on this line and no suggestion in the Reg 19 Plan or the evidence base as to the scale of improvements required. Whilst the expansion of the interchange at West Horndon station is welcomed, this of itself will not increase capacity on the rail network. The national Planning Practice Guidance addresses what baseline information should inform a transport assessment of a Local Plan. It notes that this should include an assessment of, "accessibility of transport nodes such as rail/bus stations to facilitate integrated solutions" (Paragraph: 005 Reference ID: 54-005-20141010). This includes their accessibility by rail, which is particularly important given the reliance on linked trips by rail passengers seeking to access DHGV (by bus, cycling or on foot). Yet the evidence supporting the Reg 19 Plan does not provide this.
3.4 Cycling and walking infrastructure
32. The national Planning Practice Guidance requires a transport assessment to consider whether it should establish 'future predicted trips' in respect of walking and cycling facilities and movements. Given the Reg 19 Plan strategy is for a key non-vehicular movement corridor to be between DHGV and West Horndon, this must be part of the Transport Assessment as it is important to understand the modal share that such trips are expected to account for. Yet none of the evidence provides any suggestion as to what proportion of journeys between these two locations is expected to be by non-vehicular modes. This is crucial to the success of the strategy because West Horndon is a key transport interchange and DHGV is the planned location for all new education provision to serve the growth in pupils from West Horndon.
33. Equally, Figure 3.5 in the IDP notes the scale of the challenge - between 2001 and 2011 cycling to work by Brentwood residents fell and was the second lowest in Essex. It is unclear what the strategy is to increase modal share by bicycle. Not only does the Reg 19 Plan not identify specific routes but it does not make clear how cyclists would navigate across key junctions safely. This is critical because it is well established that one of the main reasons why levels of cycling in England remain low is because of safety concerns. An off-road route will encourage people but if that route doesn't provide safe passage across heavily-trafficked junctions, then people will not cycle.
34. The Reg 19 Plan provides no suggestion that such a route has been properly considered or that it has been secured. The costs identified in the IDP schedule therefore cannot be verified because the evidence does not demonstrate how they have been derived. However, with dedicated cycle routes in the order of 3km required to link West Horndon station into and through DHGV, an allowance of £1.8m for walkways and cycleways appears to be a gross under-estimate if a meaningful and required increase in cycling and walking is to be achieved.
35. The lack of certainty is reinforced by the IDP schedule referring into to 'feasibility studies' in respect of a green bridge (over the A127) and pedestrian underpass (under the A128). Whilst a 'headline estimate' cost is provided, it is not clear how the strategy would be delivered if the feasibility studies determined that one or both of these schemes could not be delivered.
36. As noted above, it is vital to the sustainability of the Reg 19 Plan strategy that as many short journeys as possible between West Horndon and DHGV are undertaken by non-vehicular modes. Given that all the proposed primary school provision to serve the growth at West Horndon will be provided at DHGV, then maximising the potential for children to walk and cycle to school is vital. In this regard, the need for safe and direct routes increases in importance. Very few primary school-aged children are going to walk or cycle on routes which are not separated from vehicular traffic and equally, very few children are going to walk more than one kilometre to school, irrespective of the quality of the route. It is a significant concern to the Parish Council that without a clear and credible plan for developing walking and cycling linkages between West Horndon and DHGV, then the reality is that many parents will choose to take primary school-aged children to school by car. This will exacerbate the congestion at school drop-off and pick-up time in West Horndon, with some parents travelling by car to West Horndon Primary School and others leaving West Horndon to access schools in DHGV.
4.0 Flooding
37. The Parish Council, in its representations on the Draft Local Plan in March 2016, addressed concerns relating to flood risk and the impact of flooding on West Horndon. We do not seek to reiterate those points here.
38. The Brentwood Strategic Flood Risk Assessment (SFRA) 2018 identifies that large sections of the area around West Horndon, including the land to the east which connects it to the DHGV site, are considered to be high risk flood areas. This is demonstrated on the ground in West Horndon, with areas regularly lying under water and, at Christmas in both 2012 and 2013, subject to major flood events (see photos below).
[please find the photos in attached document]
39. In light of this and the fact that these events are occurring with increasing regularity (and scientific evidence making clear that a major cause of this is climate change), it is considered vital that a precautionary approach is taken to considering the impact of flooding, not least because of the scale of growth proposed at DHGV as well as the significant amount of employment development proposed at East Horndon Hall (Policy E13).
40. The likely implications of climate change on flooding are only starting to be realised. In fact, on 28th February 2019, the Environment Agency published a new report which looked at the likely impacts over the long term . This is based on more recent mapping data (2018) than is included in the flood risk mapping used to inform the evidence base for the Reg 19 Plan. It identifies that there are more places where new investment is not going to be cost effective and therefore, as a purely economic issue, more money will be needed to provide better flood mitigation infrastructure in more places. So whilst evidence from the local community may be anecdotal, it is based on observation over a long period of time and aligns with the evidence in the Environment Agency report that the threats are more widespread than the current evidence suggests.
