I recommend that the proposed E13 part of the plan is removed and if necessary the requirement for employment land is fulfilled by using space at other nearby sites.

The consultation document and the published supporting evidence is in many ways weak, confused and contradictory. As presented, I do not think this meets the requirements for the necessary evidence for a Regulation 19 consultation and thus the consultation is invalid.

I strongly object to the site south of East Horndon Hall being re-designated from Greenbelt to an Employment site (Policy E13) with the proposed intension of building an industrial estate on the site. The evidence as presented does not justify the change and a series of possible alternatives have not been examined in this consultation or the preceding Regulation 18 consultation.

Greenbelt change of designation

1. Currently the majority of the site is designated as Greenbelt and therefore there needs exceptional circumstances to justify change of designations from Greenbelt to employment use.
2. I can see no adequate justification in the Local Plan Regulation 19 consultation document or any of the supporting documents that explains an exceptional need to justify such a change of designation.
3. The proposed site is adjacent to rural residential housing and this will cause great disruption to them.
4. In the short-term industrial areas at Childerdich Park (Policy E12) & Cockridden Farm Industrial Estate (close to the A127/A128 junction and accessed from the A128) are currently not fully occupied and thus could fulfil immediate and short-term employment needs.
5. In the longer-term the propose Brentwood Enterprise Park (Policy E01) at the A127/M25 junction will be able to fulfil employment needs especially for heavy transport activities
6. The proposed DHGV will also have employment allocations for more local employment needs in the longer term.

Flood risk

1. The area is a poorly drained field which gets a lot of standing surface water with even moderate amounts of rain fall
2. This area acts as a buffer zone for water coming off Thorndon Country Park which travels under (and sometimes over) the A127. The modified section of the A128 to the east of the site prevents that water draining away naturally. In heavy rain fall situations the water backs up and overflows into the West Horndon Village drainage system
3. At present the West Horndon Village drainage system is barely adequate and has in recent times failed to cope with the volume of surface water following heavy rain fall. Excess water backs up and has caused flooding in the village in both 2012 & 2013.
4. On both occasions water from the E13 site overflowed into the village drainage system and contributed to the water backup that resulted in the flooding in the village.
5. The flood risk assessment published to support the consultation do not adequately examine or address this problems and, in my view, shows a complete lack of understanding of the issues. As a local resident of over 35 years I have observed several floods in the immediate and surrounding area and the assessment as presented in no way recognises or addresses the incidents I have personally witnessed.
6. In particular it does not adequately address the wider problem of water overflow from this site causing flooding in the village of west Horndon or the settlements south of the railway line. All are vulnerable and had been flooded in the past. How this situation can be managed is not adequately addressed.
7. A flood risk assessment report submitted as part of the refused planning application 17/01050/OUT (which sought to get outline planning permission for an industrial estate on this land) indicates that the land is subject to excess surface water and flooding. Other than Sustainable Urban Drainage techniques, which the report recognises will not manage the excess volume of water following high rain fall, the only mitigation measures suggested in the risk assessment report recommends passing excess water into the West Horndon Village drainage system. The potential consequences of this are not assessed.

Transport & Road Infrastructure

1. Construction of employment building on this land would significantly increase transport access, both car and vans for employees and also HGV traffic for the operation of the businesses on the site.
2. The supporting transport assessment identifies that the A127 is already at capacity during peak hours. It also projects that with all the proposed development in the South Essex A127 corridor will get significantly worse.
3. The A128 is also at capacity during peak rush hour times.
4. Access onto the proposed employment site will be via a small country lane turn off the A128. This is totally unsuitable for HGV traffic as is the junction onto the A128.
5. The transport assessment and other reports published by Essex Highways do not address safe and sustainable access to the site.
6. It is clear that if the proposed Dunton Hills Garden Village development proceeds then the road infrastructure will need to be upgraded and could be enhanced to incorporate improved access to this site, however that is a long term project and it is clear that developers want to progress this proposal significantly more quickly (they have already submitted an outline planning application) and as a consequence it is not clear how the road infrastructure will be managed.