9.14

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Support

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 23977

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Representation Summary:

A Spatial Vision for Dunton Hills, paragraphs 9.14 - 9.18

CEG supports the spatial vision as expressed in this part of the Local Plan (paragraphs 9.14 - 9.18), and as set out in the three interrelated policy domains, namely site requirements; the spatial design; and the delivery approach and legacy management. These three domains are then carried forward into the presentation of Policy R01 itself, and this approach is generally supported.

Full text:

Introduction

CEG supports the Strategic Allocation of Dunton Hills Garden Village (DHGV). CEG's objections relate primarily to specific aspects of Policy R01 and what modifications are considered necessary to make the Local Plan sound. Other minor modifications to improve the clarity of the Local Plan are also suggested, and it is indicated which representations fall into this category.

CEG is the main developer which has been working on the Strategic Allocation and the proposals for DHGV for several years. As the Local Plan indicates (paragraph 9.11), Dunton Hills was selected as one of 14 proposed garden villages in England receiving funds to take plans forward and help the timely delivery of the development. CEG has undertaken significant work on all technical and delivery aspects of taking forward a development of the scale and type described in the Local Plan, advised by an experienced professional team.

Informed by this detailed work CEG can confirm that the DHGV allocation site is suitable, available and achievable for development in the terms set out in the Planning Practice Guidance. Bearing in mind the site will be released from the Green Belt at the culmination of this Local Plan process, CEG is working on the basis that planning permission will be granted for DHGV soon after the adoption of the Local Plan.

CEG is a developer with a proven track record of delivery of strategic sites of this scale and type, and is an active participant in the garden village agenda across the country. CEG is experienced at working with housebuilders, affordable housing providers and other developers as well as the many other stakeholders involved in the delivery of large sites such as this. The projected lead-in times and build out rates for development take account of this experience and the detailed work undertaken on this site and support the assumptions adopted by the Council in the Local Plan. As well as the delivery of a minimum of 2,700 new homes over the plan period, the allocation provides for up to 4,000 new homes, with the remainder provided after 2033.



Paragraphs 9.1 - 9.7

CEG supports the general approach outlined in these paragraphs and agrees that the site allocations, including Dunton Hills Garden Village, reflect the spatial strategy and strategic objectives set out earlier in the Local Plan.

CEG supports the approach of setting out of each policy by the sub-headings specified, although representations are made below on what is set out for DHGV in Policy R01.

CEG supports the cross-reference to other policies in paragraph 9.4 to avoid unnecessary repetition in the Local Plan, but it should be noted CEG has submitted objections to Policy HP04. Consistent with paragraph 6.36 of the Local Plan, and to ensure the Plan is effective, the approach to affordable housing, including mix and tenure, should allow for some flexibility to provide for possible changes in circumstances over the lifetime of the Plan. This should then be carried forward into paragraph 9.17 iii, with reference made to viability as an important aspect which will inform the delivery approach, including the phasing of infrastructure, and legacy management. Modifications are proposed in our response to question no. 6 to this effect.

Dunton Hills Garden Village

Background, paragraphs 9.8 - 9.14

CEG supports the selection of DHGV as a Strategic Allocation, which is consistent with policy in the National Planning Policy Framework (NPPF) which the Local Plan refers to in paragraph 9.8.

CEG supports the strategy that in Brentwood the supply of new homes can best be achieved by the planning of DHGV in the way proposed by the Council in combination with the other allocations. The site of DHGV is well located, the proposals will be well designed and supported by the necessary infrastructure and facilities, in accordance with paragraph 72 of the NPPF.

It is noted that the Local Plan (paragraph 9.10) refers to the fact that the Strategic Allocation at Dunton Hills was selected to meet the 'majority' of Brentwood's housing need, but this overstates the position as it gives the impression it will deliver more than half. The Strategic Allocation will meet 35% of the housing need over the plan period - which would be more appropriately described as a 'significant proportion' of Brentwood's housing need. The significant majority of the need will be met from a range of other sites across the Borough. A minor modification is suggested to clarify this matter.

CEG supports the Council's general approach to determining where housing needs should be met and the unique opportunity to deliver a sustainable new settlement at DHGV. CEG also agrees that this approach aligns with the Borough of Villages character explained elsewhere in the Local Plan, and would continue to maintain characteristics of Green Belt openness.