41. One such example where this is considered to be the case is the proposed East Horndon Hall allocation. This field is observed to frequently be flooded and therefore there are significant concerns that the flood mitigation required for this site alone will be significant. The cumulative impacts of this site and the neighbouring DHGV site are therefore considered likely to be significant and the evidence used to inform the Reg 19 Plan has not fully and properly considered this.
42. The Reg 19 Plan is not accompanied by a Level 2 SFRA. National Planning Practice Guidance states that:
"Where a Level 1 Assessment shows that land outside flood risk areas cannot appropriately accommodate all the necessary development, it may be necessary to increase the scope of the Assessment to a Level 2 to provide the information necessary for application of the Exception Test where appropriate." (Paragraph: 012 Reference ID: 7-012-20140306).
43. One of the recommendations of the Level 1 SFRA was:
"Should the Council wish to allocate sites with an identified flood risk, then the policy should either be to avoid the areas of flood risk or to assess the risk in more detail through either Level 2 SFRA work or on a site specific level. This more detailed review should include identification of Flood Zone 3b and it should assess flood hazard and depth for return periods up to and including the 1 in 1000 annual probability plus climate change event." (paragraph 9.2.1)
44. The nature of the areas that are within flood zone 3 (see Map 2) suggests that it could be difficult to ensure that the DHGV site delivers the necessary levels of development. Indeed, the SA notes Appendix K of the Surface Water Management Plan (SWMP):
"Whilst the Dunton Garden Suburb consultation document (January 2015) suggested that the area in question [around the area of high flood risk] would be left as open space, there is currently less certainty regarding precisely where built development... would occur. Also, it is noted that a large portion of the area under consideration... is identified by the SWMP as having limited potential to deliver 'infiltration' measures as part of sustainable drainage strategy."
Map 2: Flood zones in DHGV site
[Please find Map 2 in attached document]
45. Moreover, whilst the requirement of Policy RO1.D.k on DHGV for "strategically designed and appropriately phased infrastructure, employing the most up to date technologies to ensure a smart, sustainable and a resilient basis for drainage and flood management" is welcomed, it is of concern that such measures have not been scoped out in more depth to ascertain whether they do not undermine the viability of the overall development.
46. It is considered that without a Level 2 SFRA of the DHGV site, the Reg 19 Plan is not sound because it has not been justified and is not consistent with national policy.
47. The SA, in assessing the approach to flooding, summarises at paragraph 9.8.8:
"The Draft Plan (2016) appraisal concluded no significant effects on the basis that the spatial strategy generally avoided areas of flood risk, although flood risk is a constraint to growth at DHGV. Work has been ongoing to understand surface-water flood risk, and necessary Sustainable Drainage Systems (e.g. this was a reason for a decision being taken, following the Preferred Allocations consultation, to reduce the number of homes delivered at the Blackmore allocations), and so significant negative effects are not predicted in relation to the Proposed Submission Plan; however, there remains some uncertainty ahead of a detailed DHGV masterplan."
48. The SA then goes on to consider that, in respect of flooding, all sites are assessed as having an equal impact.
49. This approach is contrary to the advice in national Planning Practice Guidance, shown in Figure 2. The SA has failed to properly consider alternative sites at a lower risk of flooding and the evidence supporting the Reg 19 Plan has failed to properly demonstrate that the level of growth proposed for DHGV can be accommodated on the site in areas with a low probability of flooding.
Figure 2: Taking flood risk into account in the preparation of a Local Plan
[Please see Figure 2 in the attached document]
50. It is considered that the Reg 19 Plan is not sound because national planning guidance in respect of the approach to taking flood risk into account in the preparation of a local plan.
5.0 Summary of objections - consistent with national policy and justified
51. The Reg 19 Plan is not sound in respect of the Dunton Hills Garden Village because it does not adequately demonstrate that it is consistent with national policy. As stated in the NPPF, such consistency is required to enable the delivery of sustainable development in line with the policies in the Framework. In order to do this, full and careful consideration must be given to, amongst other things, promoting sustainable transport and meeting the challenge of climate change and flooding - both objectives of the NPPF.
52. The Reg 19 Plan is not sound in respect of DHGV and its transport policies because it is not justified. It is not based on proportionate evidence to inform what the Plan acknowledges is a key principle that is used to justify the overarching strategy, namely the ability to deliver infrastructure that enables more sustainable movement. The reason that it is not based on proportionate evidence is because the evidence base fails to properly assess the impacts of growth on the A127 and to articulate - and cost - the provision of a sustainable movement strategy which has sufficient capacity to accommodate the increased demand. In this regard, the lack of evidence as to how the increased passenger numbers on the South Essex railway line through West Horndon station are of particular concern to the Parish Council.
