1. Introduction

(12) Brentwood Local Plan 2016-33

(2) 1.1 This Pre-Submission Local Plan (Publication Draft, Regulation 19) presents Brentwood Borough Council's vision for how the borough will develop over the next 17 years, from 2016 to 2033. It outlines the Council's strategic priorities and sets out a Spatial Strategy and supporting policies for achieving this vision.

1.2 The Plan identifies locations to deliver local housing needs and supporting infrastructure, such as employment, retail, leisure, community and transport. It allocates land for appropriate development, sets out strategic planning policies and an overall strategy to guide decisions on the location, pattern, scale, and quality of development and/or changes in the way land and buildings are used.

1.3 Once adopted, the Local Plan will be a statutory document and a material consideration in determining planning applications.

1.4 Policies and proposals set out in this document are also illustrated on the Brentwood Policies Map. The map identifies areas of opportunity within the borough for employment and housing, as well as important local assets that will be protected and, where possible, enhanced.

(7) Plan Period and Review

1.5 The Plan period is from 2016 to 2033 inclusive. Considering the lead-up to adoption, this will ensure the period shall be for a minimum of 15 years. Nevertheless, the Local Plan will not remain a static document and will, in line with the legal requirement set out in Regulation 10A of the Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended), be reviewed at least every five years to ensure it is still delivering on its strategic priorities in the best way possible.

1.6 At the time of writing, there are many global challenging influxes that could alter the outlook of the Plan; for example, the decision to leave the European Union, technological advancement especially in relation to the transport and utility sectors, new housing calculation methodologies, and joint strategic work across South Essex. While these conditions have been taken into consideration as far as possible to ensure the future-proofing of the Plan, it will be necessary to ensure that changing circumstances are reflected within the Plan Period. The Council will maintain a watching brief on advancements and respond accordingly.

(2) Plan-Making Process & Next Steps

(1) Local Plan Regulation 19 Stage

1.7 This document constitutes the Pre-Submission Local Plan (Publication Draft), published in accordance with Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012 which Brentwood Borough Council proposes to submit to the Secretary of State.

1.8 This Plan has been informed by representations received in response to previous consultations, including Preferred Options in 2013, Strategic Growth Options in 2015, Draft Local Plan in 2016, and Preferred Site Allocations in January 2018. The consultation process so far is depicted in Figure 1.2. All consultation documents and assessments of representations received are available to view on the Council's website at www.brentwood.gov.uk/localplan.

1.9 This Pre-Submission consultation is the final stage before the Local Plan is submitted to the Secretary of State for an Examination-in-Public, to be undertaken by an Independent Planning Inspector. In accordance with Regulation 20 of The Act, any person may make representations on Pre-Submission Local Plan. Representations must be received by Brentwood Borough Council by the date specified in the statement of representations procedure.

1.10 Representations received will form a Statement of Consultation and be published alongside an updated Local Plan showing the proposed modifications as a result of the Regulation 19 Consultation.

Figure 1.2: Consultation Process So Far

(23) Duty to Cooperate

1.11 Brentwood Borough Council has a duty to engage constructively, actively and on an ongoing basis with neighbouring local planning authorities, the County Council and other statutory public bodies to ensure strategic issues that may impact the wider area are considered. This includes cross boundary issues such as transport, flooding, and environmental impacts.

1.12 This legal requirement was set out in Section 110 of the Localism Act 2011 and the further amendment of section 33A of the Planning and Compulsory Purchase Act 2004. Maintaining effective cooperation is also reinforced by the NPPF (2018, paragraphs 24-27), which calls for one or more 'Statements of Common Ground' to be prepared and maintained on cross-boundary matters being addressed and progress in cooperating to address these. These are to be made publicly available.

(1) 1.13 The Council is committed to cooperate with neighbouring authorities and key organisations on strategic planning issues. Since January 2018, a Memorandum of Understanding was signed between Basildon, Brentwood, Castle Point, Essex County, Rochford, Southend-on-Sea and Thurrock Councils – forming the Association of South Essex Local Authorities (ASELA), which agreed to jointly work on 'place vision' for the region. This new venture will continue to look across borough boundaries. This work is progressing at early stages and Brentwood Borough Council is committed to engaging with partners as discussions and evidence gathering progresses through the plan-making process.

1.14 The Council will publish a Duty to Co-operate Position Statement to describe the ongoing engagement and provide an update on the activities undertaken so far.

