Monday, 5 November 2018

Basildon Local Plan Final Consultation - Tips

Basildon Council has launched its final public consultation on its Revised Publication Local Plan. You can submit comments by letter, e-mail or using the online consultation portal. To do so, follow the instructions at

You have until 17th December 2018. This is the last chance to have your say.

I am a campaigner asking for housing numbers to be kept proportionate with real provision for affordable housing and infrastructure first. Whether you agree or not I encourage you to contribute to the consultation.

Here are my answers to questions you may have.

What is the Basildon Local Plan?

The Local Plan is a document prepared by council planning officers under the direction of elected Councillors. It covers the whole borough of Basildon including Basildon, Billericay, Wickford and smaller settlements. Its purpose is to set housing and development targets, and planning rules until the year 2034.

Why should I contribute to this consultation when we already commented on earlier consultations?

There have been a number of public consultations since 2014 which have been used to inform the preparation of the Local Plan, but this one is different. Previously comments have been given to the council who respond and act as they consider appropriate. This time the comments will be submitted to the ministry of housing who will assign an independent planning inspector to look at the comments. He has powers to override what the council has done. This is the last chance to have our views taken seriously and without cost.

How else is this consultation different?

This consultation is a technical consultation on the soundness and legality of the Local Plan and other supplementary documents. If you are objecting you will need to say whether you consider the plan to be unlawful or unsound, and if unsound you need to state that it is not (1) Positively prepared, (2) Justified, (3) Effective or (4) Consistent with national Policy. 

You will also need to say which section of the Local Plan you are objecting to.

Do not be put off if you are not familiar with these technicalities. Just pick which case seems most relevant and describe your objection in the comment.

What if I have more than one thing to say?

You can submit any number of comments aka representations. If you are using the online portal you complete the form for each one and then click on the button "save as draft" You can then go back to the beginning and fill in the forms again for a second representation and save that. 

For each representation you should state whether the plan is legal and/or sound and why. This should be stated with respect to each representation. E.g. you may for one representation you may say that it is not legally compliant but it is sound and then comment on the illegality. Then for another representation you can say that it is legal but not unsound because it is unjustified and give the reason for that.

When comments are saved as draft you can go back to them and edit. Once you have them all done you must submit them using the submit button. After a comment is submitted it cannot be edited or deleted, but you can go back to the start and add more representations.

What will happen after the consultation?

Basildon council will collate all comments and submit them to the secretary of state along with all the relevant documents and evidence. They cannot change the Local Plan at this point without going back to repeat the consultation from scratch. However, they can submit proposed modification of their own to be considered.

The ministry of housing will then assign a planning inspector to check the Local Plan taking into account all the comments. He/she will then make a judgement on whether the Local Plan is sound and legal. 

If the inspector does not agree that it is sound or legal he will try to suggest modifications to fix it, or he may ask the council to propose modifications. The inspector will be keen to try to deal with problems rather than rejecting the plan. However, if there is any problem that cannot be fixed the council will be asked to withdraw the plan to go back and rethink it. That would be a long and costly process. If the plan can be fixed quickly the inspector will draw up a list of required modifications which will then be subjected to one last public consultation. This is what usually happens.

Once that is done the Local Plan can be adopted by the council by a vote of Councillors. 

Do I need to appear at the public examination?

The online form asks if you wish to participate at the public examination conducted by the Planning Inspector. If you say yes then you may be given a chance to talk at the hearing. This is not necessary but if anyone makes a point contradicting what you have said this would give you a chance to respond.

The examinations will probably take place during normal working hours so if you wish to participate you will need to be able to make yourself available by taking time off work if necessary. It is unlikely that the inspector will arrange meetings for your convenience. You may only know when you are required to participate at short notice, and you may need to hear what is said in days before then. 

Can you draft comments for people to submit?

There is no point in copying comments written by other people. The inspector will consider them as the same. The consultation is not a democratic vote but the inspector may be impressed by a large number of representations so long as people are thinking for themselves and using their own words. 

What kind of things can we say?

You can say anything that concerns you, but see next question. Anything can be made to fit the parameters of soundness and legality.

You may here someone from the council say that this consultation is not about individual sites. That is nonsense. You can be sure that developers who have had their site excluded will be making representations about those sites so you can do the same about the ones that are included.

