POLICY R01 (III): SCHEME DELIVERY AND LEGACY MANAGEMENT

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Support

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

Representation ID: 22326

Received: 16/03/2019

Respondent: Anglian Water

Representation Summary:

We note that Policy R01 (III) include reference to the preparation of a masterplan as part of a collaborative process working with the private sector including Anglian Water which is supported.

Full text:

We note that Policy R01 (III) include reference to the preparation of a masterplan as part of a collaborative process working with the private sector including Anglian Water which is supported.

Support

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

Representation ID: 23207

Received: 21/03/2019

Respondent: Anglian Water

Representation Summary:

We are supportive of the Local Plan policies relating to Dunton Hills strategic allocation (RO1 (I) and RO1 (III)).

Full text:

Further to my previous e-mail - I am pleased to confirm we are largely happy with the content of the Brentwood Pre-submission Local Plan as currently drafted.

We are supportive of the Local Plan policies relating to infrastructure delivery (SP06) Sustainable Design and construction and future proofing (BE01 and BE02) Drainage and flood risk (NE06 and BE08) and policies relation to Dunton Hills strategic allocation (RO1 (I) and RO1 (III)).

We have sought wording changes for two policies as follows:

Policy SP01 - suggested additional wording to refer to potential amenity impacts from existing uses as well as new development proposals. In effect we are seeking to avoid a situation where we are unable to operate our Water Recycling Centre (wastewater treatment works) on a continuous basis due to concerns raised about amenity impacts (principally odour) from development proposals in close proximity to these sites.

Policy BE18 - clarification of wording to make it clear that wastewater treatment capacity is made available by the sewage companies and not developers who have a role in funding improvements to the network itself.

We welcome the opportunity to enter into a Statement of Common Ground or similar in relation to the outstanding points set out above prior to the examination.

If you would like to discuss these comments further please do not hesitate to get in touch.

Attachments:

Support

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

Representation ID: 23991

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Representation Summary:

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.

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

Attachments:

Support

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

Representation ID: 23992

Received: 19/03/2019

Respondent: Bellway Homes and Crest Nicholson

Agent: AECOM

Representation Summary:

Clause B states: "The development and phased delivery [...] new garden village". Whilst supported and the timely delivery on infrastructure is essential in the creation of a sense of community, off-site infrastructure may be beyond the control of the primary land owners/promoter, and risks stalling development if a Grampian condition is envisaged. An explicit policy clause is urgently required to ensure for a no ransom position. The primary developer must build roads up to the boundary of Crest Nicholson and Bellway Homes landholding. Without this added clause the allocation would be ineffective based upon the tests of soundness.

Change suggested by respondent:

An explicit policy clause is urgently required to ensure for a no ransom position. The primary developer must build roads up to the boundary of Crest Nicholson and Bellway Homes landholding. Without this added clause the allocation would be ineffective based upon the tests of soundness.

Full text:

Bellway Homes and Crest Nicholson representations Brentwood Regulation 19 Pre-Submission Local Plan (February 2019)
Merits of our client's landholdings and the Dunton Hills Garden Village
Bellway Homes and Crest Nicholson's landholdings (part of allocation R01) are unconstrained, suitable, deliverable and available. As such the landholding can be brought forward as part of the wider Dunton Hills Garden Village allocation.
Our clients are housebuilders, not land promoters, and are seeking delivery at the earliest opportunity pending suitable access. Crest Nicholson and Bellway Homes will continue to work with officers and Councillors (and other landowners/developers) to help bring forward this key site for meeting local housing needs in South Essex. It is absolutely right that the allocation should not be anchored to the work that will be carried out as part of the Association of South Essex Local Authorities (ASELA) and the emerging Joint Strategic Plan (JSP).
The identification of strategic scale sites to meet Brentwood's housing needs is supported, as is the principle of a new settlement via the Dunton Hills Garden Village Strategic Allocation (Policy R01) and its ambition for the delivery of additional homes beyond the plan period. The allocation represents an efficient use of greenfield land adjudged to be sustainable. Similarly we commend the Council for taking the decision to bring forward strategic greenbelt release alongside a comprehensively planned new settlement.
Our clients would support improved integration with Basildon alongside a landscape solution/approach agreed via a Statement of Common Ground and complementary policy positions (and/or supporting text) in both the Brentwood and Basildon Local Plans. This would help to deliver Dunton Hills Garden Village and the future expansion of West Basildon whilst maintaining separation physically through the provision of publicly accessible green infrastructure and improving connectivity for new and existing residents. Our clients do not support the position taken by Basildon Borough Council and have submitted representations objecting to the draft Basildon Local Plan.
Policy SP02: Managing Growth
Paragraphs 4.11 - 4.21 of the draft plan set out Brentwood's housing need position based upon the application of the standard methodology for calculating a minimum Local Housing Need figure; and the identification of a 20% buffer of housing sites for the first five years of the plan. The plan, at paragraph 1.38, also states that:
"..it may be necessary to review the Brentwood Local Plan, at least in parts, to ensure any opportunities for further growth and infrastructure provision in the Borough identified in the Joint Strategic Plan can be realised."
Our clients support this approach. Brentwood is seeking to meet their identified housing needs in full plus a sufficient buffer in the early part of the plan period. Crucially the draft plan is not using the JSP as a reason for deferring difficult planning decisions. As such, the draft plan is not reliant upon the emerging JSP to meet Brentwood's needs up to 2033. There has been no consultation to date on the JSP (as at March 2019) and it would be wholly unsound to rely upon a future JSP to meet identified needs up to 2033. Our clients support the pragmatic approach set out by Brentwood which is in accordance with the National Planning Policy Framework (paragraphs 11, 16 and 26 - a 'positively' prepared plan that seeks 'opportunities to meet the development needs' of their area and is 'sufficiently flexible to adapt to rapid change').
Our clients would advocate delaying submission of the publication plan until the 2018 affordability ratio data is released by the Office for National Statistics (the data used in the standard methodology for calculating housing need), due for publication in March/April 2019. This would allow time for factual updates to be made to Policy SP02 and housing target. Should submission come before the publication of the affordability ratio data, Brentwood should consider over allocating sites to increase the buffer of sites over for the whole plan period - sufficient to provide flexibility in respect of any increases brought about by the new affordability data published prior to or shortly after submission.
aecom.com
7/14
The recent release of the Housing Delivery Test (HDT) in February 2019 confirmed that Brentwood and all the other ASELA authorities (with the exception of Thurrock) have to identify a 20% buffer to their five year housing land supply and prepare a HDT Action Plan by August 2019. The minimum Local Housing Need figure (produced by the new standard methodology) will be applied to all authorities from 2018/19 for the purposes of the HDT (unless there is a plan that is less than 5 years old). As such Brentwood (and Basildon) will both be subject to HDT assessment on the basis of the minimum Local Housing Need figures until such time that their plans are adopted.
Table 1 (below) shows the HDT results published by MHCLG (19th February 2019) for all Councils that make up the ASELA. This shows housing delivery has only been achieved in one of the past three monitoring years (2016/17) for Basildon and it was never achieved by Brentwood. The HDT results evidence a persistent under delivery of housing in the South Essex region. Brentwood and Basildon are at risk of failing the HDT thresholds in 2019 and 2020. At present, Brentwood is in danger of falling below the 45% threshold this November 2019. This would leave the authority open to the presumption in favour of sustainable development (the 'tilted balance') and susceptible to speculative applications outside of the identified draft allocations. For Basildon there is a real risk that they will also be captured by the presumption in favour of sustainable development (75% threshold) as early as November 2020. Basildon's position is even more precarious given that they have not identified sufficient land to meet their minimum Local Housing Need, let alone a 20% buffer for the first five years, in their previous consultation draft plan.