(1) 1.15 In addition, the Council will continue to have regards to neighbouring authority plans, Essex County Council plans, and strategies of other relevant bodies.

(30) Evidence Base

(2) 1.16 The Pre-Submission Local Plan is supported by evidence from a variety of sources, which can be found on the Council's website at www.brentwood.gov.uk/localplan.

(1) 1.17 Evidence is presented in the form of technical studies that identify key issues and strategic priorities for transport, leisure, housing, among others. The Council has carried out a Sustainability Appraisal to test the evidence underpinning the Plan and help demonstrate that the Plan, when judged against reasonable alternatives, will help achieve sustainable development. The Council has also undertaken engagement and consultation to address issues being raised by local communities and other interested parties. This approach has shaped preparation and content of the Local Plan.

1.18 Additionally, a Brentwood Borough Profile has been developed, serving as an illustrative summary of the borough's key issues that have been considered as part of the plan-making process.

(22) Sustainability Appraisal

(1) 1.19 As stated above, a Sustainability Appraisal (SA) has been carried out at key stages in the plan-making process, in line with the Environmental Assessment of Plans and Programmes Regulations 2004. The Sustainability Appraisal recommendations at each stage have informed the production of this Pre-Submission Local Plan.

(1) 1.20 The SA has considered potential impacts of the Plan on economic, social and environmental considerations and how they can be mitigated. It has also considered several reasonable alternatives to ensure Brentwood's growth strategy is sound. The Sustainability Appraisal is available for public consultation alongside the Pre-Submission Local Plan.

(2) Habitats Regulation Assessment

(1) 1.21 In accordance with Regulation 61 of the Conservation of Habitats and Species Regulations 2010, a Habitats Regulation Assessment (HRA) screening has been undertaken to determine whether the Pre-Submission Plan is likely, either alone or in combination with other plans and projects, to have a significant adverse impact on internationally important habitat sites.

(1) 1.22 To assess the in-combination impacts of new development, a need to prepare a Recreational disturbance Avoidance and Mitigation Strategy (RAMS) has been identified for the Essex Estuaries and Coastal sites. A RAMS is being prepared to cover these sites, with a view to their subsequent adoption as a Supplementary Planning Document (SPD) by the Council. Residential development that is likely to affect the integrity of European Sites, is required to either contribute towards mitigation measures identified in the RAMS or, in exceptional circumstances, identify and implement bespoke mitigation measures to ensure compliance with the Habitat Regulations.

(1) 1.23 Similar work assessing in-combination impacts on the Epping Forest is being considered by the Council and partners.

(1) Planning Policy Context

1.24 The Local Plan has been prepared in line with the relevant Acts (Planning and Compulsory Purchase Act 2004, the Localism Act 2011, and the Town and Country Planning (Local Planning) Regulations 2012. It also takes account of the National Planning Policy Framework (2018), Planning Practice Guidance and national planning policies (Planning Policy for Traveller Sites 2015).

1.25 This Local Plan must be read as a whole. Proposals will be considered against all relevant policies set out in this Plan. Additionally, this Local Plan will sit alongside other key policy documents that currently exist or that may come forward during the lifespan of the Plan, which together will form the borough's development framework and be used to make decisions on planning applications:

1. Essex County Council plans, such as transport strategies, education plans, economic growth priorities, and minerals & waste policy;
2. Future neighbourhood plans, which will provide more detailed planning policies to help shape the development of specific neighbourhoods; and
3. Future sub-regional plans, such as the South Essex Joint Strategic Plan.

Minerals Local Plan

1.26 Essex County Council is the Minerals Planning Authority for the Borough. The County Council is responsible for preparing planning policies and assessing applications for mineral development. The Essex Minerals Local Plan (2014) forms part of the statutory Development Plan and should be read alongside the Brentwood Local Plan. The role of the Minerals Local Plan is to ensure a steady and adequate supply of mineral resources to facilitate development over the Plan period and beyond.

(1) 1.27 There are currently no active quarry sites in Brentwood. However, there are unworked sand and gravel deposits which are subject to a Minerals Safeguarding policy within the Essex Minerals Local Plan 2014. The safeguarding policy requires that Essex County Council, as minerals planning authority, be consulted on development proposals covering five hectares or more within the sand and gravel Minerals Safeguarding Area.