53. The Reg 19 Plan is not sound in respect of DHGV and its policies in relation to flooding for two reasons. First, it has not undertaken a Level 2 Strategic Flood Risk Assessment, despite there being clear concerns raised in the Sustainability Appraisal (SA) about the ability to accommodate the levels of growth proposed on the site whilst adequately mitigating the flood impacts. Second, the SA has failed, in light of this, to consider reasonable alternatives. Both of these matters mean that the preparation of the Reg 19 Plan is not consistent with national policy.

I believe the plan to be unsound and not thought out thoroughly with common sense in mind. It is full of "ideas" that have not been sensibly thought through. Development at West Horndon and Dunton is unrealistic and unworkable.

RO2 - Point 3.3 Drainage - West Horndon currently suffers from surface water flooding. A further 580 homes, together with all the extra infrastructure required to accommodate this volume of people, will exacerbate this problem. The Tillingham Hall development in the 1990s was abandoned, in part, due to this problem.
Point 9.91 Main vehicular access via Station Road. Station Road is already unable to cope with the current volume of traffic. It is a country lane with a sharp double bend where the road crosses the railway line. This part of the road is a major hazard with frequent accidents. 580 new properties will result in a minimum of 580 cars exiting onto what is already a major danger spot.
Station Road is also used as a "rat run" when the M25, A127 and A13 are closed, running slowly, or congested.
9.93 & 9.94 The Council are living in Never Never Land if they think people will use alternative forms of transport to the car .... people will use cars! West Horndon station is a 2 platform station which barely copes (in the rush hour) with the sudden impact of hundreds of people descending on such a tiny space. There is very little parking space and nowhere to allocate further spaces.
(Also see below comment regarding Dunton Garden Suburb inhabitants using West Horndon Station)
RO1 Point 8.2 Potential Dedicated Bus Routes My previous comment applies ... West Horndon station is a 2 platform station which barely copes (in the rush hour) with the sudden impact of hundreds of people descending on such a tiny space.
8.4 Improvements at West Horndon Station etc My previous comments apply regarding parking, nowhere for extra infrastructure to accommodate bus interchange or bicycle storage.
I believe the plan to be unsound and not thought out thoroughly with common sense in mind. It is full of "ideas" that have not been sensibly thought through. It's everyones' idea of what, in a perfect world, it could be like.
There is no space at West Horndon station to accommodate more passengers in the rush hour, nowhere to park, provide cycle storage or allow interchange for buses. Station Road will become totally congested with traffic joining from the proposed site for the new homes. The addition of buses coming in from Dunton Garden Suburb would exacerbate the problem further.
This part of the plan is unrealistic and unworkable.

The SA and evidence base do not support the spatial strategy for growth set out in the Local Plan. The Local Plan process should be suspended to allow a fundamental review of the SA.

We find the plan to be unsound, not legally compliant and failing in its Duty to Cooperate, as set out in the statement below.

1.0 EXECUTIVE SUMMARY
1.1 Work on the emerging Local Plan for Brentwood Borough commenced back in 2009. Andrew Martin-Planning has made representations to each key stage in the plan-making process on behalf of Countryside Properties, in respect of land to the east of West Horndon. We attach past representations as appendices because they continue to be relevant and demonstrate that land at West Horndon represents the most sustainable location for strategic growth in the Borough to meet development needs over the Plan period 2016 - 2033.
1.2 Representations to date have argued that Brentwood Borough Council (BBC) has progressed its local plan without the benefit of a complete, robust and up-to-date evidence base. Furthermore the Sustainability Appraisal (SA) does not fully support the spatial strategy for growth proposed in the Local Plan. The SA cannot be said to have informed the production of the Pre-Submission Local Plan. We submit that this continues to be the position.
1.3 The emerging Local Plan has struggled to identify land for strategic growth in a Borough where 89% lies within the Green Belt. The latest version of the Plan acknowledges that it is not possible to identify a 5-year housing land supply (paragraph 4.18). A greater proportion of the required homes will therefore have to be delivered beyond 2023.
1.4 The Council's problem in identifying land for housing is compounded by recent sanctions imposed by the Government under the 2018 Housing Delivery Test introduced in the revised National Planning Policy Framework. The total number of homes required in the Borough over a three year period up to April 2018 was 933. The Council only delivered 474 homes, i.e. 51% of its target. Consequently it is now required to produce an Action Plan showing how it intends to boost delivery and must have a 20% buffer on its housing land supply.
1.5 Throughout the preparation of the Plan the Council has maintained its intention to deliver at least one large-scale, strategic site for a mixed scheme of housing and employment. Various strategic site options have been examined over the years and the latest SA to the Brentwood Local Plan Pre-Submission document, February 2019, confirms :
"there is now a refined understanding of those sites that are genuine ('reasonable') contenders for allocation through the Local Plan. Specifically at the current time there is a need to give close consideration to two options:
* Dunton Hills Garden Village (DHGV)....
* West Horndon..."
