The following aspects of the policy require modification to ensure consistency with the NPPF and statutory requirements as set out in the Planning (Listed Buildings and Conservation Areas) Act 1990:
Criterion A. "sympathetic to its character and setting" is not consistent with NPPF.
Criterion D. "only be permitted in exceptional circumstances;" is not consistent with the NPPF or 1990 Act.
It is recommended that the policy is re-visited generally to ensure consistency with the NPPF and the Planning (Listed Buildings and Conservation Areas) Act 1990.

Policy HP01, Housing Mix (page 124)

Self-build and/or custom build housing is supported by the National Planning Policy Framework (NPPF) and its contribution can help to diversify a housing offer, thus supporting housing delivery overall (Letwin, October 2018). CEG is committed to the delivery of self and custom build housing at Dunton Hills Garden Village (DHGV). Planning for a variety of housing types, including self and custom build assists in the delivery of housing on large sites. However, the minimum target of 5% set out in criterion A. c. (i) is not justified by an appropriate evidence base.

CEG is aware that the current level of interest on the Council's Self and Custom Build Register is relatively limited and the need for such housing does not, therefore, justify a minimum level of 5% being required. Indeed, if such a level isn't needed setting such a high minimum requirement could effectively prevent land being released for other types of housing which are needed.

In the 12 month period ending in October 2018 it is understood that 47 individuals and no associations were registered with the Council. Of the total number, 9 indicated a preference for village locations across the Borough, which in the future might include DHGV.

It is acknowledged that the Register is relatively new and the need for this type of housing might change over time. Considering this, a lower minimum requirement should be sought, probably at 1%, to support this type of housing at a level proportionate to the likely need. DHGV will provide for 2,700 new homes over the plan period, and 1% of this would amount to 27 self-build homes in total.

Overall CEG considers the 5% is too high and a lower figure should be adopted.

Policy HP03, Residential Density (page 128)

The policy is positively prepared. Taking a design led approach to density should enable development to achieve a net density of at least 35 dph or higher. This approach is consistent with Chapter 11 of the NPPF which seeks to make efficient use of land and optimise the density of development. A modification is proposed to reflect that density across a site should be an average.



Policy HP05, Affordable Housing (page 131 - 132)

CEG supports the approach set out at paragraph 6.35 which explains that the 'need' for 86% social rent and 14% other forms of affordable housing will be used to inform negotiations between the Council and developers to determine the appropriate tenure and mix of affordable housing.

This 'need' is then expressed as an 'indicative requirement' in Figure 6.2 and a 'requirement' in Policy HP05(B). The Policy currently requires a specific tenure split (86% social rent and 14% other forms of affordable housing) which may not be appropriate for the life of the Plan or for Strategic Allocations in the Plan. CEG supports the approach set out in paragraph 6.35 to ensure there is an appropriate amount of flexibility, for example, to accommodate changing circumstances over the lifetime of the Plan; and ensure the right mix and balance is created where Strategic Allocations are concerned.

Policy HP19: Conservation and Enhancement of the Historic Environment (page 160)
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.

Policy HP20 Listed Buildings (page 161-162)
The Policy is not consistent with the NPPF or statutory requirements as set out in the Planning (Listed Buildings and Conservation Areas) Act 1990 about listed buildings and how proposals that affect them should be assessed. Some modifications are proposed in our response to question no. 6 to address this

Policy PC08: Retail Hierarchy of Designated Centres

For consistency with Policy R01 the following modification is proposed:

A. The Council will promote the continued roles and functions of the existing and proposed Designated Centres to positively contribute towards their viability, vitality, character and structure....

Figure. 7.7: Brentwood - Designated Centres on the Retail Hierarchy

DHGV should be added to the list of Local Centres.

The centres at DHGV should be denoted as 'proposed' or a footnote added to clarify this.

Footnote no. 10 should be amended to state the Primary Shopping Areas will be designated in a Local Plan review.

Paragraph 7.54 iv. should be redrafted to ensure consistency with Policy R01 and Policy PC08.

Policy PC08, Retail Hierarchy of Designated Centres (page 187)

CEG supports the Council in its promotion of the designated centres, although it is suggested that reference is made to existing and proposed designated centres, considering the fact the District Shopping Centre at Dunton Hills Garden Village (DHGV) doesn't yet exist.

