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Policy R01 (1) should be amended to reduce the overall amount of housing to be delivered at DHGV in the plan period. This needs to be more realistic with commencements of completions no earlier than 2025/2026, with a total delivery of 1950 in this period.
The Housing Trajectory at Appendix 1 also therefore requires modification for DHGV to remove the completion of dwellings in the period 2022/23 - 2025/26 which are considered to be unrealistic given the time necessary to resolve planning, land control and funding matters fully. The overall quantum should be reduced accordingly rather than further backloaded in the DHGV trajectory.
Other reasonable alternative sites (as identified in the Sustainability Appraisal), including LLLP's land interest at Honeypot Lane, Brentwood should be included within the Local Plan allocations to assist in meeting the housing requirements and acute shortage in the early part of the Plan period given the changes needed in total delivery and phasing trajectory for DHGV. Additional technical evidence, testing and evaluation of the DHGV proposals in terms of transport, community and green infrastructure requirements costs and funding, is required to support the Local Plan's proposed allocation of the site and to ensure that this is proposed on a comprehensive and realistic basis. Policy R01 (I) should be modified accordingly.

Policy R01 (I): Dunton Hills Garden Village Strategic Allocation and Appendix
1: Local Plan Housing Trajectory
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Policy R01 (I) Dunton Hills Garden Village
Strategic Allocation and also Appendix 1 Local Development Plan Housing
Trajectory.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Housing Delivery and Trajectory
4. Point B of Policy R01 (I) establishes that the Dunton Hills Garden Village (DHGV)
will provide 2,700 new homes in the plan period (some 35% of the total planned
housing provision) and an indicative overall capacity of some 4,000 homes in total
(the remainder beyond the current plan period).
5. Point D(a) of the same policy then states that delivery will be "at least" 2,700
dwellings in the plan period.
6. Appendix 1 of the Plan sets out the Local Plan housing trajectory which identifies a
total of 2,700 dwellings to be developed at DHGV in the plan period. The Housing
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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Trajectory proposes that 100 dwellings will be completed in 2022/23 with
development delivery rates ramping up significantly to 150, 250 and then 300
dwellings per annum (dpa) during the period from 2023/24 - 2032/33.
7. Paragraph 9.23 (iii) in establishing development principles, sets out that the
development of DHGV should be flexible to accommodate the likely progression
over a 20 year build-out period.
8. DHGV is a Green Belt, greenfield location. Any development therefore requires an
adopted Development Plan that includes release of the whole site area from Green
Belt as well as all of the necessary land control, funding and planning permissions
(outline and then reserved matters) together with requisite secured planning
obligations and contributions in order to proceed.
9. The development proposed and the community that would be created depends
entirely on new social, community and green infrastructure to be created.
Substantial new and enhanced highways and public transport infrastructure is
required given the chosen location for the Garden Village. There is evidently a
major programme of new infrastructure development necessary to ensure that the
resulting new settlement is in any way sustainable.
10. It is clear to LLLP that the planning and development of DHGV is a long-term
project and not a scheme that can be swiftly mobilised and construction completed
in the short term as the Council's assumptions concerning the delivery trajectory
propose.
11. In this context, LLLP raise significant concerns over the quantum of housing that is
intended to be provided within the plan period and the phasing of such delivery.
The total quantum of residential development proposed does not appear to be
realistic in the plan period with very substantial development rates identified each
year up to 2033.
12. The Housing Trajectory in Appendix 1 signals that there will be 100 residential
completions in 2022/23. To achieve this, the Local Plan will need to be adopted in
order to release the site from Green Belt, the DHGV masterplanning and
infrastructure testing and validation work completed and all necessary outline and
reserved matters permissions secured. Pre-commencement conditions will also
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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need to have been discharged, CIL payments made and relevant planning
obligations completed and implemented, including the negotiation and signing of a
S.106 Agreement.
13. Put simply, LLLP do not believe that there is a realistic prospect of any residential
dwellings being completed by 2022/23 and indeed would not anticipate that DHGV
will be sufficiently advanced to deliver housing in the following years until at least
2025/26.