1.6 Although these two sites are said to remain in contention, the Local Plan has chosen DHGV as its preferred option for growth. This is contrary to the accompanying evidence base which appears to lend greater support to growth adjoinging the existing settlement of West Horndon. We argue that the Local Plan is unsound because it is not accompanied by a Sustainability Appraisal that supports the Brentwood Local Plan spatial strategy for growth. The SA prepared by AECOM is quite simply unable to rule out strategic development at West Horndon as a viable alternative solution to growth in the Borough. It therefore remains in contention. The SA finds favour in DHGV over West Horndon, only in terms of the scale of housing that can be provided. We and others submit that there is no evidence to suggest that the scale of development proposed at Dunton Hills can be delivered.
1.7 A Joint Spatial Plan for authorities in South Essex (Including Brentwood, Thurrock, Basildon, Castle Point, Rochford and Southend on Sea ) is in the early stages of preparation. This will be an important document that encompasses several local authorities that are struggling to meet their growth needs in predominantly Green Belt areas. Brentwood Borough Council's attempts to create a cross boundary settlement with Basildon at Dunton Hills has failed, but more recent proposals for a new settlement on land at Thurrock, centred on West Horndon, are a feasible alternative as proposed in Thurrock Council's emerging Local Plan (Issues and Options Stage 2). It provides the opportunity to address the need for housing in the context of a probable shortfall across the South Essex Strategic Housing Market Area. Through the Duty to Cooperate procedure authorities like Thurrock could contribute towards meeting any unmet housing needs from Brentwood within a proposed new settlement centred on West Horndon.
1.8 Growth at West Horndon rather than Dunton Hills has historically been supported by Thurrock and Basildon in their response to the emerging Plan for Brentwood. Reasons include its proximity to existing infrastructure such as a railway station, less impact in landscape terms and in relation to the key purposes of the Green Belt, such as coalescence (with Basildon). Crucially, land at West Horndon would be able to deliver much needed housing in the first five years of the Local Plan.
1.9 Strategic infrastructure proposals for Brentwood or Thurrock should not be considered in isolation from wider strategic infrastructure proposals, specifically the options and final decision on the Lower Thames Crossing.

2.0 LOCAL PLAN HOUSING REQUIREMENT
2.1 The Brentwood Local Plan, February 2019 maintains that housing need in the Borough, based on the NPPF July 2018, should be set at a minimum of 350 homes per annum. With an uplift of 20% this rises to 456 dwellings per annum. Given recent poor performance in reaching its housing target (over the three year period to April 2018 it delivered only 51% of its required housing), the Government has identified the Authority as one that must put in place an Action Plan to state how it will boost housing and apply a 20% uplift.
2.2 Whilst Local Housing need will be the subject of ongoing debate and analysis through the examination of the Local Plan, what the Plan does not dispute is its current failure to identify a five year housing land supply as required by government guidance. Consequently a greater proportion of required homes will be delivered beyond 2023 (paragraphs 4.18 to 4.21).
2.3 From an overall minimum requirement of 7752 homes over the plan period, some 35% (2,700 homes) is proposed to be located within a new settlement at Dunton Hills, which is not supported by evidence to demonstrate deliverability and viability. As more need is identified in the Borough this proposed new settlement is being called upon to absorb an ever increasing number of new homes. In November 2018 when the Regulation 19 Plan was considered by Full Council, some 19 amendments were proposed including ones to remove certain housing allocations such as land at Honeypot Lane, resolving simply to reallocate lost housing (some 200+ homes) to DHGV "so that there is no net loss to the overall plan". Discussion between members simply referred to the promoters of DHGV stating that they have agreed to accommodate the extra number of homes. The proper justification for such a significant change to the plan is absent.
2.4 The Plan places great emphasis on the fact that DHGV was announced by the Government as one of 14 proposed Garden Villages back in January 2017 and that the Council received funding to take this forward. In reality such an investment is made at the risk of the planning and legal processes which may conclude that the proposals go no further. This has been demonstrated in the case of the North Essex new settlement proposals where a Local Plan inspector found that significant further work is required to justify the Garden Community proposals. They have not been shown to be viable and deliverable. It could be argued that the proposals for DHGV will suffer the same problems.
2.5 Lessons can be learned from emerging Local Plans for nearby/adjoining authorities and their proposals for key strategic sites. A Post Hearing Note issued by the Local Plan Inspector appointed to examine the London Borough of Havering Plan casts doubt over the spatial strategy for growth and issues surrounding housing land supply. It queries the SA and various options examined, together with the assessment of the alternatives. The evidence drawn upon by the Council to reach its conclusions is queried. The Inspector has also expressed concern that the Plan does not demonstrate sufficient housing land supply to cover the 15 year period, nor has the Council been able to demonstrate that it has sufficient sites to provide a 5 year supply. The Housing Trajectory is queried. The Council is asked to justify its expectations in relation to delivery of key sites and assumptions in relation to infrastructure requirements. Brentwood could be accused of being similarly vague in terms of the proposed delivery of DHGV, on several counts.
