Comment

Representation ID: 15882

Received: 12/05/2016

Respondent: West Horndon Parish Council

West Horndon Parish Council have submitted 8 documents which are:
Introductory letter; Representations, SA Executive summary; SA report; Appendices 1-4 for the SA. Reprentations have been submitted on the Brentwood Draft Local Plan and as WHP is a designated Neighbourhood Plan area, they have commissioned a Sustainability Appriasal of various Growth Scenarios for West Horndon. These scenarios are:
!. No growth; 2. Controlled growth; 3 proportional growth; 4. Controlled growth along with 1 strategic site; and 5. Expansive growth.

Object

Representation ID: 15912

Received: 12/05/2016

Respondent: West Horndon Parish Council

WHPC comment up front that whilst the Draft Local Plan document sets out historic consultation processes, it fails to provide a full background as to consultation response on a number of points. In particular, and as noted in 2.12 of this document, 84% of respondents to the Dunton Garden Suburb consultation in January 2015 rejected the proposal for significant development at Dunton, with only 3% supporting conditionally, and 3% supporting unconditionally. Whilst Dunton Hills Garden Village looks only at the Brentwood side of the originally proposed Dunton Garden Suburb, there was clear rejection of material development both 1) at this site and 2) within West Horndon village as stated throughout the Draft Local Plan, in response to the 2013 consultation round. As such, consultations to date clearly reject material development at either potential location within the A127 Corridor. Yet the current Draft Local Plan is supporting this approach.

Object

Representation ID: 15913

Received: 12/05/2016

Respondent: West Horndon Parish Council

WHPC note that the proposed development within the Draft Local Plan is highly concentrated within the A127 Corridor. This scale and concentration will irrevocably harm Green Belt within this area (at a disproportionate level than the wider Borough), create problems and risks with regards to deliverability, contribute to urban sprawl rather than prevent it, and create material infrastructure requirements that are simply not considered in sufficient detail within the Draft Local Plan. These issues are either ignored, or glossed ove r, in the Draft Local Plan document. WHPC believe that these issues lead to the potential for the Draft Local Plan to be considered unsound, unsustainable, and lacking in the level of detail that is required for a proposal of this nature. Much of the discussion below picks up on, and expands on the issues around material development within the A127 Corridor.
On this basis, and considering the independent Sustainability Appraisal undertaken by WHPC, WHPC represent that a sustainable level of development within the A127 Corridor would be limited to a maximum of 500 houses across sites 020 and 021 (the West Horndon Industrial Estates). As noted in 3.7 above however, even this level of development would require a significant amount of infrastructure expenditure to ensure it is sustainable. On this basis, and considering the independent Sustainability Appraisal undertaken by WHPC, WHPC represent that a sustainable level of development within the A127 Corridor would be limited to a maximum of 500 houses across sites 020 and 021 (the West Horndon Industrial Estates). Even this level of development would require a significant amount of infrastructure expenditure to ensure it is sustainable.

Object

Representation ID: 15914

Received: 12/05/2016

Respondent: West Horndon Parish Council

Throughout the development of the Draft Local Plan, BBC have consistently ignored potentially viable alternative sites, focusing primarily on the A127 Corridor despite the concerns expressed by WHPC. WHPC believe that BBC's 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 and hard evidence. Given the scale of development proposed, the original "problems" identified by BBC 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 it is noted that the A12 is in the process of being upgraded to 3 lanes (funded allocated), with the A12 Corridor also benefiting from Crossrail. Neither of these upgrades are proposed or indeed, currently feasible, within the A127 Corridor with the A127, and the C2C rail line.

