Object
Draft Local Plan
Representation ID: 14381
Received: 14/04/2016
Respondent: Thurrock Borough Council
Thurrock Council considers the approach set out in the Interim Sustainabilty Appraisal (SA) is flawed and that a number of assumptions on the way that options have been scored is not supported by the available evidence.
The Interim SA does not adequately include or reflect in paragraph 6.2.9, Thurrock Council's concerns about development focused on the A127 corridor and impact on Green Belt and Landscape. Paragraphs 6.2.11 to 6.2.12 also do not include a reference to Thurrock Council's fundamental concerns about the deliverability, viability and impact on Green Belt and Landscape of the Dunton Garden Suburb.
The SA appraises and scores six options for the location of development with the assumption that most development would be located in one of the locations and with a strategic scale of development. Whilst this may be useful as an initial approach it is considered that actual development may result in a hybrid of such options with development in several key locations but not necessarily the dispersed option or one strategic location. A hybrid option may well moderate the scoring and impact of development in these locations therefore giving more positive scores rather than a large scale concentration of development.
It is noted that further assessment needs to be undertaken of urban extensions around Brentwood. A new option should be considered including development north and east south east of Brentwood/Shenfield. Again this may result in different scores for a Brentwood Town based option. Such an option is likely to give different scores than presented in the report.
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.