14. There is therefore no likely or realistic contribution arising from new dwellings at
DHGV towards meeting the Borough's persistent and acute housing needs or in
remedying the lack of a five year housing land supply.
15. LLLP has, in previous representations on the emerging Local Plan, raised the
importance of ensuring that the Local Plan offers a choice and mix of housing sites
to enable delivery in the immediate and shorter term and reduce the risk of nonimplementation
of individual residential schemes while plans and work continues
to secure necessary consents for DHGV.
16. The removal of sites, such as LLLP's land interest at Honeypot Lane, Brentwood,
in favour of a greater quantum of housing growth at DHGV during the plan period
does not help achieve the choice and mix of housing sites necessary. In fact it
positively discriminates against such an outcome.
17. LLLP therefore object to the total proposed quantum and the identified phasing of
new residential development at DHGV as set out in Policy R01 (I) and at Appendix
1.
Infrastructure Dependency and Viability
18. DHGV is predicated on a substantial level of new transport, community, social and
green infrastructure. This is largely necessary because of the site's greenfield
location which is well away from existing settlements and facilities in Brentwood
Borough or in Basildon or Thurrock (with which the proposed site borders).
19. The full costs and infrastructure requirements are not specified in detail in the
Local Plan, but policy R01 (I) and R0 (II) set out a series of proposed development
and design aspirations, objectives and needs. The evidential basis confirming the
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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scale, extent and need for many of these requirements is not convincing (see
LLLP's separate representation concerning R01 (II)).
20. Furthermore, LLLP are concerned about the deliverability and viability of DHGV
with the potential infrastructure necessary to make the scheme sustainable.
21. The Local Plan Viability Assessment (October 2018) identifies an infrastructure
contribution cost of some £126m based on modelling of 3,500 dwellings rather
than the 2,700 dwellings proposed in the current Plan, but this assumes no
contribution arising/required from the Borough's Infrastructure Delivery Plan (IDP)
and the viability work was clearly undertaken prior to the Pre-Submission Plan's
specific policy requirements for DHGV. Indeed, the Viability Assessment notes
that further work is likely to be needed as the site specific costs and requirements
for DHGV are derived.
22. As LLLP's separate representation to policy R01 (II) concludes there needs to be
an updated, comprehensive viability analysis of the DHGV proposals including all
costs, site specific infrastructure requirements, CIL, S.106 obligations and
modelling of the effects of all of the proposed design and land use requirements
set out in the Local Plan, including those stated in Policy R01 (I) and R01 (II).
Sustainability
23. The location chosen to site the new settlement comprises greenfield, Green Belt
land that is unconnected to the existing pattern of settlements. It is, at its northern
boundary, adjacent to the A127 strategic road and to the south, adjacent to the
main Basildon rail line, but is not easily connected to either. It is some 1.6+ km
distant from West Horndon railway station and also separated from the centre of
Laindon in the west of Basildon Borough by existing countryside and agricultural
land including Dunton Hall and various farm buildings.
24. LLLP noted that there are no proposals in the emerging Basildon Borough Local
Plan: Revised Publication (October 2018) that includes any development or
proposed vehicular or public transport connection between the eastern edge of
DHGV and the Southfields and Laindon area in the west of Basildon Borough.
The DHGV site's location is therefore clearly unrelated to the existing and
proposed settlement pattern.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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25. The Local Plan Sustainability Appraisal (SA) has had to make a number of 'heroic'
assumptions in order to attempt to demonstrate that the DHGV proposals
represent the most appropriate reasonable development alternative.
26. It is suggested in the SA that the opportunity to achieve higher levels of
sustainability at DHGV are greater for a new greenfield settlement than
development in/adjacent to existing settlements because of the 'clean sheet' such
a site would afford.
27. In taking this approach the SA fails to properly consider that the existing settlement
hierarchy represents a sustainable pattern of land uses and activities with
appropriate infrastructure available now and with significant enhancements
capable of being made or indeed already committed during the lifetime of the Local
Plan (for example the opening of the new Queen Elizabeth Line connecting
Brentwood and Shenfield more closely with London and other centres).
