Dunton Hills Garden Village 2017
Dunton Garden Suburb: Update 2017
Much has happened in the first half of 2017, yet the Brentwood and Basildon draft local plans remain unchanged for now. In January the plans submitted by Brentwood Council proposing Dunton Hills Garden Village were given government backing. In reality this just means that the council get a little money to carry out a study on infrastructure requirements. The plan must still be approved through the Local Plan process.
One thing we discovered later was that the proposal raised the number of houses from 2,500 to 3,500 as part of the deal to get backing. The council kept very quiet about it and we only found out through a Freedom Of Information request to obtain the proposal documents which we can now publish here. (Part 1 and Part 2) This change explains why more land is marked for development on the plans published earlier. It will mean even more traffic passing along the A128 to Brentwood where there is already considerable congestion through the villages of Ingrave and Herongate.
The Brentwood Local Plan itself has not changed or been submitted for examination despite the fact that the schedule still shows an adoption date in second quarter 2017. This schedule is supposed to be kept rigorously up-to-date but it is typical for Brentwood Council to ignore due process when it suits them. There was talk at a council meeting of a new consultation but even with all the elections out of the way everything has gone very quiet. Perhaps they are waiting for the outcome of the Housing White Paper consultation before taking any new actions, as this is likely to rewrite the planning rules once again.
Basildon Council objected to the Brentwood Plans and tried to persuade them to move the development a little further West so that they could keep their own plans for Dunton separate. If Dunton Hills Garden Village goes ahead it would be an ecological disaster, but it could also be a reprieve for the people of Dunton Village who may be able to keep their homes and a buffer of green belt between them and the development.
Then there were dramatic changes to the administration in Basildon when the opposition parties (UKIP, Labour, Wickford Independents and Independents from EU) finally decided to club together to oust the minority Tory administration that had been running the Council through the outdated cabinet system. When it became clear that the game was up and the council would switch to a committee based system of governance the Conservatives with their arms firmly twisted behind their backs instigated a review of the Local Plan to see if the number of houses could be reduced from its present value of 15,300. A new figure of 12,000 homes was mentioned which would give some scope to save areas of green belt around the borough. The stated opinion of Tory leader Phil Turner was that they would go through with the review but the likely outcome would support their view that such a reduction is not possible.
Then in a move at the Council's AGM, the opposition formed an accord to work together, ousting the Conservative regime entirely. The emerging Basildon Local Plan is now in the hands of the Infrastructure, Growth and Development Committee chaired by UKIP Leader Linda Allport-Hodge who has pledged to reduce the target to 10,000 homes saving Dunton and other areas of green belt. This is excellent news, but to achieve their goal they must beat neighbouring councils and the planning inspectorate who are very keen to see high housing growth. Pressure has grown with an update to the Thames Gateway Housing Market Assessment which increased the Basildon housing target to 20,000 homes. Basildon seems to have taken an unfair proportion of the overall increase for the region, and the situation may get even worse when Southend-on-Sea ask its neighbours to take on its own housing need which it has no room for. The final outcome could now depend on a race against the clock to complete the difficult process of review, rewrite and examination of the Local Plan within one year before the next elections in May 2018. Most of the UKIP, WI and IFEU councillors will stand for re-election giving the Conservatives a golden opportunity to retake control.
Dunton Hills Garden Village
Brentwood Council have prepared a new preliminary Local Plan for the Borough of Brentwood detailing housing and other development for the next 15 years. This was put to public consultation from 10th February to 23rd March 2016. This and earlier consultations have seen good participation from residents in Southern areas of the borough such as West Horndon, Ingrave and Herongate which have been threatened with the prospect of over-development.
In what must be the UKs most brazen act of NIMBYism, Brentwood council have refused to build on a proportionate quantity of land around their town. Only 1000 homes will be built on green-belt in extensions of the urban area of the town of Brentwood and along the A12 corridor. Compare that with Billericay where 1740 homes are proposed on green belt or Wickford which faces 3300 new homes of which 2100 are to be built on its green belt. Brentwood is 70% bigger than Billericay and the population along the A12 corridor from Brentwood to Ingatestone is as much as Billericay and Wickford combined.