Table 1 South Essex HDT results (MHCLG, February 2019)
[see attachment]
This illustrates the severity of the housing crisis in South Essex and the pressing requirement for all ASELA authorities to identify sufficient land supply (to meet their needs and a 20% buffer for the first five years) and maintain the plan-led approach. Basildon's failure to allocate sufficient sites to meet housing needs will impact the other ASELA partners (e.g. increased unmet needs in the region).
Duty to Cooperate
The above issues should be addressed as a matter of urgency through Brentwood and Basildon's Duty to Cooperate Statements of Common Ground. A Duty to Cooperate position statement is welcome, although the MOU with the ASELA is insufficient to evidence the detailed Duty to Cooperate matters that need to be addressed with Basildon. A Statement of Common Ground that outlines areas of uncommon ground would be just as valuable in advance of submission of both plans and the forthcoming examinations.
This will help to avoid creating inconsistencies or prejudice any future plan making as part of the ASLEA JSP. If Basildon and Brentwood both wish to avoid the appearance of sprawl along the A127, this can be achieved through a simple Statement of Common Ground and via identical high-level policies (or supporting guidance) in each Local Plan. At present the current policy position does not ensure an integrated approach to delivery of the Garden Village and adjacent sites to the West of Basildon. It is our client's view that a failure to tackle this issue head-on now could stall delivery on Dunton Hills Garden Village. The JSP is not the appropriate vehicle for resolving a planning issue within the emerging Basildon and Brentwood plans; this matter must be resolved prior to submission, of both Local Plans (ideally via a Statement of Common Ground).
Policy NE13: Site Allocations in Green Belt / Policy HP18: Designing Landscape and the Public Realm
Our clients support the strategic release of greenbelt sites in sustainable locations. Dunton Hills Garden Village has followed a robust Green Belt review; Sustainability Appraisal; and site selection process. The draft plan does not allocate land between Dunton Hills Garden Village and West Horndon; therefore it maintains physical separation and avoids the coalescence of the new settlement and existing built up area of West Horndon. To date there is no evidence that it would be possible to meet the Borough's acute housing needs without amending the Green Belt boundaries as proposed in the draft plan.
The Stage III Green Belt Review January 2019 (GBR3) continues the work of the previous two stages. Again the methodology used appears sound and has been consistently applied. GBR3 assesses the DHGV site, Parcel 200, as being Not Contained, exhibiting Significant Separation Reduction between settlements, as being Functional Countryside and of Limited Relationship to Historic Towns. This results in an overall conclusion of Parcel 200 making a moderate to high contribution to the Green Belt. As with the LSCA the scale of DHGV inevitably results in elevated scores.
The Dunton Hills Garden Village allocation (shaded yellow) and wider Green Belt parcel incorporating land West of Basildon in Basildon Borough (shaded red) shown on Figure 1 (below) is an area bounded by the A127, the A128, a railway line and the western edge of Basildon - there are few (if any) examples nationally of more contained and defensible boundary in Green Belt terms.
Figure 1 Green Belt Context: Land West of Basildon (red) and Dunton Hills Garden Village (yellow)
[see attachment]
There would be clear separation maintained between Dunton Hills Garden Village and West Horndon in Brentwood Borough. Paragraph 9.12 is also supported as it recognises that "The B148 (West Mayne) is the eastern road beyond the borough boundary separating the site from the built-up area of Basildon". If Dunton Hills Garden Village and the land West of Basildon (in Basildon Borough) are both allocated it is only logical to remove all of this land from the Green Belt based upon the strong defensible boundaries that exist for both areas. Landscape approach, design principles and physical separation can (as previously discussed) be dealt with via a Statement of Common Ground and complementary Local Plan policies (and guidance) in the respective plans. Policy R01 includes a detailed statutory policy to ensure the new settlement is comprehensively planned via landscape-led approach. This will ensure the development is not simply ribbon development along the A127 and instead an autonomous Settlement Category 2 Garden Village that will complement the existing settlement hierarchy and is well related to the existing communities of Basildon and Laindon and West Horndon.
The Landscape Sensitivity and Landscape Capacity Study: Potential and Strategic Allocation Options October 2018 (LSCA) assigns a landscape capacity to the potential allocations. The methodology used appears sound and has been consistently applied. The LSCA identifies the DHGV site, Parcel 200, as being of high landscape sensitivity, medium - low landscape value and medium - medium low landscape capacity. It is noted that the scale of the strategic options considered make comparison with smaller sites difficult. The scale of DHGV inevitably results in elevated scores.
The site is not the subject of any landscape quality designations that would prevent development. Our clients consider that Policy HP18: Designing Landscape and the Public Realm, in combination with Policy R01(I) clause C, provide an adequate policy framework for guiding a future landscape scheme - including the provision of green infrastructure between R01 and the development of the West of Basildon.
