Wednesday, 6 June 2018

Another Day in the Life of the Basildon Local Plan

A year ago when the UKIP/Labour/Independent administration took control of Basildon Council away from the Conservatives, a Local Plan prepared under the leadership of Phil Turner was on the table and almost ready for submission to the Secretary of State. The plan was never made public but based on what we have heard from Councillors it was a big step up in numbers from the Draft Local Plan that had been consulted on in 2016 with a target of 15,260 houses. The council had commissioned masterplans for South West Billericay, East Basildon and Gardiners Lane South. To support these changes the Conservative run council had held another public consultation to introduce "New and Alternative Sites." Many of these had been incorporated into the new plan. 

This included about 500 homes at the Pound Lane site in North Benfleet increasing the number of new homes for East Basildon from 2,000 to 2,537. The expanse of new sites proposed around South West Billericay had grown to enough land for 2000 additional homes to support a relief road that Essex County Council insisted had to be financed by developers (ECC are blowing their entire road and transport budget for the next decade on infrastructure to support the North Essex Joint Strategic Plan for Braintree, Colchester and Tendring.) There was also an expansion of the site at Thomkins Farm in Nethermayne to 600 homes and options for further development at Noak Bridge, Dale farm and Hovefields. 

The plan at that stage retained its claim that 255 new traveller and gypsy pitches were required with as many as possible accommodated on council owned sites at Wickford, South East Pitsea and Gardiner's Lane. Many more were to be added to the existing huge developments at Crays Hill, Hovefields and Cranfield Park as detailed in the 2015 Draft Local Plan. Implementation of this plan would have raised the borough's 20-year housing target to over 20,000 in keeping with rising numbers for the region's assessed development needs which the Basildon Tory  Group under Turner were keen to meet, despite a last minute promise to review the loss of green belt when they knew they were set to be kicked out.

Jump forward a year and things have moved on. Linda Allport-Hodge as chair of the Infrastructure Growth and Development committee oversaw a reduction of the housing target by 2000, removing some of the developments at the East and West of Basildon using the justification that these would result in coalescence with towns in neighbouring authorities. She also reduced the target for traveller pitches by nearly 200 down to just 56. Of course residents including many campaigners fail to appreciate this effort having not seen the unpublished 20,000 home plan they started from. Cllr Andrew Baggott played the standard opposition game of attacking the administration and promising to fix the plan with little regard for its real history. Such is the ignorance of his group that one of the few places where the actual numbers in the unpublished 2017 plan appear is in their own campaign literature where they accuse the opposition of setting a target of 20,000 homes rather than the reduced 18,000. In a leaflet currently being circulated for the Pitsea South East by-election they write of "The perverse decision to build traveller sites and 2500 homes between Eversley and Pitsea" despite the fact that this number of homes only ever appeared in their "East of Basildon High Level Development Framework" and the traveller pitches were put in by them in 2016.

Cllr Turner has been snubbed by his own party with no policy making role and Cllr Baggott as the replacement leader finds himself having to defend his election promises. The council has not started the pre-submission consultation that it had agreed to. Tomorrow an extraordinary council meeting will recind the council's approval of the Local Plan to reconsider a few of its policies. This is what I think of what they have announced in the meeting agenda:

"Reconsider the merits of including 300 homes in H18: South West Billericay, in addition to those recommended in the Higher Level Development Framework 2017"

300 homes were added to H18 to enable a longer route for the relief route. When this was reverted to avoid the loss of a corner of Frith Wood the 300 homes were left in. Removing them now may seem justified but people are forgetting that other homes were removed from sites around Billericay in the 2015 draft plan. Furthermore, the housing target is below the assessed need and any further reduction needs a solid justification on planning grounds.  From a residents point of view the fact that it is on green belt would seem sufficient reason but that is not likely to satisfy the planning inspector at examination. 

The meeting agenda was edited to include a mention of the rest of the South West Billericay development after members of the Billericay Action Group made it clear that a mere 300 homes reduction was not quite what they had been led to expect. As a campaigner I wish them luck, but I doubt it will be possible to remove these developments unless they move them somewhere else such as West Basildon. If they do that it will undermine the council's coalescence case for protecting the green belt and the inspector will be sure to restore all the developments at the examination while keeping the replacements too in order to meet the full need.