Half of the homes for Brentwood Town's green belt are likely to be constructed in the next few years on Officer's Meadow
East of Shenfield Station
where a planning application is already pending. A scattering of other infill sites along the corridor will add a few hundred more homes.
The rest of Brentwood's unmet housing need
will be built four miles away from the town south of the A127. If the preliminary plan is approved there will be 500 new homes in West
This sounds like the perfect solution for Brentwood, no wonder they are keeping quiet, but it's not going to be that simple. The government are on a mission to build as many homes in the country as they can. England's countryside and rural villages are no barrier to their ambition. They are placing great pressure on planning authorities such as Brentwood Council to have a new Local Plan approved by March 2017. (Update: deadline was quietly put back to 2018) New measures guarantee that if that does not happen the consequences will be dire. To put it in a nutshell, by concentrating their building program along their Southern border, Brentwood is leaving itself open to the government stepping in to exploit the Northern half. To avoid this Brentwood council must act quickly because they are already the last council in England to begin consultations on a Local Plan compliant with planning policy introduced in 2011. Once it is prepared the plan will need to be examined and found to be sound by the government's planning inspectorate. If it fails the test there will be insufficient time to fix it.
Beyond the deadline for Local Plans the government may look at locations around the fringes of London for sites to build new garden cities. Legislation is already being introduced to allow the government to force development around underused commuter hubs such as Brentwood. The government has invested billions in Crossrail out to Shenfield and has earmarked £1.6 billion over the next five years for improvements to the A12 including widening all the way from the M25 through Brentwood to Chelmsford. In contrast Essex Council is struggling to find a few million just to improve junctions on the A127 which already faces the extra traffic of 30,000 homes to be built in Basildon and further East. It does not take much imagination to see how the planning inspectorate will view the tardiness and NIMBYism of Brentwood, nor to think of some of the likely things they will do about it, but just in case here it is spelt out in more detail.
Ten reasons why the Brentwood Draft Local Plan is unsound
Brentwood council can glibly answer public objections with condescending responses, until the time their Local Plan is submitted for examination by the Planning Inspectorate. From that day they will have to convince the assigned planning inspector of the soundness of their plan. Campaigning residents and other organisations will stop petitioning the council directly, and will make their case with representations to the inspector instead. The Inspectorate will test the plan against a wide set of criteria to determine its soundness. It will need to be consistent with the National Planning Policy Framework. It will have to be flexible and meet its objectives. The inspector will insist on robust evidence to justify each point. If the plan is found to be unsound they may ask for quick changes but if the problems are too many or too serious the examination process will be stopped and the plan will be sent back for revisions. This may require new evidence to be prepared and new consultations to be held. Needless to say, Brentwood has not left any time to allow for that process. The consequences that will follow mean that failure is not really an option, but unfortunately as the local plan now stands, failure is almost a certainty. Here are the top ten reasons why.
1. Meeting Local Needs
A Local Plan needs to meet the economic and social needs of its local residents and businesses. Brentwood's plan has a sufficient number of houses but they are not in the right place. It may meet the wishes of house owners in most areas by avoiding new developments near where they live, but it does not meet the needs of younger workers looking for their first home. House prices in Brentwood are some of the highest in Essex outside the M25. Key workers in the borough need affordable housing and they need it near to Brentwood, not Basildon. If a nurse or teacher lives next to Basildon they will look first for work there, not in Brentwood. If they do work in Brentwood they will have to travel by car along the already congested A128 through Ingrave and Herongate making their punctuality unreliable.
West Horndon and Dunton Hills may be part of the Borough of Brentwood but they are as far away from its heart as you can get. Other boroughs such as Basildon have ensured that urban extensions are spread evenly around the edges of their built-up areas. Brentwood has added its largest urban extension onto Basildon leaving Brentwood with only a fraction of the housing it needs. This is a glaring flaw in the Brentwood Local Plan and it will be the first thing the Planning Inspectorate notices.