A Spatial Vision for Dunton Hills, paragraphs 9.14 - 9.18

CEG supports the spatial vision as expressed in this part of the Local Plan (paragraphs 9.14 - 9.18), and as set out in the three interrelated policy domains, namely site requirements; the spatial design; and the delivery approach and legacy management. These three domains are then carried forward into the presentation of Policy R01 itself, and this approach is generally supported.

DHGV Strategic Aims and Objectives, paragraphs 9.19 - 9.22

CEG generally supports the three Strategic Aims and Objectives and the contents of each of them. However, the relationship of these Strategic Aims and Objectives (paragraphs 9.20 - 9.22), the three policy domains (paragraph 9.17), and the Development Principles (paragraph 9.23) is unclear.

In paragraph 9.19 it indicates that the three overarching aims, each supported by sub-objectives, provide the link between the vision - presumably the Spatial Vision for Dunton Hills - and the development strategy. It then states that these form the fundamental development principles to help shape and inform the development of a masterplan and guide decision-taking.

CEG considers clarity should be provided in the text at paragraph 9.19, on how the Strategic Aims and Objectives inform Policy R01, this being the policy against which a masterplan and a planning application for development at DHGV will ultimately be determined. Such clarity could be provided by stating that the Strategic Aims and Objectives underpin the requirements of the Policy R01 and the supporting text in paragraphs 9.24 - 9.89 provides further guidance on the application of that policy.

With respect to paragraph 9.20 (iii) the wording is potentially onerous and inconsistent with national policy. It relates to heritage assets so the reference to natural assets should be removed or the title changed. With respect to the heritage aspects it should refer to the desirability of sustaining and enhancing the significance of heritage assets in line with paragraph 185 of the NPPF.

Development Principles, paragraph 9.23

As stated above the relationship of the Development Principles (paragraph 9.23) with the three policy domains (paragraph 9.17) and the Strategic Aims and Objectives (paragraphs 9.20 - 9.22) is unclear. CEG questions whether the Development Principles are necessary or couldn't be incorporated within the Strategic Aims and Objectives, notwithstanding the fact it generally supports what they are seeking to achieve.

CEG considers that if the Development Principles are retained further clarity should be provided in the text at paragraph 9.23, on the relationship with Policy R01, this being the policy against which a masterplan and a planning application for development at DHGV will ultimately be determined.

CEG objects to paragraph 9.23 (i) where Green Belt, landscape capacity and environmental impacts are conflated within a development principle entitled Design and Build with Nature. New Green Belt boundaries will be clearly defined with the Strategic Allocation using physical features that are readily recognisable and Green Belt isn't a landscape or environmental designation, in any event. The reference to Green Belt should be removed.




Policy R01 (I) Dunton Hills Garden Village Strategic Allocation

CEG generally supports Policy R01(I) and what it is seeking to achieve, subject to the representations outlined below.

Criterion A

There is a very small difference between the size of the site set out in criterion A (and paragraph 9.12) and that contained in Appendix 2. The difference is insignificant but a minor modification would ensure consistency.

Criterion B

CEG proposes wording changes to ensure the presentation of the number of new homes is consistent with criterion D, insofar as the number to be provided over the plan period is presented as a minimum, and to ensure the plan is positively prepared in this regard.

Criterion D

CEG proposes wording changes for reasons of clarity and to provide some limited flexibility, for example, in the amount of land to be provided for employment space, consistent with the approach adopted elsewhere in the policy for other uses.

With respect to sub-criterion (a) CEG supports reference to the provision of a variety of housing typologies and tenures which will help create a holistic new settlement in line with garden community principles and assist in delivering the new homes at DHGV.

With respect to sub-criterion (d) and (e) CEG objects to the references to co-location which are considered too prescriptive and the policy is not justified. CEG considers that sub-criterion (e) should refer to two primary schools, 'preferably co-located' with early years and childcare nurseries, which would make this consistent with the wording of paragraph 7.100 of the Local Plan.