"Reconsider the merits of H10, in addition to H11 in Noak Bridge"

It's a little ambiguous whether they are aiming to remove both these close developments or just one. H10 was in their 2015 draft plan so they are probably looking to remove H11 which was part of their New and Alternative Sites consultation. It was included to enable a new primary school. Much as I would like to see this reduction I again think it will be difficult and the development will simply be restored later. At least these changes have the merit of being something that can be done more or less instantly with just the need to find convincing planning reasons. This is not the case for most of the rest of the changes.

"Reconsider the options for meeting the Borough’s Gypsy, Traveller and Travelling Showpeople 53 pitches and 3 plots need, including the ‘hub model’"

This is much more problematical. Nobody wants the new traveller sites proposed for developments in Wickford, Billericay and Pitsea, (even the travellers themselves would prefer a large site somewhere else, it is claimed), but there is strict legislation to comply with. The term ‘hub model’ was first heard at the IGD meeting when Cllr Baggott used it to refer to the policy in the 2016 draft plan which included adding pitches to the existing large traveller sites (as well as their three new sites of course) In a radio interview Cllr Baggott confirmed that he intends to consider returning to this. This problem is that this idea was conceived before a change in government policy made it clear that large sites in the green belt cannot be legal. Let's look at the three main site options:

Oak Lane, Crays Hill: Expanding the site here would effectively mean restoring Dale Farm to traveller occupation making the millions of pounds spent on eviction look like a huge waste of money. Traveller here have complained of unsanitary conditions and there is a lack of safe access to facilities in Basildon across the A127 where two travellers have died crossing the road in separate incidents. If the council authorised the enlargement of this site they would be responsible for ensuring that all facilities are adequately provided for at tax payers expense. Any new presence here would be bitterly opposed by long-suffering Crays Hill residents.

Hovefields: This was another site where the council engaged in expensive evictions and recently the council has fought in the courts to prevent further expansion on the site. Residents have worked on an alternative development plan to end the long-standing problems they face. Allowing expansion here now would open the door to another large influx of travellers who want to move in and would go against everything the council has been trying to achieve there.

Cranfield Park: This site just South of the A127 has attracted less attention except for a notorious recent murder case on the site and reports in national press on the extent of expansion here. It might seem like a better option than Hovefields or Oak Lane but it is next to a proposed new employment area and would be opposed by prospective new business owners who would otherwise like to move in. 

For all three sites the following serious problems need to be addressed: release of green belt to enable massive traveller sites, reversing previous policy to restrict site expansions, strong opposition from the settled community and the potential for further uncontrolled influx around these sites. A fourth option might be to build a new "garden ghetto" of 56 pitches somewhere else such as Dunton, but that would face the same issues and would require buying land from reluctant land owners. Whatever they consider will require months of report writing and evidence gathering which would certainly invoke government intervention for the Local Plan.

It is hard to know what Cllr Baggott is thinking of, other than he made a lot of noise about the (more sensible and legal) "fairy dust" model during the election campaign and now has to find some way of making good to Billericay residents. The chances are he will have to back down at some point and much damage may be done before he does.

"Reconsider the options for the Hovefields and Honiley Neighbourhood Area"

"Reconsiders the options for Bowers Gifford and North Benfleet Neighbourhood Area"

Neighbourhood plans can be progressed independently of the local plan so there is no need to delay its submission for these matters. There are reasons why the alternative sites in the neighbourhood plans were not already incorporated into the Local Plan. They would both contribute to the potential coalescence of communities that green belt is meant to prevent. Including them now would undermine the arguments used to restrict the borough's housing target on the grounds of the green belt constraint. Furthermore, neither Neighbourhood Plan is ready. Waiting for them would trigger government intervention. 

I'd like to see residents in these neighbourhood areas have their wishes taken into account but it makes much more sense to progress them independently and reconsider them again when the Local Plan is reviewed. I suspect that a review will be happening much sooner than the usual five years because of the unmet need and the "South Essex 2050 Ambition." Legislative changes in the pipline may even make it possible to activate the Neighbourhood plans without reviewing the Local Plan.

"Reconsider the options for housing development in Ramsden Bellhouse"

It is not clear what Cllr Baggott wants to reconsider concerning the 39 homes planned for this settlement but if he can address issues raised by local residents without undermining the spacial strategy or delaying the Local Plan further then all will be fine here.

