brentwood.gov.uk

The Pre-Submission Document relies very heavily on the Dunton Hills Strategic Allocation. If it were not accepted, or only partially accepted, a review of all the Plan's allocations would be needed and alternatives, like our client's site at Pilgrims Hatch, be reconsidered to make up the deficit.

Figure 4.2 sets out a total net new homes requirement of 7800 of which 6100 will be met on new land allocations. One strategic allocation, Dunton Hills Garden Village, accounts for 2700 or 44% of the total allocations. The Plan is therefore heavily dependent on the ability of this site to deliver within what remains of the Plan period, which is 12 years.
The Document's Appendix 1: Local Development Plan Housing Trajectory, notes a potential delivery start in 2022/23. This means the allocation will need to deliver 2700 homes over a nine year period, an annual build rate of 300, around the build rate for the whole District predicted during the Plan's first six years.
The 2018 consultation on the Preferred Sites Document said that delivery at Dunton Hills would start by 2021/2022. 2500 homes would be delivered over 10 years, a build rate of 250 per year.
The logical conclusion is that the longer it takes for the emerging Local Plan to be adopted, the shorter the time and the higher the build rate will need to be. The LDP Timetable suggests that adoption will be in Quarter 3 of this year. We believe adoption will more likely happen in Quarter 1 next year or beyond. This will squeeze delivery at Dunton Hills into an eight-year period with a resulting annual build rate requirement of nearly 340.
In commenting on the Preferred Sites Document in 2018, we referred to research carried out by Nathaniel Lichfield and Partnership on delivery from large housing sites. Their report calculated the average planning approval time for sites of 2000 or more dwellings was 6.1 years. The 'planning approval period' was calculated as the time between the validation date of the first application for the proposed development to the decision date of the first detailed application which permits the development of dwellings on site.
We believe the Local Development Plan Housing Trajectory's figures for Dunton Hills Garden Village are based more on wish fulfillment, rather than solid evidence of achievable build rates.
The Dunton Hills Garden Village proposal remains locally controversial. A number of local newspaper articles, published during 2018, highlight opposition to the proposal from two neighbouring Local Planning Authorities: Basildon Borough Council and Thurrock District Council.
Your Thurrock in an article dated 29 October 2018 quotes Thurrock as saying :
"The location does not have any public transport such as a railway station or other infrastructure or services compared to existing settlements", adding that the development will have "a much greater negative impact on the landscape than stated".
The same article quotes Basildon Borough Council as follows:
"The proposals in Basildon and Brentwood Boroughs could, without careful planning and site allocation choices, lead to settlement coalescence and inadequate access to appropriate infrastructure, which in turn could have implications on the amount of development that can be brought forward in this location on both sides of the boundary."
Basildon's website says that Dunton Garden Suburb:
"... was a potential cross-boundary development opportunity to the west of Laindon (Basildon Borough) and east of West Horndon (Brentwood Borough) for 4,000 to 6,000 homes."
It goes on to say:
"On 4 November 2014, Basildon Borough Council and Brentwood Borough Council each signed a Memorandum of Understanding (MOU) setting out the terms and conditions for the joint project to explore Dunton Garden Suburb in accordance with Section 110 of the Localism Act 2011, also referred to as the Duty to Cooperate. It expired on 4 February 2016 and has not been renewed."
Brentwood Borough Council's Dunton Hills webpage makes no reference to the expiration of the MOU, neither does it record any further progress with the project following January 2018's Preferred Sites consultation. CEG is the company promoting the Dunton Hills project; their website relating to the proposal is currently a holding page.
The Emerging Basildon Local Plan shows no proposals relating to the Dunton Hills project on its side of the border. Instead it shows the whole area as Metropolitan Green Belt land.
All the above indicates that there has been a lack of cross-border cooperation on the Dunton Hills proposed land allocation since 2016.
We believe both the quantity and timing of new housing delivery from this site, set out in the Pre-Submission Document, are not soundly based. Furthermore we believe the whole project is now mired in a controversy that involves two of the Borough's local authority neighbours. This must cast doubt on whether the Duty to Cooperate has been fully followed. Therefore at present the whole project is surely in jeopardy.