1.28 Requirements of the Minerals Local Plan need to be considered where a development falls within a Minerals Safeguarding Area. The Minerals Local Plan also designates Mineral Consultation Areas at a distance of 250m around active quarries, mineral infrastructure and mineral deposits permitted for extraction. Essex County Council must be consulted on all non-mineral related development proposed within these Consultation Areas.

Waste Local Plan

1.29 Essex County Council is also the Waste Planning Authority for the Borough. Essex County Council provides waste disposal infrastructure to ensure waste generated by households, and other wastes collected by Councils in Essex, is effectively managed. Brentwood borough is the Waste Collection Authority and is responsible for the collection of this municipal waste^[1].

1.30 The County Council is responsible for preparing planning policies and assessing applications for waste management development. It noted that the delivery of local plans which increase residential development, through both infilling and major developments, will impact on waste management systems on a number of levels as the resultant population growth will lead to an increase in waste arisings which require handling and disposal.

1.31 The Essex and Southend-on-Sea Waste Local Plan was adopted in July 2017 forming part of the statutory Development Plan and should be read alongside the Brentwood Local Plan. The Waste Local Plan covers the period 2017 to 2032. It sets out where and how waste management developments can occur and contains the policies against which waste management planning applications are assessed.

(1) 1.32 The Essex and Southend-on-Sea Replacement Waste Local Plan does not propose any new waste development in Brentwood. However, the Waste Local Plan does identify a number of areas of search across the county where the Waste Planning Authority may support development outside of allocated waste sites. These areas of search are all existing industrial estates, and any waste use proposed on these estates will be required to be in keeping with existing development. The Waste Local Plan seeks to focus any new proposals for waste management facilities, which support local housing and economic growth, within these areas of search before other locations are considered. Two are proposed for Brentwood Borough, at Childerditch Industrial Estate and West Horndon Industrial Estate.

1.33 In addition, the Municipal Waste Strategy (2017-2032) is in the process of being updated and ECC is in consultation with the Essex districts, including Brentwood. The major waste treatment infrastructure currently in place for managing Local Authority Collected Municipal Waste has been equipped to accommodate the anticipated waste growth levels resulting from the proposed Local Plan growth. The strategy will review current sites (smaller waste facilities and recycling centres for household waste) and may result in changes to their location, rationalisation, and/or increased capacity. A review of existing and potential facilities will be taking place during the first five-year local plan period to determine requirements in the 10-15 year period. This is likely to result in a need to extend or expand this infrastructure offer to meet local needs. However, at this stage it is not possible to determine what these needs are.

(1) 1.34 The Plan also designates Waste Consultation Areas at a distance of 250m around permitted and allocated waste management facilities. Essex County Council must be consulted on all non-waste related development within these areas to ensure that the proposed development would not adversely impact on their existing or future operation. The Brentwood Policies Map identifies existing waste sites within the Council's area.

(2) South Essex Joint Strategic Plan

1.35 In Summer 2017, the Leaders and Chief Executives of South Essex – Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council – embarked on a process to develop a long-term growth ambition that would underpin strategic spatial, infrastructure and economic priorities across the sub-region. The 'South Essex 2050 Ambition' is now being taken forward through a number of workstreams, including a spatial strategy delivered through a Joint Strategic Plan (JSP).

1.36 In January 2018, the authorities formed the Association of South Essex Local Authorities (ASELA) to ensure that implementation of the ambition has strong leadership and is managed on a truly collaborative basis.

1.37 A key task arising from the new joint working arrangements is the preparation of a Joint Strategic Plan. There is an ambition for this to deliver the homes and jobs needed in South Essex through partnership working, not just at a local level, but also with government, to bring forward the strategic infrastructure improvements to transport, education, health and green infrastructure that are needed to support growth.

1.38 Work on the Joint Strategic Plan is at an early stage with adoption expected in 2020. The Brentwood Local Plan will contribute towards some of the growth requirements early in that Plan. However, following the adoption of the Joint Strategic Plan it may be necessary to review the Brentwood Local Plan, at least in parts, to ensure any opportunities for further growth and infrastructure provision in the Borough identified in the Joint Strategic Plan can be realised.

Local Enterprise Partnership

1.39 The South East Local Enterprise Partnership (LEP) is the business-led, public/private body established to drive economic growth across Essex, Kent and East Sussex. Whilst the LEP has no statutory land use planning powers, it is responsible for determining local economic priorities and undertaking activities to encourage economic growth and local job creation. The Council will continue to work with the LEP and partners to realise economic growth potentials in the borough.

Figure 1.3: Local Plan Policy Context