Likely topics are use of green belt, affordable housing, flood risk, lack of infrastructure, roads, schools, hospitals, pollution, wildlife etc.

What should we not say?

Do not complain that development will reduce your house price. It is a major objective of the government to make homes more affordable by building more so this complaint will backfire. An exception is if your home will be directly blighted e.g. by a road passing next to your boundary.

By careful not to say anything that might be considered discriminatory. You need to be particularly careful with comments about travellers. Do not imply that they are all undesirables. You should refer to the government or council traveller policy instead. You should also not suggest that development would attract the wrong class of people, or anything else of that sort. 

Don't suggest that houses planned near you should go somewhere else in the borough. Every community is under strain, and caring only about your own neighbourhood will just make you look like a NIMBY. It is right that you may want to focus on your own area because you know it better and care about it more, but the whole borough will suffer from the strain of new housing all around. We need to stick together to fight over-development.

Do not make your comments political. The political stage of the process is over and the inspector is only interested in legality and soundness.

In general, avoid any kind of polemics or insults. If you are not careful your comments can easily be disqualified altogether. Just be factual. 

Finally, include all necessary detail but avoid any unnecessary detail. The inspector will have a lot to check through and will appreciate concise bullet points. Make your main points as quickly and clearly as possible. If you need to make a very long and complex point then prepare a separate document to attach as supporting evidence, then make the main point of your representation in the comment space with reference to the longer document for details and evidence. If you seem like someone who can make your case without being long-winded there is also a better chance that you will be asked to participate at the hearing.

Any other tips on comments?

Think about what the main counter arguments are to any point you are making. Say why those are not the case. You wont get a chance for a long dialog so you need to cover everything up front.

If you are not sure, look at previous consultations and the responses given by the council in the documents called "Statement of Consultation." Think about how you can make your point better so that those responses will not apply. 

Try to use evidence. If the council's evidence base is not enough look elsewhere. You can link to newspaper reports. You can take snapshots from google traffic. You can get stats from rightmove. You can take your own photographs provided they make a relevant point. Google will find you reports about the A127 or Basildon Hospital or other relevant issues which the council does not want you to draw attention to.

However, do not get bogged down trying to make your comment perfect. If you are short of time and knowledge, just say what you want to say and leave it at that.

What is the relevant legislation?

If you are making the case that something in the plan is not legal you may want to clarify by citing the relevant legislation such as:

For legislation related to wildlife see

What about Soundness?

Soundness is about how the Local Plan complies with national planning policy. The relevant documents are

for more policy and legislation links see 

Where is the council's evidence base?

Which development sites should we worry about?

In addition to the sites marked for development in the Local Plan, any site that has been considered before is still a concern. Many of the developers and land owners who proposed these sites will submit comments to the consultation to suggest that they should be added back in by the planning inspector to make up the council's unmet need for housing.

This map shows green belt sites that are in the Local Plan in green and most of the sites that were not included in yellow. If you are concerned about any of these sites who should submit comments to say why it should be excluded. If your site of concern is shown in green you should say that the Local Plan is unsound because it is not justified. If it is shown in yellow you should say that the plan is sound without it included, but it would become unsound if it was added back in.

click on map to enlarge
There is an interactive version of this map at

Does the planning inspector have to let us speak if we make a representation?

Under the Planning and Compulsory Purchase Act 2004, section 20 (6) "Any person who makes representations seeking to change a development plan document must (if he so requests) be given the opportunity to appear before and be heard by the person carrying out the examination."

So, yes, if you propose a specific change and ask to contribute to the hearing on your representation to the consultation, the inspector must give you the opportunity to appear at the examination.

This is useful in case someone makes a point against your proposal.

Does Basildon actually need a new Local Plan?

Some people say Basildon would be better without a new Local Plan because its green belt would be protected. The trouble is that an up-to-date Local Plan is a legal requirement and the ministry of housing has very broad powers to step in if the council does not prepare one. Basildon council was one of 15 put on watch for not doing enough. They narrowly missed being taken onto the next step as Castle Point has been.

If the secretary of state did intervene they government would appoint Essex County Council to implement our Local Plan. ECC are very pro-development and have little care for the green belt in South Essex. They want high levels of development to raise money for the infrastructure they are responsible for. They could order the borough to release land for all of its own assessed need plus extra for London and Southend which do not have the capacity or will to meet their own needs.

