brentwood.gov.uk

There needs to be prepared an updated, comprehensive viability analysis
of the DHGV proposals including all costs, site specific infrastructure requirements,
CIL 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), policy needs redrafting in light of evidence.

Representations for and on LaSalle Land Limited Partnership
Policy R01 (II): Spatial Design of Dunton Hills Garden Village
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 (II): Spatial Design of Dunton Hills
Garden Village.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. Policy R01 (II) is concerned with establishing design principles and requirements for
the proposed Dunton Hills Garden Village (DHGV).
Overall Consideration
5. Much of Policy R01 (II) appears, in LLLP's view, to be aspirational rather than well
founded policy direction based on clear testing and evidence of the needs and
impacts arising from the proposed development of DHGV.
6. It is appreciated that DHGV represents a major new settlement for the Borough,
however the scale and nature of the proposed scheme, even in outline, means that
there needs to be a greater level of precision and evidence set out to support the
design principles, land use mix and proposed infrastructure contained in draft policy
R01 (II).
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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Green Infrastructure Buffer/Wedge
7. Policy R01 (II) includes a requirement at Point C (f) for the creation of a:
"green infrastructure buffer/wedge on the eastern boundary with Basildon
Borough to achieve visual separation to help significantly improve the
landscape and habitat value thus reinforcing the beneficial purpose and use
of the Green Belt in that zone".
8. The purpose of the proposed green infrastructure buffer/wedge is unclear and the
justification for such infrastructure is not established in the Plan. LLLP are unclear
what the reinforcement of the "beneficial purpose and use of the Green Belt in that
zone" means or is intended.
9. In LLLP's view, it appears to be simply an attempt to maintain some separation of
DHGV from Laindon in Basildon Borough and thereby avoid, unsuccessfully, the
perceptual and physical coalescence of DHGV with an existing settlement contrary
to the purposes of the Green Belt.
10. The development of DHGV would include a very significant and adverse impact on
the existing landscape character and visual amenity of the area (including land
within Basildon Borough to the east and Thurrock to the south) due to the scales
and nature of the development proposed.
11. No evidence is presented in the draft Local Plan offering a comprehensive
understanding, evaluation or testing of the landscape or visual effects of the
development of DHGV.
12. The presence of a green wedge/buffer to the eastern boundary appears to be more
to screen and separate the proposed new settlement development from Basildon
Borough than as an integral component in a wider landscape strategy. Such a buffer
would not, of itself, serve to mitigate the potential landscape and visual harm arising
from such a substantial scale of new development in the countryside and on land in
the Green Belt.
13. The green infrastructure buffer/wedge therefore appears to be an unjustified
aspirational measure rather than a well-founded, evidenced requirement.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
14. LLLP is concerned that the proposed development of DHGV will give rise to very
substantial changes to landscape character and visual amenity and that the Plan
has not offered sufficient analysis or substantive evidence to justify why this is
appropriate or whether it is the most suitable choice to support the Borough's future
housing growth requirements.
Transport Impact Mitigations
15. Policy R01 (II) sets out at Point H that development of DHGV will be required to
mitigate any predicted transport impacts and that these should be monitored and reevaluated
throughout the lifespan of the build out.
16. The policy proposes various transport mitigations, which includes, new junctions to
access the site H(a); at H(b) the creation of a dedicated bus route connecting the
development with West Horndon Station, nearby employment locations and other
key social infrastructure; contributions to school bus services (H(c)); improvements
to West Horndon Station (H(d)) and plans for key connections to surrounding green
infrastructure destinations (H(e)).
17. LLLP are concerned that the transport impacts and proposed mitigations set out in
the policy, including the proposed dedicated bus route have not been effectively
tested and their delivery is uncertain.
18. The policy is not sufficiently clear as to whether a dedicated bus route would be
needed, although the lack of an on-site rail station or public transport hub is obvious
and the relatively remote and poorly connected location, some 1.6+ km distance
from DHGV to West Horndon Station (as the published West Horndon Interchange
& Southern Development Sites Plan (June 2018) shows) is a distinct limitation and
disincentive to the use of public transport.
19. Indeed, the need to contrive new dedicated bus and cycle links to West Horndon
Station indicates how poorly situated and remote the DHGV proposal is in relation
to existing settlements, employment centres and services/facilities.
20. Furthermore, LLLP are concerned that the costs of such transport infrastructure
development have not been properly identified and that there is no certainty of
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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securing the requisite land necessary to create a dedicated bus and cycle route from
DHGV to West Horndon.
21. As set out in policy R01 (II) the transport impact mitigation requirements are not, in
LLLP's view, sufficiently substantiated and do not appear to form part of a coherent,
tested transport strategy (including all of the necessary highways capacity and
impact modelling) in order to demonstrate that the DHGV will not have unreasonable
impacts in transport and highways terms.
Viability of Design Principles
22. There does not appear to be current viability assessment evidence available that
shows that DHGV will be a viable development incorporating all of the requirements
set out in Policy R01 (II) and including the requirements of the Council's published
Infrastructure Delivery Plan (IDP).
23. It is noted that a headline viability assessment of DHGV was undertaken as part of
the Local Plan Viability Assessment (October 2018) but this identifies that the IDP
was assumed to have a zero cost (paragraph 12.51) and the scheme size modelled
for DHGV was 3,500 dwellings rather larger than the 2,700 dwellings now proposed
in the Local Plan.
24. Indeed, the Local Plan Viability Assessment confirms at paragraph 12.75 that it is:
"premature to provide definitive advice as to the deliverability of the strategic
sites" (which include DHGV).
25. It continues, noting that:
"when the Council has completed the work assessing the strategic
infrastructure and mitigation requirements, it may be necessary to revisit the
analysis".
26. Put simply, there needs to be prepared an updated, comprehensive viability analysis
of the DHGV proposals including all costs, site specific infrastructure requirements,
CIL 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).
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
5
27. LLLP reserve the right to make further submissions with respect to viability of the
development and its design principles in due course.
Conclusions
28. LLLP object to policy R01 (II) for the reasons set out above. The design
requirements appear to be a mixture of aspiration and emerging ideas rather than a
set of tested, evidenced measures and policies to firmly guide the proposed Garden
Village. The result is a collection of thoughts and expectations for DHGV and LLLP
are concerned that the design proposals are not realistic and it cannot be
demonstrated that they are deliverable.
29. The policy as drafted is unsound as it is not:
* Justified - in terms of representing the most appropriate strategy and
underlying rationale for the design principles and development requirements
set out;
* Effective - in terms of clearly demonstrating that the design principles and
requirements for DHGV are needed, deliverable and viable.