2.6 The Uttlesford Local Plan has recently been submitted for examination and initial questions by the appointed Inspectors raise concerns about potential gaps in the timing and funding of large critical infrastructure associated with the proposed Garden Communities that are central to the overarching strategy of the Plan, in particular the delivery of housing. DHGV is beset with the same problem of a lack of technical evidence to support the proposed new settlement.
2.7 As the 2019 SA of the Brentwood Plan confirms, the adjoining authority of Basildon questions whether the scale of development proposed at Dunton, which amounts to over a third of the Borough's entire housing provision for the plan period, could be supported by infrastructure, in the absence of a clear delivery plan. The adjacent authority of Thurrock cites a lack of technical evidence and failure to test fully all the reasonable options given the decision to rely on a new settlement rather than urban extensions closer to existing infrastructure.
2.7 There is insufficient evidence to demonstrate that the Local Plan housing requirement can be met by the spatial strategy for growth proposed in the Draft Local Plan.

3.0 SUSTAINABILITY APPRAISAL
3.1 The SA is clear that both DHGV and West Horndon remain in contention as strategic site options to meet growth needs in Brentwood. The SA has been undertaken by AECOM who clarifiy in the section entitled "Establishing the Preferred Option" that it comprises text that "is the response of Council Officers to the alternatives appraisal". As we have stated in previous representations to the emerging Plan, the only real support for DHGV to justify its elevation to a 'preferred allocation' is that the scheme is supported by the Council. Consultation on DHGV has led to wide-scale objection from the public and key stakeholders which the Council has chosen to ignore. Various positives and negatives of DHGV and West Horndon are set out in the SA, concluding that Dunton Hills provides the opportunity for a larger and comprehensive scheme. The SA acknowledges proposals for a new settlement in the north of Thurrock where it adjoins West Horndon but rejects these on the basis that "this proposal is at such an early stage of formulation that it cannot be considered to be a potential issue or constraint in delivering DHGV".
3.2 It has been difficult for the Council and its advisers to dismiss land at West Horndon as a reasonable alternative because it represents a more sustainable location for growth than DHGV, as confirmed in various evidence base documents and summarised in the SA. Unlike DHGV, it can deliver houses in the first five years of the plan and in conjunction with land in Thurrock is capable of exceeding housing need going forward.
3.3 The only reason DHGV is selected as the preferred option for growth is its perceived ability to provide a greater number of new homes. As we have stated above there is no firm evidence to demonstrate this.
3.4 AECOM has recently been appointed by Uttlesford District Council to review the SA to its Local Plan. This follows the report of the Inspector who considered the Joint Section One Plan for the North Essex Authorities and his concerns regarding the SA process it was subject to. UDC felt that a review of its SA was necessary because of similarities between the NEA Plan and Uttlesford in terms of their reliance on Garden Communities. AECOM identified a number of concerns in relation to the objectivity of the SA for the Uttlesford Local Plan, and assumptions made for its Garden Community options. In particular the SA is said to have relied on what was being proposed by developers/promoters of the key strategic sites, raising concerns about the fairness and consistency of the appraisal. The same criticism could be levelled at the SA of the Brentwood Plan that relies without question upon the word of CEG as the promoter of DHGV.
3.5 Representations to the Draft Local Plan, Sustainability Appraisal and evidence base submitted by AM-P on behalf of Countryside Properties in March 2018 are attached at Appendix 1. These refer to the Interim SAR of January 2018 and 2016, and remain relevant. Appraisal of the spatial strategy alternatives in versions of the SA over time, demonstrate differing results for which there is no justification. By way of example we compare the summary tables from the 2016 SAR and that for January 2019. Under several topics the score for West Horndon has been downgraded in the most recent appraisal, without proper explanation. Despite this it has still not been possible for the Council and its technical advisors to dismiss West Horndon as a sustainable location for growth. In landscape terms development at West Horndon would have significantly less impact than that at Dunton. DHGV continues to be preferred (albeit AECOM confirm this as an officer view) because it is seen as an answer to the Council's housing supply problems. The latest proposals by Thurrock on land to the south of West Horndon throw a different light on the SA conclusions.

4.0 THE EVIDENCE BASE
4.1 The evidence base to the Local Plan is in part outdated, and incomplete.
Transportation
4.2 The Infrastructure Delivery Plan (IDP) has no date on it. The chapter on transport and movement refers to ongoing studies on the A12 and A127 key routes and the proposed route of the Lower Thames Crossing. Work so far finds that main junctions on the A127 are operating significantly over capacity.
4.3 The SA confirms that ECC withholds support until the appropriate highway modelling has been undertaken to assess site specific and cumulative impacts of developments on the local and wider highway network. Furthermore, highway network considerations must be a foremost consideration when arriving at reasonable spatial strategy alternatives.