"Reconsider the implications of its recommendations for i-iv on the potential soundness and legal compliance of the Plan and take steps to engage with other public bodies, as required and necessary, to discharge the Duty to Cooperate"

Note that they mean the six items i-vi as above but the agenda was illegally edited to add two of them and this typo remains. The Duty to Cooperate is being discharged through the Association of South Essex Local Authorities. The only thing which I think is missing is that other neighbours such as Chelmsford and Maldon were not formally notified of the unmet need, but I doubt that this is what Cllr Baggott is thinking about. If he does not take care he will commit us to looking at the unmet need from Southend, Castle Point and London in addition to our own. 

"Reconsider the options for the Community Infrastructure Levy Preliminary Draft Charging Schedule."

Again, I have no idea what they are thinking of doing here. I don't think residents have queried this. Have the developers had a word with the Conservatives or is this some idea of their own? We will no doubt find out soon enough.

In conclusion, Cllr Baggott has promised a serious redraft of the plan, but his initial intent was just to remove a few hundred homes, not much compared to the 2000 homes that UKIP/Labour removed from the Tory plan. If they could reduce the numbers further that would be great, but if it was possible the previous administration would have done it. The planning officers cannot submit a plan for examination that they do not consider sound and they have been informed by a planning inspector. Either Baggott will have to back down or he will remove development from one area and put it in another.

Whatever he does there is no sign that the Secretary of State has given him the go ahead to delay proceedings. I doubt Brokenshire regarded any intent to reduce the target as being consistent with Conservative policy either. Some of the proposed changes are just not possible. Others require a delay and might even lead to the need for a new round of consultations that would push the plan back even further. Any change to the schedule would trigger government intervention. Even the relatively simple changes such as removing 300 homes from Billericay will have consequences for the planning logic used to keep the loss of green belt down. 

I am left wondering whether this is being done more out of ignorance or arrogance. Does Cllr Baggott really believe his own bluster that the opposition did not know what they are doing? Will residents ever see through the Tory spin? I was optimistic that the years of campaigning we put in had done something to improve the Local Plan. Now I fear we are about to see it all go up in smoke at the hands of the Tories, voted in by residents we spent so much of our time trying to help, and aided by others who chose not to vote at all. Thanks a lot folks.

Having said that, I fear that our efforts are endangered in the longer term anyway. The six South Essex councils have hatched a plan to build even more houses in the area and Basildon is already signed up to it. They have even renamed their plan from "South Essex Vision 2050" to "South Essex 2050 Ambition" and it appears to know no limits. Their Statement of Common Ground seeks to add new Garden Communities on top of the 90,000 homes South Essex is struggling to accommodate. It's no surprise to see that the Brentwood Council Leader, Cllr Louise Mckinlay chairs the ASELA committee of what is now seven Tory Council Leaders. She is well known for her plan to dump Brentwood's housing need next to Basildon and will no doubt be looking to send more our way in order to protect the Northern parts of her own borough. In the longer term our present Local Plan will become a base onto which they will add more development when it is reviewed almost as soon as it is adopted.

Sadly the residents of our local communities are doing exactly what the government wants them to do. They blame local councils who are forced to follow central government policy that leaves them no choice but to plan for massive levels of development with no guarantee of infrastructure. Everything else you hear and believe is misleading spin coming down from the top. 

Sunday, 18 March 2018

Basildon Traveller Site Update

Two years ago I reported on the Traveller and Gypsy site allocations in the Draft Basildon Local Plan. At that time the plan preparation was under the political direction of the Conservative group who were running the council as a minority administration. The details of their plan were not clearly stated but by going through the documents carefully and counting up all the sites I was able to work out what they intended.

The conclusion was that they were planning for 98 to 109 new Traveller pitches in the borough. The total assessed need was for 240 pitches so this still left about 140 pitches worth of unmet need that they would have to ask neighbouring boroughs to help out with.

To accommodate the requirement there would be 15 pitches at a Gardiners Lane site that had been planned privately for some time. There would also be a new 15 pitch council site in Pitsea and a 10 pitch site in Wickford. The remaining 60 new pitches were to be added to the existing partially unauthorised sites at Oak Lane (Dale Farm), Hovefields and Cranfield Park. These sites are on green belt and are already well beyond the maximum 15 pitch size that is considered manageable according to government policy.