CEG notes that Policy R01 which deals with the DHGV Strategic Allocation proposes a District Shopping Centre with additional Local Centres in line with Policy PC08. Policy R01 deals with the specific requirements of DHGV. Policy PC08 refers to the Designated Centres set out in Figure 7.7 but this only refers to the District Shopping Centre at DHGV and not the Local Centres. To ensure consistency and to ensure the Plan is positively prepared the list of Local Centres in Figure 7.7 should include reference to local centres at DHGV.

The explanatory text which follows Figure 7.7 refers to DHGV (paragraph 7.54 iv) and also needs to be brought into line with Policy R01. It should refer to the 'provision of', rather than the 'potential for', a District Shopping Centre; and that the Local Centres are additional to, rather than potentially instead of, the District Shopping Centre.

The last sentence of paragraph 7.54 iv) is also confusing and creates further inconsistency. It indicates that the designation of these centres will be informed further by the South Brentwood Growth Corridor Masterplan and further retail evidence and considered as part of a future Local Plan review.

The Local Plan should either designate existing centres and propose new ones, which when they are built are designated as existing centres as part of a Local Plan review; or designate existing and proposed centres which appears to be the approach the Council is adopting here. In the latter scenario it is reasonable to defer the designation of the Primary Shopping Area to a later review once the centres are built. Whatever approach is adopted the way the District Shopping Centre and Local Centres are presented should be consistent with Policy R01.

CEG supports the recognition of the potential for use of upper floors for residential use in Designated Centres. This encouragement could be extended further to a more general statement of support for such uses in criterion C.

Figure. 7.7: Brentwood - Designated Centres on the Retail Hierarchy

DHGV should be added to the list of Local Centres.

The centres at DHGV should be denoted as 'proposed' or a footnote added to clarify this.

Footnote no. 10 should be amended to state the Primary Shopping Areas will be designated in a Local Plan review.

Paragraph 7.54 iv. should be redrafted to ensure consistency with Policy R01 and Policy PC08.

Policy PC08, Retail Hierarchy of Designated Centres (page 187)

CEG supports the Council in its promotion of the designated centres, although it is suggested that reference is made to existing and proposed designated centres, considering the fact the District Shopping Centre at Dunton Hills Garden Village (DHGV) doesn't yet exist.

CEG notes that Policy R01 which deals with the DHGV Strategic Allocation proposes a District Shopping Centre with additional Local Centres in line with Policy PC08. Policy R01 deals with the specific requirements of DHGV. Policy PC08 refers to the Designated Centres set out in Figure 7.7 but this only refers to the District Shopping Centre at DHGV and not the Local Centres. To ensure consistency and to ensure the Plan is positively prepared the list of Local Centres in Figure 7.7 should include reference to local centres at DHGV.

The explanatory text which follows Figure 7.7 refers to DHGV (paragraph 7.54 iv) and also needs to be brought into line with Policy R01. It should refer to the 'provision of', rather than the 'potential for', a District Shopping Centre; and that the Local Centres are additional to, rather than potentially instead of, the District Shopping Centre.

The last sentence of paragraph 7.54 iv) is also confusing and creates further inconsistency. It indicates that the designation of these centres will be informed further by the South Brentwood Growth Corridor Masterplan and further retail evidence and considered as part of a future Local Plan review.

The Local Plan should either designate existing centres and propose new ones, which when they are built are designated as existing centres as part of a Local Plan review; or designate existing and proposed centres which appears to be the approach the Council is adopting here. In the latter scenario it is reasonable to defer the designation of the Primary Shopping Area to a later review once the centres are built. Whatever approach is adopted the way the District Shopping Centre and Local Centres are presented should be consistent with Policy R01.

CEG supports the recognition of the potential for use of upper floors for residential use in Designated Centres. This encouragement could be extended further to a more general statement of support for such uses in criterion C.

CEG sets out the modifications it considers are necessary to make Policy R01 sound, the reasons for which are explained in question no. 5 above.

Other comments outlined above relating to the supporting text to Policy R01 are left for the Council to consider by way of minor modifications. The modification of Policy R01 in the manner set out below may require some of the supporting text to be aligned accordingly, in the manner described in response to question no. 5.