4.4 The Transport Assessment of the Brentwood Local Plan was undertaken by Peter Brett Associates in October 2018. This confirms in paragraphs 1.2.3 to 1.2.5 that in respect of the A127 corridor for growth, a number of studies are progressing, being led by ECC. Within the A127 Corridor for Growth Study there are individual pieces of work which are currently at different stages of planning and development. Where information is available, this has been used to inform modelling. The final outcomes of the study are not yet known and continued working with ECC and other neighbouring authorities will be important.
4.5 The Local Plan confirms the incomplete status of the transport assessment by stating that A127/A128 studies by ECC are "to be fed into the plan". Policy does however aim to maximise the value of railway connectivity and recognises the important role for West Horndon station in future transport provision.
4.6 An Amendment Note to the Transport Assessment dated January 2019, confirms the further information that is to be provided. This includes amongst other things additional junction studies, further trip distribution plots, cross boundary impacts, reassignment impacts and proposed highway mitigation.
4.7 The SA confirms that Highways England's work is not complete in terms of the transport study, that ECC question the use of the A127 corridor over the A12 and Basildon Council has concerns over infrastructure provision relative to DHGV. Thurrock Council favours growth at West Horndon which is closer to existing infrastructure.

Green Belt/Landscape
4.8 When the emerging Plan was last consulted on in early 2018 the Green Belt study was in draft form and had not influenced the site selection process. However, back in 2016 a Landscape Study by Crestwood had identified that Dunton was one of 7 sites out of 203 assessed that makes a 'high contribution' to the Green Belt. The analysis found that "This expansive agricultural site if wholly developed would significantly reduce the gap between West Horndon and Basildon, as well as presenting large scale development along the A127 leading east from the M25." The site was found to be "not contained", to have "significant separation reduction" and a harmful effect on functional countryside. Land at West Horndon is found to make only a 'moderate' contribution to the Green Belt. Development on land to the east of the settlement would decrease the gap to Basildon but still retain a functional open space with very limited or no visual linkages. There would be some loss of countryside if developed. Land to the north-east would lead to larger encroachment of the countryside but not to the coalescence with other towns.
4.9 By 2018 work by Crestwood reached a different conclusion on the contribution made to the Green Belt by land at Dunton Hills. Its importance in terms of contribution to the Green Belt went from 'high' status to 'moderate to high'. Land at West Horndon remained classified as 'moderate'. In our previous representations we submitted that the findings were contrived. We considered that they had been retrospectively prepared to justify the Council's wish to promote DHGV. Detailed site assessment still remained to be undertaken.
4.10 A Green Belt Study Part III was published in January 2019 alongside the Regulation 19 Plan. This maintains that the scope of study did not extend to the identification of sites that should be prioritised for allocation for housing, employment or mixed use. Its conclusions were the same for land at Dunton Hills ('moderate to high' contribution to the Green Belt ) although part of the land at west Horndon (to the east) was altered from a previous moderate status to 'moderate to high'. Once again we find these results to be contrived to fit the Council's desire to promote DHGV.
4.11 Immediately following the previous round of consultation on the emerging Local Plan in January 2018, we became aware of an evidence base document entitled "The Dunton Area Landscape Corridor Design options Local Plan Green Infrastructure", dated 07/11/2017. This was undertaken by Essex Place Services and commissioned jointly by Basildon District Council and Brentwood Borough Council. The purpose of this document was stated to be "to undertake a broad scale landscape assessment and present proposals for a landscape buffer and green corridor that could encompass the borough boundaries and give visual separation between two potential residential development sites." i.e. an urban extension to Basildon on its west side and a new Garden Village settlement based on the Dunton Hills area (see appendix 2 which is a plan from this report showing the extent of a landscape buffer that would be required in respect of residential development at Dunton Hills
4.12 Key conclusions of this assessment were:
* an assessment of the landscape as "particularly sensitive landscape areas";
* "Views of the project area from the north, west and south west are likely to be particularly notable due to the gently rising land form";
* "In order to mitigate what could be adverse landscape and visual impacts arising from development, the retention of landscape features and the provision of new landscapes, both green and blue infrastructure are likely to be a significant element of any development";
* "There will also be a need to ensure that residential areas are well protected from the busy transport corridor routes in terms of noise, visual impacts and pollution. The landscape infrastructure required to achieve this will be in addition to the landscape corridor required to provide settlement separation and the potential for connectivity to the wider countryside"; and
* Three landscape corridor Options are considered within the report, concluding that Scheme 3 - i.e. that proposing the maximum land-take - is recommended. This considerable land take within the wider assessment area is proposed to "ensure a good outcome in terms of preventing visual settlement coalescence, allow for diverse landscapes and the ecological enhancements to be achieved".
4.13 Despite the fact that Brentwood Borough Council did jointly commission this evidence base report, it does not feature on its website as an evidence base to the emerging Local Plan. A key finding of this assessment was that landscape mitigation works required would crucially not leave sufficient land for development to accommodate 2,500 new homes at that time proposed in the Draft Plan for Dunton Hills Garden Village, let alone the potentially higher figure of 4,000 beyond the plan period.

