brentwood.gov.uk

ECC acknowledges that the Interim SA Report identifies a good range of both high level and more focused options for exploration, with a clear narrative throughout as to what constitutes a 'reasonable alternative'. This is an important step at this stage in the context of the plan-making process to date and the issues that BBC has faced.

ECC considers that Table 6.2 presents a thorough and useful number of options / permutations related to a spatial strategy for the Plan area. The findings of the Interim SA in regard to the 'preferred allocations' however is similarly high level and is limited to the identification of general cumulative impacts over a broad area. It is considered that the Interim SA should offer more commentary and recommendations regarding the assessment of sites at the 'local / micro level' in order to justify some of the high level conclusions. This is in light of the wide range of impacts identified within the individual site assessments in Appendix III which do not appear to be elaborated on.

ECC also recommends further cumulative impacts could be identified at a more local level. This could serve to further assist BBC in both the site selection of small sites in an area, and also the development of site specific policies at the Regulation 19 stage.

ECC notes that the Interim SA takes the same approach as the 2016 Interim SA when arriving at reasonable alternatives, which seeks to develop the reasonable alternatives for strategic level growth arising from work undertaken in 2015/2016, rather than the overall SA process. ECC recommends that a comprehensive audit trail of those alternatives that have been considered and subject to SA throughout the plan-making process should be produced, including detailing the reasons for rejecting and progressing alternatives at each stage. In addition, the cumulative assessment of the 'givens', for the purposes of satisfying the requirements of SA, should be presented, alongside their cumulative impacts to inform the strategy proposed.

In paragraph 6.3.2 of the Interim SA, reference is made to significant concerns raised to the DHGV allocation in the 2016 consultation having been addressed. ECC seeks clarification as to how these concerns have been addressed, particularly those raised in the ECC response to the BBC 2016 Draft Local Plan.

ECC would draw attention to a number of the conclusions on the Draft Plan in Chapter 10 of the Interim SA, which appraises the Draft Local Plan. It is clear that a significant amount of work is still to be undertaken to address concerns and uncertainties, and ECC seeks clarification that these matters will be addressed as part of the preparation of the pre-submission plan.

Areas of concern as to certain conclusions in the SA are as follows:

* Air Quality - concludes that no significant effects are likely to occur, however highlights there is considerable uncertainty at the current time ahead of further work still to be undertaken, including highway modelling;
* Climate Change - concludes that no significant effects are likely to occur, however highlights there is considerable uncertainty, with further work still to be undertaken, in relation to how the Plan can reduce CO2 emissions, including from transport;
* Economy and Employment - concludes possible significant effects, but uncertainty in the absence of detailed transport modelling;
* Landscape - concludes that there are likely to be significant negative effects; further work required to identify developable parts of sites and strategic open space and landscaping;
* Soil and Contamination - concludes that there are likely to be significant negative effects; an increase in the number of homes required is likely to increase the amount of agricultural land to be lost, some of which is likely to be 'best and most versatile';
* Water Quality and Water Resources - concludes effects are currently uncertain; need for detailed examination of waste water treatment capacity, and further work for robust DM policy to be in place.

ECC welcomes the comments in relation to the following:
* Biodiversity - further work to focus on borough-wide and site specific policy on ensuring development achieves net biodiversity gains
* Community Infrastructure - work on-going to understand issues, working with partners including ECC
* Flooding - thematic and site specific policies to be examined further including master planning and SUDs
* Waste - some waste infrastructure capacity issues locally to be addressed

In terms of assessing heritage in the SA, it is clear that listed buildings and conservation areas have been considered, however there is no reference to the extensive archaeological remains within the Borough. ECC considers that a Historic Environment Characterisation report, including consideration of archaeology, should support the preparation of the draft Local Plan.

ECC also recommends that Section 13.1.2 incudes a bullet point on the impacts for archaeology and historic landscape.