After writing the blogpost linked above, I asked a public question at full council. The government had published a revision of its traveller policy a few months earlier. It forbade traveller sites on green belt and instructed councils that they did not have to meet needs where there were large unauthorised sites. The new policy also modified the definitions so that travellers who settled at permanent sites and ceased to be nomadic no longer need to be counted in the assessment for pitches. I asked Conservative Councillor Richard Moore if the Local Plan was going to be revised to take account of these policy changes. He answered by telling me that a revised assessment was under way and would be published early that year. You can watch a recording of that here:

Time passed and the revised assessment remained unpublished. Basildon Council even helped kill the Castle Point Local Plan by saying that they had not cooperated over the unmet need for traveller pitches, despite the fact that this unmet need should never have existed if legal policies had been followed. 

Over a year later the opposition parties finally put aside their political differences and got together to take over control from the Conservatives. They began to run Basildon Council through a much more open committee system as a "rainbow alliance". Many good things have come out of this accord and one of them is a revision of the Draft Local Plan with a much more reasonable allocation of traveller pitches. The revised assessment for traveller needs has finally been published. It followed a prolonged Essex-wide survey that was probably unnecessary and was incomplete. The report split traveller needs according to those of the "nomadic travellers" and the "non-travelling travellers." Our council officers continued to argue that despite the explicit oxymoron "non-travelling travellers" should still be catered for because they have a "cultural need and right to culturally appropriate accommodation." This was justified by reference to the Equalities Act 2010, but the legislation only protects Romany Gypsies and Irish Travellers against discrimination. It says nothing about accommodation. In fact the phrase "culturally appropriate accommodation" can be traced back to the United Nations and their ill-informed attempts to stop Basildon Council evicting the travellers at Dale Farm.

Fortunately the new administration was having none of that and directed that the needs of non-travelling travellers should simply be added to the overall housing need so that they would be treated equally along with the rest of us. Taking into account the rest of the revised government policy the borough was left with a need for 53 new pitches. It's a big improvement on the 240 figure given under the Conservative administration, but it is still a struggle to meet.

To find sites the council officers looked again at the options. Sites could not be on green belt and had to have at most 15 pitches, so expansion of existing sites was no longer considered a possibility. New sites would therefore have to be included inside new developments on land released from the green belt in the Local Plan. The former site at Gardiners Lane was ruled out because after years of planning it turned out that there was a covenant on most of the land preventing the parking of caravans (very convenient for the developers.) Five other developments were determined to be big enough and suitable. This included the sites at Pitsea and Wickford from the earlier draft plan plus one more in Wickford, one in Billericay and one in Nethermayne near Vange golf course. Only four sites were needed to make up the numbers so Councillors voted to discount the former site at Wickford. This leaves a balanced distribution around Basildon, Wickford and Billericay. It should also be noted that West Basildon faces a double site of 30 pitches close by in Dunton Hills courtesy of Brentwood Council. I was one of the few residents present at the meeting where this was decided and I also witnessed the Conservative Councillors voting unsuccessfully to remove the traveller site in Billericay while leaving those in Wickford and Basildon.

My understanding on the nature of the proposed sites is that they will be assigned for long-term occupation as a base for travellers and gypsies who have caravans that they continue to use for touring. They will not be transit sites for temporary occupation, nor permanent sites for non-travelling travellers.

I know that many residents will still be upset about the allocation of pitches left in the plan. This is understandable given the history of illegal encampments in Basildon. However, the plan would be deemed unsound at public examination if less than 53 pitches were included. Submitting the Local Plan would then be just a waste of time and money. The main problem is with illegal and unauthorised sites both temporary and permanent. The government has been promising to review legislation but little has been done. Under the new administration this year the council has acted to tackle these problems as far as they are able to do so within the law. This has included the introduction of a legal injunction to prevent illegal encampments in the industrial area. If the courts allow, this could be extended to other areas as circumstances require. Action has also been ongoing against new unauthorised sites near Hovefield, but the legal process that must be followed is lengthy and restrictive. We all need to let the government know what we think about this.

In my opinion a significant part of the problem is legislation against hate speech which leaves organisation reluctant to speak out or prosecute. I do not believe that any minority is predisposed to illegal activity, but if a specific section of the community is allowed to break the law repeatedly with little fear of prosecution then there are always some who will take advantage. Travellers themselves are thus harmed by legislation that was intended to protect them. They are not the only minority to which this applies. Racist comments and incitement should rightfully be illegal, but genuine criticism and reporting of crime should not be caught in the same net. Until free speech is restored in this country the situation can only get worse.

