Object
Draft Local Plan
Representation ID: 14262
Received: 14/04/2016
Respondent: Thurrock Borough Council
Thurrock consider the following require new or updated evidence, and therefore consultation, for the reasons given:
Objectively Assessed Need: population projections used are out of date. Figures were pubished in 2015 and the 2014 set of sub-national population projections (SNPP) in May 2016.
Economic Futures Report: as with the OAN, demographic forecasts and household projections based on EPOA Phase 6 study scenarios or earlier information is out of date.
SHMA requires updating as based on 2011/2012 demographic figures. Also disagree that Brentwood has a high level of self containment
Dunton Masterplan - including deliverability and phasing
Green Belt Review: Strong failure of Brentwood for failing to undertake a formal comprehensive Green Belt review to date. As Brentwood can only accommodate some of hte objectively assessed housing need on borwnfield land in the urban area it is considered this represents the exceptionsl circumstances for Brentwood to undertake a Green Belt review.
Park and Walk scheme referred to but no strategy or policies relate to this.
Viability Assessment, particularly of strtegic proposals
Road Capacity, Impact and transport eidence - including any proposed mitigation
Landscape Impact
Employment Provision at Brentwood Enterprise Park
Concern that evidence not made available for respondents to maek a full and informed review. Unclear how evidence has been used to develop Strategic Growth Options 2015 and Preferred Options 2013.
Impact on Thurrock Housing Market
Infrastructure and Public Expenditure Funding
The following were proposed in 2015 but are not available with the plan:
Green Infrastructure Plan
Landscape Capacity Assesment
Housing Viability Study
Crossrail Economic Impacts
Highways Modelling
Open Space Study
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.