Policy R01: Dunton Hills Garden Village Strategic Allocation
The policy would benefit from being shortened and simplified. Much of the detail could instead be covered in the supporting text. Our clients would recommend a less prescriptive policy in favour of a series of development principles. The policy also recognises the appropriate phasing of infrastructure and mechanisms for delivery. However, our clients have a number of detailed comments to help enhance the clarity and utility of the draft policy.
R01(I)
 Clause B uses the term "self-sustaining" - this is currently an undefined term in the context of the facilities that may be required by future residents. It is likely that services and schooling would also be accessed in Basildon and so the policy should also recognise the importance with connectivity to nearby allocations and settlements in Basildon Borough. Whilst appreciating the need for a garden village to be separate, it should also be appropriately connected and complimentary to nearby settlements.
 There is a slight inconsistency between policy clauses A and D in the use of "around 2,700 homes" and "at least 2,700 homes" in the plan period. Our clients would favour the more positive "at least" in light of the pressing housing needs in the area.
 Policy clause D(c) currently expresses a requirement for employment land as 5.5ha. An alternative approach would be to also reference a jobs figure, employment densities are not fixed and the policy will need to remain flexible to provide the optimum employment solution on the site up to 2033.
 Policy clause D(d) references a co-located Secondary school, but this term is not defined in terms of what facilities could be appropriately co-located or any indication on forms of entry etc. This clause could cross reference to the Infrastructure Delivery Plan that shall remain a living documented capable of being updated as the development of the site evolves.
 Policy clause D(h) states 50% of the "total land area", this term is not defined and may have implications for the net developable area. Without the benefit of a detailed masterplan and Environment Statement supporting an application this requirement appears needlessly onerous and will make the allocation less flexible. We would suggest removal of a specific percentage in advance of further masterplanning and consultation.
R01 (II)
 Policy clause C(f) states: "a green infrastructure buffer / wedge on the eastern boundary with Basildon Borough to achieve visual separation to help significantly improve the landscaped and habitat value thus reinforcing the beneficial purpose and use of the green belt in that zone." This matter needs careful consideration in advance of submission in light of Basildon's representations and their erroneous position on Green Belt coalescence and countryside encroachment in their draft plan (which fails to allocate sufficient land to meet needs). Brentwood should provide further clarity that this separation can be achieved without sterilising large tracts of the allocation. A modest multifunctional green gap running north-south in close proximity to the Borough boundary would be a proportionate response in this location.
 Policy clause D(c) states "pathways through the green and blue infrastructure (GBI) network will be made of permeable material and follow a coherent treatment throughout the village. The pathways will all connect into a circular walk, with interconnected shortcut routes and be signposted offering directions to key destination points". It is premature at this stage to place overly restrictive pathway design where they may be sound place-making reasons for not following this approach in all areas.
 Policy clause I(a) states that emphasis will be given to: "incorporating car sharing clubs and electric vehicle only development". Whilst the principle is supported, this may not be appropriate for all areas of this large allocation and would be overly restrictive.
 Policy clause L(b) includes a small typo for BREEAM. This clause should make clear that BREEAM is for certain types of building only.
R01 (III)
 Clause B states: "The development and phased delivery of DHGV must ensure the timely delivery of the required on-site and off-site infrastructure to address the impact of the new garden village". Whilst supported and the timely delivery on infrastructure is essential in the creation of a sense of community, off-site infrastructure may be beyond the control of the primary land owners/promoter, and risks stalling development if a Grampian condition is envisaged.
An explicit policy clause is urgently required to ensure for a no ransom position. The primary developer must build roads up to the boundary of Crest Nicholson and Bellway Homes landholding. Without this added clause the allocation would be ineffective based upon the tests of soundness.
The Site benefits from the involvement of volume housebuilders which, according to the Letwin Review (2018), leads to a variety in product and higher build out rates. An extensive analysis of national house builder annual reports, conducted by Turley on behalf of Bellway Homes, demonstrates that average delivery rates (per outlet) range from between 40-58 units pa1. There is potential for sites (normally larger sites) to see a number of outlets building new homes at any one time. Additional outlets are sometimes in the form of a different house builder, but it can also be in the form of different products sold from different marketing suites by the same house builder. Crest Nicholson and Bellway Home's landholdings are jointly promoted in order to deliver high quality sustainable developments at pace and will help to achieve the housing trajectory set out in Appendix 1 of the draft plan.