In the last week we have seen a strong base of opposition to the traveller site at the location in Nethermayne. A meeting was organised by a Councillor and the developer of a proposed hotel near Vange golf course. Sadly some tough language was used at the subsequent meeting that several hundred people attended. I can understand the strong feelings but this kind of response generates more heat than light. Vange residents were told that the site had been moved from Wickford to Vange. This is simply not true. I was one of three residents at the meeting where this was decided and the proceedings were as described above. I also live-streamed the meeting to the "Basildon Political Discussion" facebook group where a recording can still be viewed or the minutes can be checked on the council website. It is perhaps worth also pointing out that given the location of the development the traveller site will be between 500 and 800 metres from the Hotel and it will not be on or next to the golf course.

Conservative Councillors have now been trying to whip up as many people as possible to attend the next IGD committee meeting where the final decisions on the local plan will be taken. It's good to have participation but any delay to the final preparation of the Local Plan will trigger the government to step in as they have threatened to do. This will probably result in many more houses being added to the Local Plan. The council has been forced to shell out a large sum of money to book the Basildon Sporting Village, disrupting the activities of our young sportspeople. The Towngate Theatre would have been a much more comfortable venue with better acoustics at lower cost and less disruption, but the Conservatives insisted that the Sporting Village will be the only place big enough. I think it will be hard to conduct the meeting there and it may end up being adjourned again. I urge residents not to let that happen. Trust me that it would not be a good result for the borough.

I don't want to discourage anyone from attending the meeting but as one of the few who has regularly been to earlier meetings of the committee I think there is a need to manage expectations. The meeting is not a public lecture. It is a council meeting held in public where a number of important decisions have to be taken. Council officers will brief the Councillors and answer their questions but there is a huge pile of documents providing background that the Councillors are familiar with from earlier briefings. The officers and Councillors will not have time to explain these background documents to the public as the meeting could continue for several hours even without doing so. I suggest that unless people want to speak themselves they will be better off at home watching the webcast than sitting on cold hard seats for several hours with limited opportunity to get up.  

It has been indicated that the public will be given an opportunity to speak for three minutes each. If you intend to do so I recommend that you prepare your words in advance and ensure that they can be delivered in that time. There will be a clock and you may be cut-off when the buzzer goes. If you are representing one of the many campaign groups that will want to have their say please coordinate with others in the group so that time is not wasted on repetition. This will help to ensure that everyone has time to contribute. Finally, these will not be question and answer sessions. Council Officers may address some of the points raised but the main point is to allow Councillors to listen to residents and decide in combination with the legal and professional advice they have on how they should vote.

Note that I am just a campaigner who has been closely following the preparation of the Local Plan. I am not any kind of council representative and the opinions expressed here are my own. No offence of any kind is intended towards travellers or anyone else. 

Thursday, 5 May 2016

Blog Introduction

This Dunton Garden Suburb blog is used by me (Philip Gibbs) to post non-political articles for the R.A.I.D campaign group (Residents Against Inappropriate Development) If you have facebook you can follow more news on our facebook group at

Our goals are to oppose inappropriate development of the green belt with special attention to areas in Brentwood, Basildon and Thurrock near our base of Langdon Hills

R.A.I.D aims to be a non-political group and welcomes comments and support from people and politicians of all political persuasions. Individuals like myself are entitled to their political views and if you want to read more about mine I have another blog for that at

Sunday, 20 March 2016

Flood risk from new housing developments

The risk of flooding caused by new developments is a serious issue, as witnessed recently in the North of England. There is increasing pressure to build on flood plains but that is not the only problem. All new developments on green field sites channel surface water rapidly into rivers instead of absorbing it into the ground and trees. This poses enormous flood risks to downstream settlements which developers will ignore if they are given half a chance. They can justify each individual small development by showing that it does not add significant risk itself, but overtime the accumulated impact of multiple developments builds up until an exceptional weather event causes severe flooding in towns elsewhere.

surface water risks around Dunton

This problem is particularly relevant in areas around Basildon where surface water drains into the Mardyke and Crouch rivers. Developments in Basildon and Billericay will be of great concern to residents of Ramsden Bellhouse and Wickford where the Crouch has come very near to bursting its banks this Winter.