The government are reluctant to intervene because they are concerned about votes. Some people claim they would never intervene for this reason, but they can easily avoid electoral losses by passing the blame for unpopular outcomes onto the authority they assign to implement it. Intervention is no idle threat. The government are keen to make an example of one or two councils in order to encourage others to get on with their Local Plans. It would be wise to avoid becoming one of those examples.

Why don't Councillors defy the government and protect our green belt?

Because not enough residents are telling them that this is what they want. To make that happen we need a large proportion of the local population to respond to consultations like this one. Then we need people to stand as independent Councillors and we need people to vote for them. We also need people to stop voting for a government that wants this. Defying the government is a huge financial risk for the council so it can only be done if there is overwhelming support from the electorate.

Any final tips?

If the consultation seems complicated and technical but you have something you want to say, don't worry about the technicalities. Just submit your comment using common sense to fill in the form in the way that seems best. 

Thursday, 20 September 2018

New government housing stats show that a lot less houses are needed than planned.

This morning the Office for National Statistics has published new housing projections that show only 159,000 new homes per year will be required in England compared to 210,000 per year as previously predicted two years ago. The contrast between reality and the government ambition to build 300,000 homes per year is now more glaring than ever. So much so that you would think even the journalists used to feeding off government press releases would start to ask questions. The only way government targets could be achieved would be to increase demand for housing by doubling inward net migration, but don't count on anyone listening to reason.

The ONS says the changes in their projections are due to lower estimates for birth rates, life expectancy and net international migration. It could be argued that even now these inputs are too high and further downward adjustments can be expected in the future, but the government sees things differently. They have already announced that they plan to fudge the standard formula for housing targets to compensate for the drop.

migration is the biggest source of uncertainty in the projections

Why do they want to plan for a surplus of houses? Nobody seems to know, or even ask. Do they want to accelerate the influx of international migrants in the belief that it will solve the national debt crisis, or is it simply a plan to give the lobbying property industry the land they need to make big profits on, so that they can continue to make big donations to the government? Whatever the answer is they obviously won't tell us. Do they think we won't understand or are they afraid we will? Instead we get spin about the housing crisis and how they will protect the green belt, provide gleaming new infrastructure and reduce net migration. Why would anyone swallow such utter nonsense now?

The new numbers out today tell us the number of houses projected to be built in each district or borough in England. These can also be plugged into the government's standard formula which applies an uplift based on affordability ratios to give the "Local Housing Need." This is the number that local authorities are required to use as housing targets in their 20 year Local Plans. However, the government has already said that they want to adjust this number upwards to compensate for the fall. In some councils the fall is less than elsewhere so those councils could end up with significantly higher targets. We don't know yet how they will make the adjustment so the adjusted target can only be guessed at.

new projected old target new target new plus 24%
Southend-on-Sea 11308 23553 15711 19482
Thurrock 10236 23378 14075 17452
Basildon 14158 21600 19892 24666
Braintree 10142 16974 13628 16899
Brentwood 4894 9399 7105 8811
Castle Point 4568 7446 6738 8355
Chelmsford 11110 19514 16234 20131
Colchester 18624 21376 24316 30152
Epping Forest 9434 22166 15619 19368
Harlow 4524 9353 5955 7384
Maldon 4438 6075 6291 7801
Rochford 5362 7782 8043 9973
Tendring 14400 16757 18855 23380
Uttlesford 9040 16380 14334 17774

The table above shows the new projected household growth over 20 years for Local Authorities in Essex, the old target from 2014-based projections with uplift, and the new target from 2016-based projections with uplift. The last column shows how much the target would increase if the government simply uplifted by a further 24% to compensate for the drop, but we do not know what they will actually do.

Some councils will see a dramatic drop in targets, e.g. Southend, Thurrock, Epping Forest and Harlow. Thurrock in particular will find the new numbers hard to reconcile with their stated ambition to build 32,000 homes. Other councils are likely to see a big rise, e.g. Basildon, Castle Point, Colchester and Tendring.

The ministry for housing has already said that it will apply an exceptional uplift in Oxfordshire and it is possible that other places where the numbers have dropped dramatically will be treated the same, although it is hard to see why this is necessary given that these targets are described as minimums.