The plan's delivery trajectory relies on increased delivery in the later part of the plan period (partly reliant on infrastructure investment). This emphasises the importance of infrastructure equalisation and removing any ransom scenarios as far as practically possible through statutory policy. In addition, it would be prudent for the ASELA authorities to work together to lever in external funding for reinforcements such as the gas pipeline to enable an alternative access arrangements and internal connectivity that would release more development land for housing and public open space later in the plan period.
R01 Supporting text comments:
 Paragraph 9.30 includes a reference to 'Medium' density- but this is not defined. The allocation location is in close proximity to Basildon and West Horndon and the potential for sustainable modes of transport lends itself to higher densities in district and local centres.
Transport policies B11 - B17
The general approach taken to transport within the Local Plan with the Built Environment policies (BE11 to BE17) is supported and it can be seen that these policies are feeding through into the policies for the site specific allocations.
The evidence base for the Local Plan includes Brentwood Borough Local Plan Transport Assessment (Local Plan TA) dated (October 2018) prepared by PBA and the Infrastructure Delivery Plan (IDP) prepared by the Council. These documents together provides the transport element of the evidence base and support the Council's proposed development strategy including the proposed development at Dunton Hills. They are essential elements of the evidence base and their soundness is not questioned in these representation, however, the conclusions of the Local Plan TA and the IDP need to be better reflected in the Local Plan.
The Local Plan TA sets out the approach to the modelling work, results of modelling and junction assessment, highlights those worse performing junctions that may require mitigations, the sustainable measure proposed and the impact this has on the junction assessment to enable the development sites to come forward. The assessment covers key 27 junctions within Brentwood planning authority.
The assessment assumed that DHGV would provide 2,500 new homes in the Local Plan period along with 5.5ha of employment land. In addition, number of sites located within Basildon Borough Council and Havering Borough Council were included within the reference case scenario in order to accurately assess the impact of Brentwood Local Plan. The West Basildon Urban Extension was included within the reference case assuming provision of 1000 new homes as per 2016 Basildon Local Plan publication.
The Local Plan TA identifies a number of junctions that would need to be improved across the Borough to support the development proposed in the Local Plan. However, the Local Plan Submission Version does not include reference to these. As an example, the following table contains the identified improvements in the surrounding roads to Dunton Hills Garden Village.
Table 2 Results of PBA capacity assessment, Brentwood Local Plan Evidence Base
[see attachment]
While it is clear that some of these improvements would be provided via Essex County Council (ECC) or Highways England as the relevant highway authorities there is no reference made in the Local Plan to them. It would be expected that the evidence base would transfer through to the IDP to be clear on how and when these identified infrastructure improvements would be provided.
As each identified allocated site comes forward to a planning application stage it will define what highway improvements are needed through the Transport Assessment associated with the individual site. However, guidance should be given on what improvements have been identified as part of the Local Plan TA to ensure that the need for them is considered and if they are required then how would they be funded i.e. guidance is needed on the scope for any future Transport Assessments to support developments.
The IDP contains a similar table for highway infrastructure improvements and those relevant to Dunton Hills Garden Village are listed in Table 3 below:
Table 3 IDP Schedule extract.
In addition to four infrastructure requirements relating specifically to DHGV a number of requirements are set out in the IDP for new developments and site allocations coming forward in the Local Plan period. Key improvements to be delivered as part of DHGV development are:
 DHGV: Widening Connectivity - further feasibility studies required to improvements of pedestrian connectivity across the A127 and A128;
 DHGV: Walkways/ Cycleways - provision of a good footway and cycle way network;
 DHGV: Sustainable Transport Infrastructure - provision of cycle hub within the DHGV site; and
 DHGV: Public Realm and Village Square - subject to detailed masterplanning good quality pedestrian centres should be provided.
It is acknowledged within the proposed policy for Dunton Hills Garden Village that reference is made for the need for a Transport Assessment report to be undertaken and this is where the detailed assessment can be made of the highway infrastructure needed to support the proposed allocation. However, there should be some reference to the published evidence base to guide the scope of this work. This is not to say that the identified improvements will be needed, but they should be considered as they have been identified within the evidence base.
Attendance at the examination hearing sessions
Our clients request attendance at the relevant hearing sessions to make verbal submissions in response to matters and questions related to: the Duty to Cooperate; housing numbers and the spatial strategy, landscape, transport, infrastructure, deliverability and the strategic allocations. We reserve the right to make further representations at the examination hearing sessions, should work on Brentwood's Community Infrastructure Levy evolve in respect of any implications on strategic sites and their ability to deliver policy compliant schemes.

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