Crouch near to flooding in Wickford January 2016
We need to include comments to the Basildon and Brentwood Local Plan consultations objecting to overdevelopment on the grounds of flood risk. Here as an example is my objection comment submitted to the Brentwood consultation:

Flood Risk
Development of Dunton Hills and West Horndon will pose a very high risk of flooding especially through its onward effect on the Mardyke River.
The Environment Agency flood map shows that the location for the development of Dunton Hills Garden Village is at a high risk of surface water flooding in several areas. It is a critical drainage area. This means that it presently absorbs large amounts of water including water that runs off from surrounding areas. Removal of trees and other vegetation will reduce the ability of the area to absorb rainfall. Rain that falls on roof tops and road surfaces will be quickly channelled through surface drains needed to prevent flooding in the new development area.
The altitude of the land is mostly around 40m. The A127 presents a barrier to drainage systems because it is at a lower altitude of about 20m. Therefore most of the surface water will have to be drained towards the South and West via the Mardyke tributary and into the Mardyke itself.
It will be necessary to take into account events of extreme rainfall when up to 50mm can fall in a period of 24 hours. At times of persistent rain that are common during the winter in this area this could continue over periods of several days. Rain falling on 250 hectares of developed land will have to be managed via the drainage system. SuDS will not be sufficient to mitigate the risk to the wider area along the Mardyke. This could amount to 100,000 m3  of extra rain water in a day. It is estimated that the Mardyke River has a typical capacity of 50,000 m3  per day and is already prone to flooding causing inundations around West Horndon and Tilbury.
The development of the Dunton Hills area will thus multiply by a significantly factor the amount of water entering an area that is already the scene of many past floods. Mitigation will require an extensive system of flood defences and pumping stations at enormous cost. This will have to be done before building starts and will require agreements between Thurrock and Essex that are likely to be difficult to reach agreement on. There is a danger therefore that development will go ahead without any new flood defenses and nothing will be done until the first major flooding event has already happened.
In my opinion the cost and uncertainty over the ability to control the flood risk makes the Dunton Hills Garden Village development unacceptable in its own right.

Friday, 18 March 2016

Energy in the Basildon Local Plan

Everyone thinks about the obvious areas for objection to the local plan: green belt, traffic, flooding, pollution etc., but how about energy? 

We tend to simply assume that electricity and gas will be supplied as usual from outside so there is little for us to worry about. It is not that simple. Planners are now obliged to take into account the carbon footprint of the community and aim to reduce CO2 emissions. Unfortunately Basildon planners seem to have gone completely mad and are ready to turn the borough into a huge experiment of unconventional renewable energy sources. Instead of simply advocating well insulated houses, rooftop solar panels and low-power LED street lighting as they should, they are instead promoting decentralised energy, and combined heat and power supply for large new developments such as the East and West Basildon extensions. Decentralised combined heat and power means generating electricity and hot water locally using biomass and waste burning plants and distributing it around the area using private cables and pipes!

They also seem to like the idea of solar farms despite the problems and loss of green belt that these have already caused and are looking at wind farms on places where they would do enormous harm to wildlife such as on the Vange and Pitsea marshes.

Areas considered suitable for windfarms
Their evidence base is described in an 80 page document produced last year "Basildon Borough Renewable and Low Carbon Energy Constraints and Opportunities Assessment" If you are concerned about the impact do have a look a this document and comment accordingly to the local plan consultation. For a quicker overview of what some of it might mean see the submission to the Dunton Garden Suburb consultation from KTI-energy

For the record, here is my submitted comment on the subject:

In policies H10 to H27 there is mention of the opportunity to make provision for decentralised energy. Paragraphs 11.96 and 11.134 indicate that there is potential to secure provision of decentralised facilities in locations of policies H10 and H13. Policy CC7 also mentions the possibility of combined heat and power plants. 

There is no evidence given for CHP or decentralised energy in the "Sustainability Appraisal including Strategic Environmental Assessment." The "Basildon Borough Renewable and Low Carbon Energy Constraints and Opportunities Assessment" describes some of the options but does not give sufficient evidence that large scale schemes are viable.

Decantralised CHP may be practical for limited use close to a source of heat but using a local power plant to supply areas as large as H10 or H13 would require exceptional evidence based on working examples. Areas of Basildon should not be turned into experiments for renewable energy. There are many potential problems with decentralised energy whether it comes in the form of electricity or heat. The custom power networks would have to be built at the cost of either the developer or the power supplier and would be passed on to consumers, or would subtract from the developers CLI.  Choice of energy supplier and the ability to switch is an important principle promoted by the government through Ofgem. A decentralised energy system in a community brings a risk of monopolistic opportunity for the supplier. There are also possibilities of unreliability in the power source and even 
the risk that the decentralised energy supplier could run into financial difficulty forcing the council to take over in order to ensure  the continued power supply. Power plants fueled by biomass and/or 
waste are of particlular concern due to the possibility of polution and the continuous HGV traffic supplying the plant. There are likely to be particular technical risks associated with heat supply over large areas using hot water because of the need for efficient insulation, pumping to raised levels and the likelihood of leaks as the infrastructure aged. Hot water is very corrosive.

