Object
Draft Local Plan
Representation ID: 14330
Received: 14/04/2016
Respondent: Thurrock Borough Council
Thurrock Council is fundamentally opposed to any large scale Strategic Green Belt releases either at Dunton Hill Garden Village as put forward in the Brentwood Local Plan consultation or the previous option for the Dunton Garden Suburb. The assumption that the A127 has greater potential for growth is questioned. Thurrock Council highlights the key concerns in relation to the A127 Corridor strategic corridor below and in response to Policy 6.6 Strategic Sites:
*Significant impact and harm to the openness of the Green Belt;
*Coalescence of settlements;
*Detrimental impact on the Landscape;
*The lack of certainty regarding the deliverability of the development;
*Lack of detail on location and phasing of such a development;
*Lack of detail on the viability of such a proposal;
*Impact of the scale of development on adjoining housing markets and ability of
Thurrock to deliver its housing;
*Infrastructure delivery and funding;
*Impact on strategic highway network - A127, A128, A13;
*Impact on the local highway network including within Thurrock;
*Lack of transport modelling and mitigation measure;
*Impact of possible LTX crossing route on land and infrastructure capacity;
*Assumption and scoring in the SA/SEA.
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.