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. 

Friday, 4 March 2016

R.A.I.D. AGM 2016

The message at our AGM was that if you submitted a comment to the Dunton Garden Suburb consultation last year, you now need to copy it over to both the Brentwood and Basildon Draft Local Plan consultations. The submitted comments were of such high quality that the councils had no comeback. Instead they threw the joint consultation aside without the individual responses we were entitled to. Then they went right ahead and continued with plans for the development in two halves. Brentwood are now calling their half "Dunton Hills Garden Village" while Basildon refer to their part as simply "Policy H10". If we now submit the same comments again to both consultations they will have to respond. If you have time to edit them to fit the wording of the new draft plans that would be even better.

R.A.I.D (Residents Against Inappropriate Development) is now one year old, and the need for action is as strong as ever. In addition to hundreds of hectares of green belt under the threat of housing development we now have the Lower Thames Crossing with one of the route options passing within 200m of the Basildon Boundary. Our AGM attracted only about 40 people, suggesting that many residents here are either becoming complacent or are losing hope. We still can and must fight these developments. 

The up-side of having a smaller gathering at the meeting was that the audience participation was very good and many worthy points and questions were raised during the talks. The meeting was recorded so you can see it here if you missed out. Better still, come along to our second meeting on 16th March 8pm-10pm. This will be at Friern Manor in Dunton Village at the heart of the proposed development. Those of you who attended our meeting there last year will know what a luxurious venue it is. There is ample parking at the rear.

Link for Basildon Local Plan Consultation:
Link for Brentwood Local Plan Consultation:
Link for earlier comments on Dunton Garden Suburb consultation: 
Link for Thames Crossing Consultation:

Tuesday, 16 February 2016

Essex Councillor Bass on the "Luddite Community" opposed to the Thames Crossing

Cllr Rodney Bass had some strong words for campaigners in his response to a question posed by Cllr Walters at the Essex County Council meeting on 9th February.  Needless to say I do not agree with his interpretation, but people should know what is being said up at County Hall. Here is a transcript of what was said:

Cllr Walters: Cllr Bass you will have seen lately that there are a lot of delays on the crossing between Kent and Essex. Particularly we have had problems with the wind, there have been accidents and despite the improvements in the tolling system there continues to be very lengthy delays. Could you update me on what is happening with a proposed new crossing because it seems to me that it is stalled

Cllr Bass: I most certainly can, I do welcome the question in that quite recently the government has published a further options paper. It has asked for responses to that consultation by the 24th of March and it is focusing as its preferred route on option C in the original proposals but providing three variants that that option C route could take on the Essex side of the crossing, and we will want to talk particularly to the Thurrock Council and Basildon and Brentwood as to which of those options presents a potential good solution that would be acceptable to all. If we can't agree that, then I will strongly commend the governments preferred option which is kind of going through the middle of that. It is the shortest route and it is the one that they say is the easiest to deliver. That will require a new junction on the M25, that particular option, and it will be a junction 29a midway between junction 29 and junction 30, but the fact that Cllr Walters' question is so relevant is that that consultation is now underway. We are having discussions with our transport boards. I think already there is strong evidence that like Kent County Council there is a very strong preference for option C. In fact option C is the only option in town that is seriously capable of being delivered and that will deliver the necessary economic growth. So we will work on that. We will also liaise very strongly with our colleagues from Kent County Council who share our view, and don't forget Essex and Kent way back in 2011 originally promoted the idea of an additional Lower Thames Crossing. It is very important that we do that and finesse it. I know my colleagues cllr Bentley will be very strong in harnessing the business support for this because the days that are lost when disruption takes place to that crossing are absolutely appalling. You have only got to witness the last couple of days. Yesterday QE2 bridge shut for 11 hours. What you need is a resilient plan. You need a tunnel lower down. It should be a tunneled crossing which it will be at the option C. You can't do it any other way, and frankly the sooner some of the people who, if I may say are the Luddite community, who say that such an additional crossing is not required, or (ridiculing tone) "let's put one on the London side of the crossing",  are simply not accepting that this is a serious disruption to the business interests of Essex and indeed Kent and therefore we would urge the government to press ahead. I am convinced that they will press ahead, particularly if we can unite around that crossing, option C and probably the government's preferred route.