Decentralised and CHP energy should therefore be removed from the local plan. A low carbon footprint can be achieved better with higher standards of house insulation and the use of low energy lighting such as LED. These things should be promoted in the plan instead.

I am concerned about the support for solar farms in section 15.70.  Solar farms are almost always placed on green belt land and are an obstacle to wildlife such as birds of prey. We have witnessed at the solar farm at Outward Farm that solar farm developers are irresponsible and do not keep to the conditions for construction imposed on them. When the farm reaches the end of its life it is likely that the land will be regarded as "previously developed" and will then be promoted for housing no matter what the original intention was. A much better policy would be to promote the placement of solar panels on the roof of new housing depending on the plot size of each property.

Wind farms in section 15.64 could be located in important environmental areas such as the Vange and Pitsea marshes. This is unacceptable because of the visual effect on the landscape and also because of the ground impact. Wind turbines are known to kill birds so they should never be allowed near important bird habitats such as these.

Thursday, 17 March 2016

"a garden village in each rural local authority"

Everybody is aware of yesterday's surprise budget announcement of a new sugar tax. The national press were kept occupied as Jamie Oliver turned up outside Westminster to praise the new health measure. You can be sure that the government would not miss such an opportunity to sneak in some less popular measures while everyone is looking the other way and they have indeed brought forward a true whopper.

There has long been talk of "garden cities" as a way to build more houses in England. Legislation was introduced a few years ago to help establish new developments of over 10,000 homes such as the one at Ebbsfleet. The train station was established there in 2007 but to the embarrassment of planners only a few houses have been built in the area alongside where 15,000 homes were envisaged. Nevertheless, the governments ambition to build more garden cities has never been buried.

When a deadline was set for planning authorities to submit their local plans by early next year it marked a point at which garden cities were likely to resurface. Some councils such as Basildon and Brentwood have been finding it hard to prepare their plans because they would have to build on green belt to meet the number of houses deemed to fulfill their "Objectively Assessed Need." Authorities such as Uttelsford and Maldon have lower assessed housing needs but more rural land not marked as green belt so they would be obvious targets for new garden cities if the government was looking for locations. If any new developments had been announced there too soon, it would have been an opportunity for Basildon and Brentwood to use the principle of Duty to Cooperate to reduce their own housing target and have those authorities take up their unmet need. The government does not want them to get off so lightly. It therefore seemed likely that any plans for garden cities were going to materialise after the local plan deadline.

With a faltering global economy and a possible Brexit on the horizon the government has grown impatient. They want to keep economic growth going at any cost but it is hard to increase productivity. A much easier way to sustain growth is to simply build more houses as more people come to Britain from abroad. This was the background to a budget announcement yesterday that was expected to be so unpopular that despite its huge significance it was not even mentioned in Osborne's budget speech.

In a document entitled "Locally-led garden villages, towns and cities" the earlier support for garden cities was extended to smaller developments starting from only 1500 houses. The "Locally-led" adjective is of course the usual spin since there is no chance that any community of residents would welcome such large projects in their area. What they really mean is that they will induce increasingly cash-strapped councils to accept the deal with financial incentives. The exact details have not been provided, but there is already an invitation for councils to propose projects by July, despite the fact that new legislation will need to be brought in. When are they planning to fit in the public consultation?

There are more conditions for eligibility. The settlements must be free-standing, so urban extensions will not do, and they must be for housing in excess of Objectively Assessed Need. This explicitly prohibits the possibility that other councils can count the new garden villages as part of their unmet housing need but at the same time it makes explicit the shocking fact that the government wants to build more houses than the country needs for its population according to current growth rates. This can only mean that they want to accelerate migration into the country, something very much against their stated policy to reduce net migration to under 100,000 individuals per year.