It is going to take a little while for the government to form a scheme for fudging the numbers upwards. There will need to be yet another public consultation. Meanwhile the Local Housing Need across the six ASELA councils in has dropped from 96,000 to 71,500 which is going to have implications for the scale of the South Essex Joint Strategic Plan.

Already we have seen a huge amount of misinformation from planning consultants about how the new numbers should be interpreted. It will be interesting to see if this is reflected by politicians and the media.

Saturday, 15 September 2018

BREAKING NEWS - Basildon to build Northern urban extension with new realigned A127 route.

At a Basildon Council meeting last Thursday the chairman Cllr Richard Moore revealed emerging plans for a realigned A127 to the North of Basildon supported by the development of thousands of additional new houses on green belt along the route. The announcement was made so quietly that it appeared to go over the heads of other Councillors on the committee. Even the planning officers in attendance did not seem to twig what it meant. 

Earlier this year six South Essex local authorities including Basildon formed an association (ASELA) to put together a Joint Strategic Plan for the region. Cllr Moore is Basildon's representative on the secretive Joint Strategic Plan Members Group which is working behind the scenes to allocate strategic locations for extra housing development. This is rumoured to included at least three new Garden Communities in South Essex which would provide additional housing to that already designated in Local Plans.

Moore is also chairman of Basildon's Strategic Planning and Infrastructure Committee which has been making a number of final revisions to the Basildon Local Plan this year. They have already made a number of revisions promised by the Tory administration after being elected in May, but in August they did a U-turn on their commitments to incorporate the Hovefields and Honiley Neighbourhood Plan into the Local Plan, deciding instead to allow it to return at the next plan review. It now appears that there may have been a hidden reason behind this.

A potential new route for the A127

On Thursday the committee was reviewing potential development sites to make sure there were sound reason to exclude each one from the Local Plan which has a deficit of development against the borough's assessed housing need. Towards the end of the five hour marathon meeting he surprised everyone by suddenly suggesting that sites around Dale Farm and Hovefields should be designated as a "broad location for housing growth." Reading a prepared statement he explained that they "need to be aware of work underway on the Joint Strategic Plan and the implications the development may have for bringing forward improvements and realignment of the A127." This could then be brought forward at the first review of the Local Plan which would be due in five years time, he explained. In fact a review could happen much earlier because of unmet need for housing.

The full implications of this idea seemed lost on others present. To be honest I didn't catch it myself until a replayed the webcast recording later. The measure  was duly voted through by the three Tory Councillors on the committee. 

The A127 is a strategic route through South Essex and is crucial infrastructure for the promotion of housing growth. Unfortunately it was de-trunked in 1997, taking responsibility for its upkeep away from central government and into the hands of Essex County Council. Since then it has seen little improvement and is now a low grade two-lane dual carriageway taking the kind of traffic levels that would normally justify a three lane motorway. Plans to upgrade it are hampered by housing on either side in Basildon. The Fortune of War "roundabout" in the middle of this stretch is a particular symbol of failure to maintain the road. No longer needed as a junction it remains as an obstacle on the route and the scene of several fatal accidents. The A127 also divides housing to the North from the main town and the area is a notorious location for unauthorised traveller sites.

The only real solution would be to create a new route for the A127 which could run through partly undeveloped land about half a mile to the North, but this would be hugely expensive and would require the loss of more green belt land. It should come as no surprise that the Joint Strategic Plan for South Essex could include this idea, but to make it possible without government funding a lot of new houses would have to be built.

Conveniently the government has recently invited new submissions for plans to form new Garden Communities which can include transformational urban extensions as well as isolated new towns. The deadline for submission is 9th November and it is thought that ASELA will certainly not want to miss the opportunity to apply. South Essex already has one proposed garden village to the West of Basildon at Dunton Hills which has been the subject of strong community opposition. Other known proposals include a garden town in the West of Rochford and developments around Lakeside and South Ockendon in Thurrock. A proposal for something North of Basildon would make sense.

Such a plan would obviously be hugely controversial. An improved A127 and the prospect of finally resolving the long-standing problem of unauthorised development in the area would be welcomed, but to support and fund this there would have to be several thousand new homes in addition to those already in the Local Plan, all built on green field sites. Strong reactions would be inevitable.

The South Essex Joint Strategic Plan is due to be published for consultation in the Spring of 2019. Until then it seems residents will have to make do with guess work about what ASELA is up to.

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.