It is a central tenet of national planning policy that all development must be sustainable. Planning authorities must show that they have funding sources for roads, schools and health services in place for the next five years of development and a realistic plan for infrastructure improvements after that. If Brentwood were to build primarily along the A12 corridor they would have no difficulty fullfilling this condition. Crossrail is increasing rail capacity for commuters from Brentwood into London. It will carry travellers on shorter journeys alleviating the load on the existing lines, allowing more express trains to be scheduled. No corresponding investment has been made for the c2c line passing through Basildon which is just a two track line compared to Brentwood's four track rail system.
Although the A12 is already an overburdened route it is in a much better state than the A127 where Brentwood wishes to put its houses. A fund of £1.6 billion has been included in the Road Infrastructure Strategy 2015-2020 to widen the A12 through Brentwood bringing it to near motorway standards. In contrast the A127 only has a few million in funding presently available for junction upgrades nearer Southend. Continuing austerity and the difficulty of widening through Basildon means that this situation is unlikely to change any time soon.
Brentwood is also better provided with secondary schools and health services than Basildon. Two new free schools (Ongar Academy and Becket Keys) add to the existing wide choice of schools available to pupils of North Brentwood. In Langdon Hills in the West of Basildon near where Brentwood wishes to build more houses, 85% of secondary school aged children travel long distances to nore than 20 different secondary schools outside Basildon including those in Brentwood.
3. Green Belt Protection
National planning policy affords strong protection for the green belt but allows planning authorities to review green belt boundaries in exceptional circumstances. Economic growth is one of the justifications that could be used to allow such a change but Basildon is already catering for its own growth and does not want additions from Brentwood. The main purpose of green belt is to prevent urban sprawl but the large urban extension proposed at Dunton Hills would take out a large section of the green belt that is keeping Basildon separated from London.
If Brentwood council want to go ahead with what will be the largest development of a single area of green belt ever to be undertaken, then it will need to show solid evidence that the exceptional circumstances are sufficient to warrant it. Basildon Council who have worked with Brentwood on the Dunton Garden Suburb proposal has stated that such evidence has not yet been provided. Unlike most councils who plan to release green belt, Brentwood has not even carried out a green belt review to determine which areas of the borough are supporting the purposes of the green belt. It is very hard to see how the planning inspectorate could allow this to go unchallenged.
4. Traveller Provision
Uk planning law demands that planning authorities make adequate provision for the traveller and gypsies community. This may not be popular but the planning inspectorate will not let any omission pass them by. Brentwood must put in place a solid plan to meet its need which has been assessed as 59 additional traveller pitches. So far Brentwood's only proposal has been to create a traveller site at Dunton Hills as part of the 2500 home development in that area. The problem with this is that the maximum manageable number of pitches within a site has been determined as 15. This will be strongly enforced in urban areas where harmony with the settled population is a prime concern. A single traveller site of 59 pitches within an urban area would have the characteristics of a gheto. Four separate sites in the same urban area would not make the situation any better. Brenwtood will therefore have to find an alternative solution involving at least four distinct locations around the borough.
5. Duty to Cooperate
At the end of 2014 Brentwood and Basildon signed a Memorandum of Understanding to hold a joint consultation over a proposed development of 4000-6000 homes across Dunton Hills in Brentwood and Dunton Village in Basildon. The move was imposed on Basildon by Brentwood under the principle of Duty to Cooperate in the Localism Act and has always been fiercely opposed by both councillors and residents of Basildon.
Emails between Basildon and Brentwood released under the Freedom of Information Act show that after the consultation ended, Basildon politely but repeatedly pushed Brentwood to complete work on reviewing the comments and hold a meeting between councillors. The meeting appears to have never taken place and Basildon has stated that insufficient evidence has been presented to continue with the project. The Memorandum of Understanding will expire on 3rd February 2016 without conclusion.
Despite this Brentwood has decided to continue with its half on Dunton Garden Suburb which it has renamed as Dunton Hills Garden Village. Proper adherence to the principle of Duty to Cooperate is an important test of the Local Development Framework that the planning inspectorate will apply. It is difficult to see how they could regard this as a pass.