APPENDICES
1. Brentwood Draft Local Plan - Preferred Site Allocations, Sustainability Appraisal and evidence base. Representations on behalf of Countryside Properties (UK) Ltd in respect of land to the east of West Horndon. March 2018.
2 Extract from "The Dunton Area Landscape Corridor Design Options Local Plan Green Infrastructure", by Essex Place Services for Basildon and Brentwood Councils, 07/11/2017. Appendix 3, Plan showing the extent of a landscape buffer that would be required in respect of residential proposals on land at Dunton Hills.
and
An extract from the Bid document to the Government for Dunton Hills Garden Village which shows how much proposed development could be lost to landscaping.

We write further to the above consultation on the above on behalf of our clients, Hermes Investment Management and Hermes Property Unit Trust ("Hermes"), the asset manager and owner of the West Horndon Industrial Estate, Station Road, West Horndon (your site refs 021 & 022). You may recall, Hermes acquired Threadneedle's interest (approximately covered by your site ref 020) last year, so they now own the bulk of the larger West Horndon Industrial Estate which includes your site refs 020 and 021. Their discussions to acquire the land shown by your site ref 152 are well advanced and will be subject to planning permission for the residential-led, mixed use redevelopment of the land which is allocated by R02 in the Pre-submission draft of the Local Plan. As you know form the last consultation in March 2018, our preparation of a planning application for residential led mixed-use development on the western portion of the industrial estate (including land identified as site refs 152, 021 and part of 020) was well advanced, and we had expected to submit the planning application sometime last year. However, following the acquisition of Threadneedle's interest and taking account of the views of Brentwood's officers and West Horndon Parish Council, Hermes took the decision to expand the planning application to include the whole of the land identified as R02. This has resulted in additional work and will require further pre-application discussions and consultations (with Brentwood BC, Essex CC and West Horndon Parish Council). Our revised aim is to make the hybrid planning application for the whole site later this year (around September/ October). Hermes has made representations to the various drafts of the local plan over the time of its ownership. It is not our intention to repeat any of those in relation to the Pre-submission draft of the Local Plan. Instead, our representations will focus solely on matters that affect the draft allocation R02. Please note, in expressing support or comment on the matters set out below, Hermes is affirming they consider the Pre-submission draft of the Local Plan to be sound. Page 22 Settlement Category - SUPPORT: West Horndon as a large village within settlement Category 2. Page 24 para 2.14 - SUPPORT for improvements to access to West Horndon station arising from and facilitated by Dunton Hill Garden Village. Page 39 para 3.21 (b) - SUPPORT. Page 92 Policy BE11 (B ii) - SUPPORT Strategic Transport Infrastructure designed to improve access to West Horndon station; arising from and facilitated by Dunton Hill Garden Village. Page 95 para 5.96 (c) - SUPPORT Page 96 para5.105 - SUPPORT Page 103 para 5.121 - SUPPORT Page 114 para 5.155 - SUPPORT Page 177 Policy PC03 Employment Land Allocations include 2.0 hectares of R02 - SUPPORT & COMMENT: insofar as this includes the employment to be retained on the site, as well as the new employment opportunities created by the new village centre (which will include retail and non-retail uses). Page 181 para 7.30 - SUPPORT Page 185 Policy PC07 Retail and Commercial Leisure Growth - SUPPORT & COMMENT: it is important to note the Brentwood Retail and Commercial Leisure Study (Dec2014) by NLP. The emerging West Horndon master plan includes a new village centre which incorporates shops and non-retail uses, such as potential health facilities. NLP suggested an additional 2000sqm of retail may be appropriate as part of the redevelopment of the industrial estate. Our latest masterplan shows around 2700sqm, but this includes non-retail uses. Page 186 para 7.53 - SUPPORT Page 187 Policy PC08 - SUPPORT& COMMENT: the new village centre for West Horndon is likely to include an additional 2700sqm of retail and non-retail accommodation. Page 231 Policy NE10 Green Belt - COMMENT: West Horndon is not within green belt, so it is unclear what purpose reference to it in this policy serves. Page 244 para 9.7 - SUPPORT the reference to R02 on the list of Strategic Housing Allocations. Page 254 Policy R01 (II) d- SUPPORT Page 269 Policy R02: LAND AT WEST HORNDON INDUSTRIAL ESTATE & supporting paragraphs - SUPPORT & COMMENT: Hermes' draft masterplan for the whole site includes a variety of dwelling types, including flats (making up the proposed village centre, nearest to the Station Road entrance and West Horndon station) and 2, 3 & 4 bed houses. At present, the R02 site measures 17.6 hectares gross, which nets down to 15hectares (after allowing for 15% POS and landscaping) in the latest draft of the masterplan. The current layout is nearer 750 dwellings, which is well over the figure of "around 580 new homes" set out in the policy. Page 309 Appendix 1 Housing Trajectory - SUPPORT & COMMENT: the timing of the supply of houses accords with the proposed phasing and Hermes' management of the existing leases on the estate. Please note comments in relation to the numbers of new dwellings the site can accommodate. Page 318 Residential Lead Sites - SUPPORT & COMMENT: it is unclear how Brentwood BC have worked out the gross (17.06ha) and net (10.23ha) figures as set out in the table accompanying the site allocation plan. It is also the case that the draft Local Plan's gross to net calculations given for all the larger residential allocation sites varies, sometimes considerably. At present, the R02 site measures 17.6 hectares in total, which nets down to 15 hectares (after allowing for 15% POS and landscaping) in the latest draft of the masterplan. The current layout is showing the number of dwellings to be nearer to 750, well over the figure of "around 580 new homes" set out in the policy. It is also noted that the density of development is lower in the Hermes' latest masterplan (50dph) than that suggested by draft Local Plan (56.7dph), although it is accepted that this depends entirely on the chosen base. Please let me know if anything is unclear. We would ask that you acknowledge receipt of these representations.