Proposed Modifications to Chapter 9. Site Allocations

Paragraph 9.4 should be amended for consistency with paragraph 6.36 and to ensure the Plan is effective. as follows:

"Affordable housing should be provided in line with Policy HP05, as well as considerations for
specialist housing, Policy HP04. Some flexibility may be required in relation to the approach to affordable housing and the phased delivery of infrastructure to ensure viable proposals come forward over the life of the Plan."

Paragraph 9.17 iii. should be amended for the same reasons, as follows:

"The Delivery Approach and Legacy Management - setting out the expectations for how the phased delivery of the scheme should be approached to ensure proposals are viable and embed an ethos of co-design and participation, timely and good governance in delivery, and an embedded legacy management of the village assets.


Proposed Modifications to Policy R01

Policy RO1 (I) Dunton Hills Garden Village Strategic Allocation

A. In line with Policy SP02, land at Dunton Hills (east of the A128, south of the A127 and north of the C2C railway line, approximately 259.2 ha in size) is allocated for residential-led development to deliver Dunton Hills Garden Village.

B. The development will deliver a mix of uses to comprise at least 2,700 homes in the plan period (as part of an overall indicative capacity of around 4,000 homes with the remainder to be delivered beyond 2033) together with the necessary community, employment, utility, transport and green and blue infrastructure (GBI) to support a self-sustaining, thriving and healthy garden village.

C. Successful development of the site allocation will require:

a. the masterplan to be underpinned by Garden Community principles and qualities

b. proposals to creatively address the key site constraints and sensitively respond to the unique qualities and opportunities afforded by the historic landscape and environmental setting to deliver a distinctive and well-designed garden village in line with the Spatial Vision and Strategic Aims and Objectives for Dunton Hills Garden Village; and

c. a holistic and comprehensive locally-led masterplan and design guidance to be developed, co-designed with relevant stakeholders to frame and guide the consistent quality and delivery across the site by different contractors over the delivery period.

D. The proposed development will be required to deliver all the necessary supporting spatial components and infrastructure to address the specific site constraints, potential impacts of development and harness the site opportunities as set out by the strategic Dunton Hills aims and objectives. Permission for mixed-use development will be granted subject to the parameters and components specified below:

a. delivery of at least 2,700 dwellings in the plan period providing a balanced variety of housing typologies and tenure and includes provision of self-build plots in line with Policy HP01; specialist accommodation in line with Policy HP04; and affordable housing in line with Policy HP05;

b. the provision of a minimum of 5 serviced Gypsy and Traveler pitches, in line with Policy HP07(b);

c. land (circa 5.5 ha) for employment space (in line with Policy PC03) to accommodate a creative range of creative employment uses suitable for a vibrant village centre and a predominantly residential area, including use class A1-A5 and appropriate B class uses;

d. land (circa 7.9 hectares) for a co-located secondary school (Use Class D1);

e. land (circa 2.1 hectares each) for two co-located primary school and early years and childcare nurseries, preferably co-located (Use Class D1);

f. land (circa 0.13 hectares each) for two stand-alone further early years and childcare nurseries (Use Class D1);

g. community and health infrastructure proportional to the scale of development, and in line with best practice principles of healthy design;

h. green and blue infrastructure to be a minimum of circa 50% of the total land area including private gardens and green roofs;

i. retail the provision of main town centre uses to form the vibrant village core in the form of a 'District Shopping Centre' with additional Local Centre(s) in line with Policy PC08, as appropriate to the scale and phasing of the development;

j. the provision of new and enhanced transport infrastructure to mitigate the impacts of development and to support sustainable modes of travel to ensure connectivity to key destinations, increase transport choice, support changes in travel behaviour, and to minimise the impact of traffic on the local and wider network, in line with Policy BE16 and as detailed in R01(ii) G-J; and

k. strategically designed and appropriately phased infrastructure, employing the most up to date technologies to ensure a smart, sustainable and a resilient basis for drainage and flood management in line with Policy BE08, water management including potable/non-potable and opportunities for grey water harvesting in line with BE03, efficient and cost saving energy networks in line with Policy BE04, superfast broadband in line with Policy BE10.

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

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

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

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

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

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

"The Delivery Approach and Legacy Management - setting out the expectations for how the phased delivery of the scheme should be approached to ensure proposals are viable and embed an ethos of co-design and participation, timely and good governance in delivery, and an embedded legacy management of the village assets.

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