Object

Representation ID: 15915

Received: 12/05/2016

Respondent: West Horndon Parish Council

Para 5.9 of the Draft Local Plan states that, in the Council's Preferred options consultation (2013) "Proportionately more growth at West Horndon was proposed because of the comparative capacity for growth in that location, and less growth in Ingatestone because of capacity and land constraints. The strategy also considered lack of capacity in the Brentwood urban area and north of the Borough in terms of infrastructure such as roads (due to congestion), primary schools, GP facilities and a higher landscape value". Whilst this is a historic comment, WHPC note that any development at or around West Horndon faces the same problems, and this is a point that remains relevant to this current consultation. New primary schools, GP facilities and local roads would need to be constructed, and major upgrades to the A127 and potentially A128 would also be required. We also continue to challenge the lower landscape value.

Object

Representation ID: 15916

Received: 12/05/2016

Respondent: West Horndon Parish Council

Paragraph 7.8 of the Draft Local Plan states that "The A127 Corridor provides an opportunity for growth in the Borough that brings along new services, facilities and infrastructure. These same opportunities are not possible in the A12 Corridor considering the higher impact on existing services and lack of contained land to provide for similar development numbers". WHPC strongly challenge this statement. The A127 Corridor is not, as noted within these representations, readily bound, with cross border authorities a material threat to urban sprawl. The scale of development proposed within the A127 Corridor is not supported by existing infrastructure, and the ability to upgrade it to support the proposed level of development is questionable. In particular, the A127 is bounded by housing along its duration, and is significantly closer to the Dartford Crossing and A13 which create regular traffic problems for the local area. WHPC also note that expansion of the A127/M25 in the context of the proposed development is not supported by Essex County Council or Highways England.

Object

Representation ID: 15917

Received: 12/05/2016

Respondent: West Horndon Parish Council

Para 7.10 of the Draft Local Plan states that "Land around West Horndon village remains a reasonable alternative because it can provide for similar development numbers forwards local needs". WHPC strongly challenge this statement. As set out above, it was recognised in prior consultations that the flood risk around West Horndon village creates significant issues when considering larger scale development around the village. The flood issues are also clearly stated in the Draft Local Plan (10.68). Previous consultations also rightly highlighted increased deliverability challenges should development be focused on West Horndon village. The village is already assumed to support 500 houses. If all development is concentrated on the village these houses' deliverability becomes more challenging, and viability clearly reduces.

Comment

Representation ID: 15918

Received: 12/05/2016

Respondent: West Horndon Parish Council

The proposed Dunton Hills Garden Village would be located on the Brentwood/Basildon border. Whilst Brentwood and Basildon Borough Councils jointly consulted on Dunton Garden Suburb in January 2015, Brentwood have decided to take their portion of the potential development forwards separately. This is despite the emerging Basildon Borough Council Local Development Plan incorporating the "Dunton Extension" which would see at least 5.5ha of land west of Basildon allocated for mixed use development.
Whilst separating the two developments may in theory improve deliverability, it raises serious concerns around sustainability when the total area is considered together. Brentwood Borough Council must work with Basildon Borough Council to ensure that any development within and around the border is developed holistically, with sufficient infrastructure provided.

Comment

Representation ID: 15919

Received: 12/05/2016

Respondent: West Horndon Parish Council

The scale of development proposed for the A127 Corridor creates material infrastructure improvements necessary, in particular, upgrading of the A127, A128 and other local roads. WHPC would question whether BBC have actively brought Essex County Council and Highways England in to pre-plan discussions, as previous consultation responses would imply some contradictory views, in particular around road upgrade plans.

Object

Representation ID: 15920

Received: 12/05/2016

Respondent: West Horndon Parish Council

WHPC strongly believe that any development within the Borough or indeed, Parish, needs to be undertaken on a sustainable basis. SO3 states that BBC will "plan for housing that meets the needs of the Borough's population and contributes to creating inclusive, balanced, sustainable communities". WHPC note that given the scale of development proposed within West Horndon village, this is essential for our community. Any development needs to provide a range and balance of different housing types, that complement the existing village and help create a dynamic and stable community. Simply providing houses/flats for commuters would not achieve this - whilst this type of housing might help balance out Brentwood Borough as a whole, it would create an unsustainable and unbalanced community within West Horndon. A good mix of housing types will be required.