Councils have a duty to promote biodiversity and protect wildlife habitats in their area. For Dunton Hills they carried out only a very cursory impact assessment. Crucially, this initial survey failed to note the existence of a Local Wildlife Site along the Mardyke tributary through Dunton Hills despite it being listed in Brentwoods own guide to important wildlife sites. The council will certainly need to do much more given the size of the development and its location between the two country parks of Thorndon and Langdon Hills. Needless to say they are planning to go ahead without any such study having been commissioned.
Objectors to the development invited the Essex Wildlife Trust to view the site and made this video showing how wildlife experts were able to find evidence of important wildlife species in the area including a rare barn owl. Conservation Officer Dr Annie Gordon who is a development expert for the trust described the site as an important wildlife corridor whose hedgerows, ditches, ponds and ancient woodlands provide an important area for the movement of wildlife.
7. Public Consultation
The result of the Dunton Garden Suburb consultation was that 84% of comments were opposed to the development and only 6% were in favour. More significantly there were many valid points of objection raised in the consultation both by residents and by public and private bodies including Essex County Council and neighbouring councils Thurrock, Basildon and Havering. It is likely that other important comments were submitted by organisations such as the NHS, Network Rail, Natural England and many others. We don't know if they were for or against or if they raised important objections because their comments have not yet been published as they should have been long before the next stage of the plan preparation proceeds. All we do have is a brief Statement of Consultation document summarising some of the points raised and a few statistics.
It is bad enough that the council have choosen to ignore an overwhelming opposition to the development. To not publish the full comments and provide individual responses is completely irresponsible. Carrying out public consultations correctly is a fundamental requirement for the preparation of the Local Plan. Update: Under pressure from campaigners Basildon and Brentwood councils have now stated that the valid comments submitted to the Dunton Garden Suburb consultation will be published on the 28th of January 2016. Responses are still outstanding.
Brentwood council will have to do two more public consultations on the Draft Local Plan. Since they have not provided any answers to previous comments submitted to the Dunton Garden Suburb consultation or the related Strategic Growth Options consultation it is inevitable that all the same points will be made again. How the planning inspector will react to the way this has been done depends on whether they get better at it or worse and that remains to be seen.
The Local Development Framework soundness guide also tells us that a Local Plan is required to be flexible. It should be able to respond to changes in circumstances. Putting more than half the housing development in a small area south of the A127 is anything but flexible. Any problem that blocks development in this area will leave Brentwood unable to fullfil a large part of its housing target. There could be issues with flood mitigation because surface water runoff from Dunton Hills will flow into the Mardyke river which is already prone to flooding. There could be problems with transport infrastructure if funding is not found for the necessary road and rail upgrades. There might also be problems if an Environmental study finds important protected habitats in the area.
Running on time in preparing the Local Plan is another necessity for soundness. Because Brentwood are so late to reach this stage they have set a very tight schedule for themselves. This may be one of the reasons why they are proceeding without completing the earlier consultation responses properly, but it is no excuse. The consultation for the Draft of the Local Plan was scheduled to take place in the last quarter of 2015. the date is now set for Feb/Mar 2016 meaning that they are already three months late. Completing the preparation before the governments deadline of early 2017 is probably already impossible.
The Local Plan is being prepared by Brentwood's planning officers under the direction and scrutiny of the borough's councillors. This can only be done effectively if the councillors understand how the plan works. Do they? Watch the webcasts of their council meetings and decide for yourself. Basildon council held a series of five well-attended seminars to train its councillors on the details of their draft plan before they voted to take it to consultation. The lack of a similar program in Brentwood could account for failure of their members to recognise the multiple issues they face. The Dunton Garden Suburb proposal has enjoyed unanimous cross-party support from the Brentwood Council.
The consequences for Brentwood
What will be the consequences of these problems with Brentwood's Local Plan? Nothing is certain. It depends on the sympathies of the individual planning inspector who examines the plan. It also depends on any further changes the government makes to planning policy, and on how well Brentwood can manage their finances. However, some of the things that could happen are very serious.