As far as sub-criterion (d) is concerned CEG considers that the reference to co-location should be removed, with the location of the secondary school left to be determined in the masterplan process, in consultation with relevant stakeholders including Essex County Council; or reference made in the Social Infrastructure section to the potential benefits of co-location in Policy R01 (II) which deals with the Spatial Design of DHGV.

With respect to sub-criterion (h) CEG generally supports the proportion of the total land area of the Strategic Allocation that policy requires for green and blue infrastructure (GBI). However, CEG objects to the fact the figure is presented as a minimum requirement which is prescriptive and considers that some limited flexibility is required in this figure, consistent with how other land uses are presented in the policy. CEG also considers that policy should clarify that GBI includes private gardens and green roofs to make the measurement basis clearer.

CEG considers that there is considerable opportunity for high quality GBI which will be a significant feature of DHGV and central to the achievement of garden community principles. CEG fully supports its inclusion and generally supports the policy relating to the spatial design for GBI outlined in Policy R01 (II). CEG considers this should inform the overall amount of GBI that is provided, as well its design; and that the precise amount and design of GBI should flow out of the masterplan process. This will ensure the Plan is positively prepared.

This approach is consistent with guidance on this matter from the Town and Country Planning Association (TCPA), which states that, "As a general rule, 50% of the land total in a new Garden City should be green infrastructure, including private gardens and green roofs and this should be clearly stated in local planning policy". (Practical Guides for Creating Successful New Communities, Guide 7: Planning for Green and Prosperous Places, TCPA, January 2018, page 17)

With respect to sub-criterion (i) CEG objects to the reference to "retail provision to form the vibrant village core" as this is not consistent with the NPPF which states that the range of uses permitted should be defined as part of a positive strategy for the future of each centre (NPPF, paragraph 85. (b)).

The provision of a District Centre and Local Centre(s) within DHGV is supported by CEG as they will form the heart of the new garden community. To provide for the needs of the new community these centres should provide a mix of main town centre uses as defined by the glossary in the NPPF. Policy currently refers only to retail provision, which could be interpreted as only Class A1 uses, when a mix of uses should be encouraged. This will ensure the plan is positively prepared.

Policy R01 (II): Spatial Design of Dunton Hills Garden Village

Suggested wording changes are proposed for reasons of clarity to ensure consistency with other parts of the policy.

Criterion C

As was stated above CEG generally supports the policy relating to the spatial design for GBI outlined in criterion C. However, CEG objects to sub-criterion (f) as it is inconsistent with national policy. The Strategic Allocation involves the release of the land from the Green Belt so the GBI on the eastern boundary that forms part of allocation cannot reinforce the beneficial purpose and use of the Green Belt in that zone, as policy requires. Amendments are proposed which rewords the policy so that it can assist in achieving objectives of visual separation of settlements and improving landscape and habitat value, whilst forming a robust and clearly defined boundary using physical features that are likely to be permanent. This is in accordance with paragraph 139(f) of the NPPF.

Criterion E

CEG supports the approach of safeguarding and maintaining key views within the development. In relation to criterion E(a) a small change is proposed to reflect that it is visual corridors that are important rather than landscape corridors. This acknowledges that not all visual corridors need to be landscape driven. In relation to criterion E(b) a minor change is suggested to make it clear that the visual separation is between DHGV and Basildon. Lastly, in relation to criterion E(c), it is proposed to remove this criterion as this does not relate to 'views' and is in any event already addressed elsewhere in the plan by virtue of Policy BE02(a).



Criterion F

With respect to criterion F, CEG objects to the wording of the policy as it is inconsistent with national policy and modifications are proposed to bring it in line with the NPPF.
Paragraph 185 of the NPPF, requires that "Plans should set out a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. This strategy should take into account: a) the desirability of sustaining and enhancing the significance of heritage assets, and putting them to viable uses consistent with their conservation;..."
In relation to designated heritage assets, paragraphs 195 and 196 provide for harm to heritage assets to be weighed against the public benefits of a proposal. As such, there are circumstances where not all heritage assets will be "sustained and enhanced". A modification is proposed in our response to question no. 6 to ensure consistency with the NPPF.

