Attachment to the covering note from Jennifer Gale OJECTIONS TO THE BRENTWOOD LOCAL PLAN 2015-2030 VILLAGE OF WEST HORNDON AND ENVIRONS (Core Policy CP4) The village of West Horndon is an ancient and historic settlement. Its size is currently around 500 homes, with another 200 in outlying areas - a community of less than 1900 people. The current housing stock has evolved over 85-90 years (although there is a Victorian public house and station, and the ancient church of East Horndon - currently unused for worship - is a significant landmark) The Preferred Options document, published by Brentwood Borough Council, proposes a major development of 1500 houses on both brown site and Metropolitan Green Belt land; this development represents 43% of the entire allocation for Brentwood’s proposal for new homes, to be sited at one end of a tiny community. NPPF paragraph 120 states that: Planning policies “should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed” Planning policies and decisions should aim to: - avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development; - recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established; and - identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. (NPPF paragraph 123) - promote the retention and development of local services and community facilities in villages, such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship”. (NPPF, paragraph 28) and guard against the unnecessary loss of valued facilities and services, particularly where t his would reduce the community’s ability to meet its day-to-day needs” (paragraph 70) The Brentwood Borough Council Local Plan appears to contravene the National Planning Policy Framework (2012) for the following reasons. 1 Major Development and West Horndon (References: BBP, SO1; CP2, NPPF, para 120, DM1-4, 6, 9, 11, 13, 14, 17, 21, 23-29) Objections a) The development would triple the size of the village within a 15 year period, probably quadruple the number of residents, seriously damage the nature of the current “settlement identity” (NPPF, para 182), and not “take account of the different roles and character of different areas, promoting the vitality of our main urban areas . recognising the instrinsic character and beauty of the countryside and supporting thriving rural communities within it”. (NPPF, para 17). b) Because of the size of the proposed development (1500 homes), this would, in effect, create a saddle development, splitting the village in two and creating an “old” and “new” West Horndon; thus, this development will not “strengthen the village centre” (Ch 2, S1, para (b); S01; Justification, para 3.7), but actually divide it. The proposal would also undermine the current “settlement hierarchy and role of key settlements” (Policy CP2). c) The plan provides no details to support the proposed allocation of 1500 homes (which is almost 5 times the allocation in the plan proposed 2 years ago). d) Although there seems to have been a company required to put forward a scoping plan (Peter Brett Associates, BBCLP, para 2.30), there has been no consultation with the Parish Council, or indeed the residents, of West Horndon, between the proposals set out in 2011 (which were more restrained and sensible), and the current plan 2015-2030. e) That scoping plan seems simply to have been based on the fact there is a station and road links at West Horndon, but has been written without any in-depth assessment of the environment or the impact on the infrastructure or residents in the existing village. That scoping plan seems to have been accepted at face value, on what appeared to be feasible on paper, with no questioning or testing of the proposals. f) While the Plan makes reference to infrastructure, there is no detail of this (only that “an Infrastructure Delivery Plan is forthcoming”), and the council seems to have no idea of the scale of the infrastructure needed or the costs of such development. Such infrastructure would need to be installed in advance of any building because of the detrimental impact on the current village. Infrastructure would need to cover: traffic lights or a roundabout at the junction with the A128; new, improved slip roads (possibly off Childerditch Lane) onto the A127; new sewage and drainage facilities in the existing village; better traffic calming on Station Road; other exits out of the village apart from Station Road; new or enlarged school; better, larger health facilities; improved exit strategies for traffic leaving the proposed new site to reach the station or turn left over the railway bridge; strengthened railway bridges in West Horndon and Childerditch Lane to deal with vastly increased traffic and heavy vehicles leaving what remains of the industrial estate. 2. Flood Risk (References BBCLP, CP2, DM 32, 35, 36) The Environment Agency’s website shows that West Horndon (as well as the neighbouring village of Bulphan), is in a flood plain, at constant risk of flooding: it flooded in 1958, 1981 and as recently as Christmas 2012. 2 DM35 (Flood Risk} states that: “a. Proposals are located in the lowest appropriate flood risk zone with regard to guidance set in the Brentwood Strategic Flood Risk Assessment as part of the sequential test b. The development would not constrain the natural function of the flood plain, either by impeding flow or reducing storage capacity c. The development is constructed so as to remain operational even at times of flood through resistant and resilient design d. The applicant has contacted the sewerage provider to assess the capacity of the receiving foul sewer network and the need to contribute to any additional off site connections for the development” DM35 also states that “No new development is to be at risk from floods or to increase the risk of flooding.” Objections a) DM35, paragraph 4.160 states that “Areas at risk of fluvial flooding in the Borough are mainly rural, and include low lying areas south of the A127 west and east of West Horndon”. This contradicts what BBC has said in paragraph (c) of CP2 (“... areas where development should not take place . risk of flooding). b) Many houses in West Horndon, which have flooded in the past, have problems in obtaining household insurance. This would be the case for houses built on the buffer Green Belt land that currently protects the village from more serious flooding. c) Thorndon country park rises above the village, and water runs down from the hills towards the village. Water run off is a constant, and the north side of Childerditch Lane often has puddles even when there has been no rainfall for several days/weeks. d) Currently, the Green Belt land around the village and alongside the A127 acts as as soakaway (including development plot area 037), absorbing most of the moisture and preventing the village and the A127 from flooding more frequently. Any change in the water table will remove the soakaway, causing flooding on the A127 and in West Horndon itself, and certainly on 1000 new homes to be sited on the current Metropolitan Green Belt (area 037). e) There is a large lake in Thorndon Park, which has overflowed in the past. Although there is now a sluice to prevent this, in heavy rain the lake becomes very full. The culverts in West Horndon are suppose to prevent flooding from water flow and from the lake, but were blocked at Christmas 2012 - resulting in flooding in the village. f) DM32 states that “It is widely acknowledged that green infrastructure and open space has a major role to play in mitigating against and adapting to climate change, for example, urban cooling, encouraging sustainable travel choices and flood alleviation. Through the provision of green corridors the policy can help overcome habitat fragmentation and improve the ability of the natural. This paragraph would seem to suggest that, particularly in a flood plain, a “green corridor” would help to alleviate flooding: this argument is contrary to the BBC Local Plan proposal to take away some of that “green corridor” in West Horndon, which 3 currently alleviates flooding in the village. g) The water table in the village is fragile: sheds/outbuilding placed in the wrong area in back gardens (ie near to concrete foundations/concrete fence foundations) can result in constant flooding of gardens in heavy rainfall. Smaller gardens, and the foundations of houses placed too close together, will create heavily flooded gardens (which will overflow into the houses in heavy rainfall). A density of between 30-65 dwellings per hectare will increase the likelihood of homes on the new development flooding more frequently, and at higher water levels than have been experienced so far (because the current housing stock is further from the A127 than the proposed development). h) Significant infrastructure would be necessary to cope with such flooding (CP2, paragraph (e) “significant infrastructure requirements). However, any infrastructure to take the floodwater from the village (which would mean new culverts under the railway) will push the water towards Bulphan, moving flooding to another settlement. Bulphan is sited on a Fen (the lane parallel to the A127 which runs through Bulphan is called Fen Lane), which by its nature is land reclaimed and prone to flooding.