Policy 6.6 - Strategic Sites

Dunton Hills Garden Village - we note that the Council wishes to establish green links from this new development to the rest of Brentwood Borough. We request therefore that these green links are accessible to all - pedestrians, cyclists and equestrians - rather than just pedestrians and cyclists.

Brentwood Enterprise Park (Policies 101A and 101B) - we note the proposal to regularise and expand the employment-led development at the junction of the M25/A127 and request that this park is planned appropriately so that the existing bridleway network in this vicinity is protected; the current enforcement issues with regard to the bridleways in this area are regularised, and a safe crossing of both the M25 and A127 is provided as part of this development, linking the bridleway networks either side of the M25.

Policy 6.1 Sustainable Development

Policy 6.3 General Development Criteria, especially at (g) 'when considering the impact of development on the significance of a designated heritage asset, greater weight should be given to the assets conservation and enhancement'.

Policy 6.6 Strategic Sites and 7.1 Housing-Led policy (confirming a housing led scheme at Dunton Hills Garden Village of up to 2,500 dwellings).

Paragraph 6.32 confirms West Horndon is removed as a strategic allocation for growth to protect the village settlement.

Paragraph 7.1 mentions the use of master plans to agree the form, mix and siting of development.

Paragraph 7.35 notes that at Dunton Hills Garden Village that not all of the landholding will be developed.

Historic England Representations:

Historic England notes that the West Horndon village development area is not now a preferred option. This is consistent with the preferred options consultation (2015) where it was stated that only one of either West Hornton or Dunton would be pursued. Historic England then raised concerns about the cumulative impact and extent of urbanisation along the A127 corridor.

The interim sustainability appraisal (interim SA) to the current draft Local Plan consultation made the point at 14.1.1 that however, Historic England did not suggest outright objection to growth in this area ("an adequate buffer between West Horndon and Dunton would be expected") and concerns from 2015 may now be somewhat allayed, given that a comprehensive Dunton Garden Suburb scheme is no longer being actively considered as an option. A Dunton Hills Garden Village scheme might well impact on the setting of Dunton Hills farmhouse (grade II listed), however.


Historic England would also make reference to the sustainability appraisal for Dunton Garden Suburb Consultation (as produced by LUC and dated November 2014). We refer to this below in our representations.

The deletion of West Hornton is a significant change to the assessment of impacts. The impact upon the setting of historic assets within the site and outside the site are matters that require further detail. The setting of a heritage asset is defined in the glossary of the National Planning Policy Framework and National Planning Policy Guidance confirms that this may therefore be more extensive than curtilage. Historic England previously drew attention to this as it will be a significant material consideration in the assessment of impacts upon these heritage assets.

The NPPG states that 'The extent and importance of setting is often expressed by reference to visual considerations. Although views of or from an asset will play an important part, the way in which we experience an asset in its setting is also influenced by other environmental factors such as noise, dust and vibration from other land uses in the vicinity, and by our understanding of the historic relationship between places. For example, buildings that are in close proximity but are not visible from each other may have a historic or aesthetic connection that amplifies the experience of the significance of each'. Reference is Paragraph: 013Reference ID: 18a-013-20140306 dated 6 03 2014.

The Dunton strategic allocation (site reference 200) has been the subject of previous comments by English Heritage in respect of the Dunton Garden Suburb consultation (February 2015). These comments still apply to the draft Local Plan. This preferred allocation includes heritage assets at Dunton Hills (grade II - a 17th century house), the Church of St Mary (grade II and rebuilt 1873) and Dunton Hall (grade II - an early 19th century house). Setting is also a material matter and this applies to Wayletts (a grade II timber framed farmhouse to the north-east), Barnards (a grade II timber house), to the Church of All Saints (grade II) and a monument in the churchyard (grade II) as well as the historic park and garden at Thorndon Hall (to the north-west), itself a grade II* landscape.

The detailed consideration of setting will be a matter of material importance and such considerations are a constituent part of Local Plan policy 9.5 'Listed Buildings' and policy 6.3 (g) when considering the impact upon the significance of the asset.

The sustainability appraisal for the 2015 Dunton Garden Suburb consultation identified the eastern part of the site as a 'historic environment zone' considered sensitive to change (paragraph 2.15 of this document). It reported that this site
' contains archaeological find areas and medieval sites or find-spots, as well as remnants of historic field patterns of possible Middle Saxon origin. There are two listed buildings in the area, Dunton Hall and Dunton Hills, with others nearby. To the north west of the area is the Registered Park and Garden of Thorndon Park with Old Thorndon Hall and Gardens Scheduled Monument. The major employment and residential development identified for the site could have a significant negative effect on the setting of these historic assets and on the listed buildings within and close to the site unless appropriate mitigation measures such as natural screening are incorporated into the detailed design and layout of the development. Additional road traffic travelling between the development and Brentwood on the A128 could have adverse
effects on the historic assets of Herongate and Ingrave villages on this route and on the centres of Brentwood and Shenfield'.

Paragraph at 2.16 concluded that
'there is potential for a significant negative impact on the heritage environment. This effect is judged to be uncertain as it may be possible to avoid or reduce the potential effects by sensitive layout and design of development'.

The interim sustainability appraisal for the Local Plan, at its page 84, accepts that 'A Dunton Hills Garden Village scheme might well impact on the setting of Dunton Hills farmhouse (grade II listed).'

Historic England therefore recommends that further investigation is required including characterisation work to inform the evidence base. This work will inform the historic environment evidence base consistent with paragraph 169 of the National Planning Policy Framework. Historic England has published guidance which deals with historic characterisation in local and neighbourhood plans. This document is 'Understanding Place - Character and context in local planning' (published 2011 - revised June 2012) and is available at https://content.historicengland.org.uk/images-books/publications/understanding-place-character-context-local-planning/understanding-place-cclp.pdf/

Further guidance is available as
'Understanding Place - Historic Area Assessments: Principles and Practice' (June 2010) and is available at https://content.historicengland.org.uk/images-books/publications/understanding-place-principles-practice/understanding-place-haa.pdf/

The interim sustainability appraisal for the current draft Local Plan consultation states that when considering site options appraisal that
Limited data is available to inform the appraisal. Whilst there is good potential to highlight where development in proximity to a heritage asset might impact negatively on that asset, or its setting, a limitation relates to the fact that it has not been possible to gather views from heritage specialists on sensitivity of assets / capacity to develop sites. This is a notable limitation as potential for development to conflict with the setting of historic assets / local historic character can only really be considered on a case-by-case basis rather than through a distance based criteria. It will also sometimes be the case that development can enhance heritage assets.
(interim SA at page 57).

Historic England would conclude that the need for characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb.

Re Dunton: is in the green belt, therefore should not be developed at all.

Re Enterprise Park: not a brownfield site (see previous representations for more detail), so not suitable.

Re William Hunter Way: insufficient case for retail-led development; high-rise flats would be a more appropriate development here.

Re Baytree: has never had full occupancy, despite prime location, so there is no point creating other retail sites.

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See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.

See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.

See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.

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