28. LLLP concludes that DHGV only performs at a similar level to alternative
development locations in Brentwood, Shenfield or Ingatestone because of a heavy
reliance and emphasis in the SA appraisal on possible positive effects from
implementing aspirational design, environmental and transport ideas/measures
that are not yet adopted plan policies or from uncosted and untested new
infrastructure that seeks low carbon, high design quality, sustainable transport and
other measures.
29. There is no clear reason however why other development locations and sites in
and adjacent to Brentwood, Shenfield or Ingatestone cannot be as sustainable, or
indeed more so, than construction of a new settlement at a greenfield location in
the countryside where all infrastructure will have to be provided from scratch.
30. The SA is flawed in its analysis of the future sustainability performance of DHGV in
comparison with reasonable alternatives (section 9 of the Sustainability Appraisal),
including greater growth at Brentwood and other existing settlements. The SA
skews its assessment based on aspirational design ideas and measures for DHGV
that are not properly or fully evidenced and appears predicated towards
demonstrating that DHGV is a better option than a more balanced distribution of
growth at Brentwood and other settlements.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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Conclusions
31. LLLP object to Policy R01 (I) and to the Housing Trajectory set out in Appendix 1
of the Plan. The policy and the Appendix are not sound as they are not:
* Justified - the total quantum of housing propose for DHGV and the delivery
trajectory proposed are not realistic or justified by sufficient evidence to
demonstrate that such housing will be delivered in the plan period.
The Plan's SA does not adequately justify the allocation and development
of DHGV and is reliant upon untested or costed new infrastructure and
upon design principles and other measures that are aspirational but not
sufficiently tested to show that they are realistic and can be viably delivered
during the plan period.
* Effective - the emphasis in Policy R01 (II) and the Appendix 1 housing
trajectory on DHGV to provide 35% of the total planned housing delivery in
the plan period represents an over-reliance on this long term development
project. The Plan is at serious risk in failing to deliver sufficient housing
because of the reliance on the new settlement proposal. This is not an
effective policy or spatial strategy as it fails to ensure that there is a
sufficient choice and mix of housing land sites to meet acute short term
housing needs or redress the persistent shortfall in housing delivery.
The proposals for DHGV are not sufficiently developed to offer adequate
certainty that the new settlement is sustainable, deliverable or viable.
Proposals in Policy R01 (I) and R01 (II) are in many cases aspirational
ideas or measures and require a substantial level of additional evidential
work and testing to prove that they are deliverable in the context of NPPF
paragraph 16.
Modifications Required
32. Policy R01 (I) should be modified to reduce the overall quantum of housing to be
delivered at DHGV in the plan period. The overall reduction in quantum need to
reflect a more realistic development trajectory with commencement of completions
not earlier than 2025/26. A total delivery figure of some 1,950 dwellings for DHGV
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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in the later part of the plan period is a more realistic target (removing the 750
dwellings proposed to be completed in the period 2022/23 - 2025/26 as set out in
Appendix 1).
33. The Housing Trajectory at Appendix 1 also therefore requires modification for
DHGV to remove the completion of dwellings in the period 2022/23 - 2025/26
which are considered to be unrealistic given the time necessary to resolve
planning, land control and funding matters fully. The overall quantum should be
reduced accordingly rather than further backloaded in the DHGV trajectory.
34. Other reasonable alternative sites (as identified in the Sustainability Appraisal),
including LLLP's land interest at Honeypot Lane, Brentwood should be included
within the Local Plan allocations to assist in meeting the housing requirements and
acute shortage in the early part of the Plan period given the changes needed in
total delivery and phasing trajectory for DHGV.
35. Additional technical evidence, testing and evaluation of the DHGV proposals in
terms of transport, community and green infrastructure requirements costs and
funding, is required to support the Local Plan's proposed allocation of the site and
to ensure that this is proposed on a comprehensive and realistic basis. Policy R01
(I) should be modified accordingly.