With respect to sub-criterion (b) CEG objects to the prescriptive nature of the requirement to integrate the listed farmstead as part of the Dunton Hills Village Centre, as it is considered that this isn't justified. The NPPF emphasises that the conservation of designated heritage assets is of great weight and that less than substantial harm should be weighed against the public benefits of the scheme; there are therefore a number of acceptable design solutions that respect the setting of the listed farmhouse. The reference to the historic core overstates the position as there is only a small collection of farm buildings. The policy should refer to the integration of the farmstead with new development at DHGV more generally, so that the solution flows out of the masterplan process and a consideration of the landscape and heritage assessments referred to in the policy. This would allow the farmstead to be integrated into the Village Centre but also allow an alternative to be pursued if a better option emerges.

With respect to criterion F(c) detailed matters relating to any alterations of listing buildings to accommodate new uses would be considered via planning and listed building consent applications and this should be simplified to aid clarity.

The proposed modifications to deal with the issues outlined above would have knock-on effects on the explanatory text which we consider below.

Criterion G and H

CEG considers that criterion G and H relating to sustainable travel and transport aren't positively prepared as they don't fully recognise changing patterns of travel and mobility that will reduce the need for travel and impact on the spatial design of DHGV.

Criterion G should recognise that 'virtual mobility' which includes internet shopping and working from home or locally are good sustainable ways of living and don't involve 'transport' or reduce the need for it. Furthermore, an amendment is proposed to discourage single occupancy car use rather than reference being made to short internal trips. The length of trip is less relevant and multi-occupancy car trips may be more sustainable than other forms of motorised travel and should not be discouraged. Sequentially the priority is: virtual mobility; active travel (walking and cycling); shared travel (shared cars, buses and trains); and then single occupancy cars.

With respect to criterion H, CEG considers for this to be positively prepared it should refer to 'transport improvements' rather than 'mitigations'. This is consistent with the amendments proposed to criterion G, as mitigation is required to in relation to impacts whereas this spatial design intention should be to minimise impacts though design and management. There is also a need to provide some flexibility to respond to changes in public transport infrastructure over the plan period.

With respect to sub-criterion (d) to ensure the plan is positively prepared an amendment is proposed to reflect the fact the developer of DHGV cannot provide the improvements sought directly, but can provide a financial contribution towards their provision. This is consistent with the approach adopted in sub-criterion (c).

Criterion K
CEG has made representations to criterion D (i) above relating to positively planning for main town centre uses in the district and local centres in DHGV and these should be carried through to criterion K for the same reasons. Furthermore, for the policy to be effective greater clarity should be provided over the form of assessment to ensure the Plan is positively prepared. Any study should assess the needs of the new community considering existing provision in the surrounding area, which would include the existing centres of Laindon and West Horndon, and the new village centre proposed with Policy R02 on land at West Horndon Industrial Estate.
CEG considers sub-criterion (a) should be deleted in line the representations above in relation to criterion F.

Policy R01 (III): Spatial Delivery and Legacy Management

CEG generally supports the third part of Policy R01. Several minor amendments are proposed which will give the policy greater clarity and ensure its consistent with other parts of the plan. The reference to a Jobs Brokerage Scheme should be defined in the Glossary or a scheme mentioned in more general terms the aim of which is to ensure jobs go to local people. This aim is supported by CEG.

Paragraphs 9.24 - 9.89

Please refer to CEG's representations above on DHGV Strategic Aims and Objectives, paragraphs 9.19 - 9.22.

In relation to paragraph 9.40, some modifications are proposed to remove reference to the 'significance' of landscape features and key views, instead requiring them to be retained and enhanced. This recognises that not all landscape features or key views will have a heritage interest and the use of 'significance' in the NPPF specifically relates to heritage assets. We have suggested that paragraph 9.40 becomes two paragraphs as the last sentence does not relate to landscape features and key views.

CEG's representations outlined above would have some knock-on implications on what is contained within these paragraphs, albeit quite limited. For example, CEG generally supports paragraphs 9.45 - 9.50 dealing with Embedding Heritage Assets into the new development. No reference is made in this section to the need for listed farmhouse being incorporated into the village or district centre. For the reasons stated above we consider this is a matter that should flow from the outcome of the masterplan process. However, in the section on Social Place, in paragraph 9.60 it does refer to the farmstead being incorporated into the village core and for the reasons set out above, we consider such a reference should be deleted

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