This representation is made on behalf of C & K Property, submitted as part of the Brentwood Borough Council Proposed Submission Local Plan (PSLP) Consultation (Regulation 19). The site associated with their land interests is east of Horndon Industrial Park, West Horndon. A location plan showing the site boundary can be found at Appendix A. This representation seeks to confirm our support for the plan insofar as those interests outlined above. The site is part of a wider site allocation for residential development, which is proposed for allocation through the Pre-Submission Local Plan (February 2019). The policy reference for the wider site is Policy R02. The site measures at approximately 0.8ha. The whole allocation under Policy R02 measures at 17.06ha. This representation is based solely on our client's land interests and its allocation for residential development. The statement does not represent the wider site outside of the red line, as shown at Appendix A. Our client's site is referenced as Site 152 in the Council's Emerging Local Plan and Housing and Economic Land Availability Assessment (HELAA) (2018). Site 152 has been actively promoted by C & K Property throughout the plan-making process. Previous representations have been made at various stages of the Local Plan, including in relation to call for sites exercises and consultations on iterations of the Local Plan. The HELAA (2018) confirms that the site is suitable, available and achievable for residential and employment development. In the previous Preferred Site Allocations Document (Regulation 18), there were some minor inconsistencies regarding the extent of the site proposed for allocation when compared to the client's land ownership. Following Strutt & Parker's previously submitted representations, we are happy to confirm that these inconsistencies no longer remain. The Proposed Submission Local Plan Document confirms that the whole site can accommodate up to 580 dwellings. It is considered that due to the sustainable nature of the site, a high density could be achieved on our client's parcel. A density of circa. 70 dwellings per hectare, resulting in a proposed capacity of around 60 new homes would allow the site to further contribute to the Borough's housing need. Our client's site is available for residential development and deliverable within the short-term. By coming forward in the short-term, the site could aid the Borough's shortfall in housing supply. Subject to the progress of the intended masterplan process as set out at Policy R02, there is an opportunity to bring forward the site earlier in the plan period. Paragraph 3.21 (b) of the PSLP states that brownfield opportunities will be taken to effectively meet local needs, such as the residential-led, mixed-use redevelopment of existing industrial land in West Horndon. We agree with this approach. The allocation of the site at West Horndon for residential development does represent a sustainable and deliverable proposal to help meet local housing needs over the coming plan period. We support the allocation at West Horndon Industrial and are prepared to work with the landowners of the adjacent site to bring forward a masterplan for the allocated wider site.

Has considered local opinion to an extent but requires further local consultation with residents.

Refer to attached scanned form.
Agree with development of West Horndon Industrial Estate, concerned about congestion from development to the north of Brentwood and Pilgrims Hatch. Sawyers Hall Lane development would result in loss of greenery and increase in local pollution. Noticed Ingrave isn't marked as a location for improvement or partial urbanisation. In the SA , Figure 5.8 as an option would reduce parking.
In the town centre, Sainsbury's parking is already full and costs money to park. Table 6.1 in the SA [Sustainability Appraisal] notes Brentwood ranks low with "significant effects". Urbanisation in these areas could further effect the biodiversity and quality if further traffic is added> This relates back to 024 Sawyers Hall Lane. The railway station in Brentwood being made into homes would mean people could park and would be able to counter productive to an increase in housing and local traffic.
I feel a reduction in car parking would be a detriment to Brentwood community in come and ability for Brentwood to be a high street to visit since there is already limited parking.
Even if 9.4.9 'other modes of transport' [Sustainability Appraisal] mean increasing local pots for the council as money making. I feel that older people cannot always rely on public transport. My experience is that it is slow and unreliable.
The Ingatestone urbanisation took several years. My concern that disruption closer to Brentwood could cause delays to local traffic.
I would prefer to pay for parking. This would enable me and my older family to retain independence around the neighbourhood rather than worrying about catching the bus.