However, the most unsettling part of the policy is where it has come from. Lord Matthew Taylor (Baron Taylor of Giss Moor), a lib/dem peer has been campaigning for exactly this policy for the last year. He had been an MP for Truro in Cornwall until 2010 before being granted a life peerage. He was then appointed to review Planning Guidance despite controversy over a possible conflict of interest due to him being a paid director and shareholder of Mayfield Market Towns Limited and chair of the National housing Federation. In February 2015 he produced a report lobbying for government support of garden villages which also came out in support of progressively building on green belt in what he called a "green belt deal." The report said that "a single new garden village in each rural English local authority would create around a million extra homes"

While it is not technically wrongful for a peer to lobby government on behalf of commercial interests, what this does show is that the garden village policy has been directly led by the aspirations of property developers rather than communities. Sadly it is the clearest sign yet that the governments election pledges to protect the green belt and reduce net migration are no more than public relations spin.

Predictably, the national media have almost completely ignored this new government policy which has more potential to change the landscape of England than anything else seen for quite some time.

Monday, 14 March 2016

Brentwood Gypsy and Travellers policy

Traveller sites are always a big concern for local residents whenever they are proposed. Many people will just be tempted to say that they don't want any travellers in their neighbourhood because of the trouble they cause. Unfortunately such a response is not likely to carry much weight compared to planning legislation that requires travellers to be catered for. It may even be marked as discriminatory resulting in the comment being invalid. Any objection should therefore be based around legislation such as the recent  "Planning Policy for Traveller Sites" We can also argue against the evidence used to justify traveller policy and even produce evidence of our own, but it must be strictly factual.

As an indication, here is a copy of my representation which I have submitted to the Brentwood Draft Local Plan consultation (policy 7.10). If you don't wish to be so detailed, even a short comment indicating that you object is worthwhile. 

I strongly object to policy 7.10 for Gyspy and Traveller provision on the following grounds
(1) Paragraph 7.79 states that the policy is based on allocations specified in the Essex Gypsy, Traveller and Travelling Showpeople Accommodation Assessment prepared in July 2014 prior to the new Planning Policy for Traveller Sites (PPTS) published in August 2015. Section 2 of PPTS states that it must be taken into account in the preparation of development plans and this has not been done. The Accommodation Assessment and Policy 7.10 must therefore be revised from scratch and will require a new public consultation in line with regulation 18 to be conducted.
(2) Paragraph 7.79 states that there is a need for 59 new pitches by 2018 and that planning permission has been granted for 17. This means that provision for another 42 pitches is required by 2018. The only provision identified (paragraph 7.80) is sites for 6 pitches as shown in figure 7.5 and 20 pitches to be allocated within “Dunton Hills Garden Village”. Even if this development could be implemented within that timescale it leaves a shortfall of 16 pitches for the first five year pitch provision. The plan must state where these will go. It seems overly optimistic that windfall sites will meet this need before 2018.
(3)  Dunton Hills Garden Village is identified as a broad location for future provision with 20 pitches being allocated as part of this provision. A pitch can accommodate two caravans or chalets to cater for an extended family so 20 pitches could easily amount to about 100 individual travellers. The total need by 2033 is identified as 84 pitches with 23 on identified locations elsewhere. This implies that the total size of the traveller site at Dunton Hills Garden Village could be extended to 50 or even 60 pitches by 2033. The government document - Designing Gypsy and Traveller Sites, Good Practice Guide – says that 15 pitches is the maximum size of a site that could be considered manageable. A site of 20 to 60 pitches created for recognised ethnic minorities in order to keep them apart from existing communities is an act of ghettoization similar to schemes in Romania which have drawn wide international condemnation. 
(4) PPTS section 13 © states that policies must ensure that children can attend school on a regular basis. The nearest secondary school to any site at Dunton Hills will be in excess of two miles away making it difficult for traveller children to attend. The location should therefore be considered unsuitable
(5) PPTS secion 13 (g) states that traveller and gypsy sites must not be located in areas at risk of flooding. Flood Maps published by the environmental agency confirm that Dunton Hills is an area at Risk of Flooding from Surface Water. This is confirmed by frequent areas of standing water seen over much of the land at times of persistent rain. Once again this is therefore not a suitable location for traveller pitches.
(6) PPTS section 13 (e) states that the effect of noise and air quality on health must be considered. The A127 is an increasingly busy road producing a great deal of noise and air pollution. Caravans are not well insulated against noise or pollution so once again Dunton Hills is not a suitable location for travellers.

(7) PPTS Annex 1 section 1 defines “gypsies and travellers” to mean those of a nomadic habit who may only have ceased to travel temporarily. With such a large concentration of travellers it will be impossible to prevent them from settling permanently. Furthermore, no provision has been made in the form of transit sites for nomadic travellers so they may continue to use unauthorised sites for this purpose.