Brentwood's local plan could be found unsound
Given the above ten reasons why the local plan should be found unsound it is not hard to predict that it will be found unsound, but that is by no means certain. The planning inspectorate may be happy enough to see that Brentwood is committed to building lots of houses and won't care about the consequences. If that does happen it is possible that retribution will only be delayed. If it is however found unsound the deadline will be passed and the government will take over preparation of the plan with much less consideration for local residents. Brentwood may then find itself with a plan involving large scale development both in the South and the North.
Brentwood could go bankrupt
In a motion moved by Cllr Clark at full council on 27th January 2016 the following statement was recorded:
All local councils are suffering from severe cutbacks in government funding, but how many have managed their finances so badly that a statement like this needs to be made? The New Homes Bonus paid out to local authorities by the government when new homes are built is increasingly becoming an essential source of income rather than an additional bonus. Some people say that it is funding schemes such as this that are driving councils to propose more house building than necessary even if it means traffic jams, pollution, over-run hospitals and destruction of precious green belt.
A new government proposal which is likely to become a reality is that they will withhold all New Homes Bonus payments if a council does not have an approved Local Plan in place. This could be the final straw for Brentwood's finances. Even if the Local Plan is found sound there could be problems due to further delays in preparing the plan or due to obstacles which prevent them from building on Dunton Hills.
The government could take over the Brentwood plan
David Cameron has pledged to take over any planning authorities Local Plan preparations if they are not ready by early 2017. No council looks more in danger of overshooting the deadline than Brentwood. What kind of plan would they put in place? Given the government's desperate house building ambitions, assume the worst.
Developers will be able to build wherever they wish
It sounds unbelievable but the government is introducing legislation that says if a council has not completed its Local Plan then developers will have a strong advantage in appeals for planning applications, even if they intend to build on the green belt. Brentwood would have to accept most planning applications simply because it could not afford to fight appeals that it would stand a high chance of losing.
Infrastructure funding could be cancelled or diverted
Under the present Road Infrastructure Strategy for the next five years Brentwood will benefit from £1.6 billion of investment in the A12. Such funding plans can easily be reviewed. If they won't build enough houses in Brentwood while Basildon plans to increase its housing on a large scale it is a distinct possibility that funding will be cancelled or directed to the A127 instead.
A garden city could be built in North Brentwood
This is the nightmare scenario for Brentwood but could it happen? Garden cities of 150,000 homes or more have often been touted as the solution to Britain's housing crisis. For now the alarms have gone quiet and everyone hopes that other strategies to increase house building numbers will be sufficient. By the middle of 2017 it will become clear how well policies have worked based on traditional Local Plans. If the conclusion is that there are not yet enough houses to be built, the government will have no option other than to start planning garden cities. Areas most likely to succumb will be those around London and close to commuter hubs especially where fewer homes are planned and investment in infrastructure has already started. Does that sound like any place you know?
What should be done?
Brentwood residents need to end their blind trust in their councillors and look at the Draft Local Plan themselves via the consultation portal.
Brentwood could declare its green belt as a constraint to development. This is something that National Planning Policy has allowed for and the government have repeatedly confirmed in public statements. However it might leave Brentwood short of cash from the housing bonus schemes and open to imposed development in areas where infrastructure is strong.
A more sound plan might be one where building on the green belt is spread around existing urban areas, especially the town of Brentwood itself. The borough of Brentwood is lucky in that their objectively assessed housing need only requires them to build 5500 homes and lose 1% of their green belt. Compare this to the borough of Basildon which plans to release 7% of its green belt to meet its need of 15300 homes. The flipside for Brentwood is that its location and low density of housing will make it a target to fill any housing shortfall that remains outstanding after current policies for new housing have been exhausted. If Brentwood don't take on their fair share of house building now, they may be hit harder later on.
This report has been prepared by RAID (Residents Against Inappropriate Development.) Join our facebook group Dunton Garden Suburb to find out more.