Comment

Preferred Site Allocations 2018

Representation ID: 18261

Received: 12/03/2018

Respondent: Essex County Council

Representation Summary:

See above.

Full text:

ECC welcomes the inclusion of a clear set of strategic objectives. It is recognised that BBC is seeking to ensure the strategic objectives are consistent with the national planning guidance through managing growth; creating sustainable communities; seeking economic prosperity; protecting and enhancing the environment; improving quality of life and providing community infrastructure; and addressing transport and movement matters. This is consistent with the PPG. However concern is raised with the increase in objectives from the 2016 Draft Local Plan (13), to the current consultation (23), and whether they reflect the strategic priorities for the Borough, or whether they are providing more detail which should be reserved for the policies within the Plan.

The strategic objectives clearly send the message that the purpose of the new Plan will be to align key infrastructure with sustainable growth, the development and resilience of health and wellbeing, creating a prosperous economy, whilst protecting the environment. ECC welcomes the anticipated benefits of this approach.

ECC seeks clarity on how Objective 13 (protecting the core office market) may be achieved. Recent evidence does not suggest that this is being supported, with existing commercial sites having been, or still being at risk of being lost to residential, including Library House, New North House, and BNY Mellon House.

ECC welcomes the protection and enhancement of the environment through Objective 16.

ECC is supportive of Objectives SO17 and SO22 in terms of BBC's support for enhancing the green infrastructure network and connectivity across the Borough. ECC is also supportive of Objective SO23 regarding supporting a low carbon future and inclusion of electric vehicle charging points.

Objectives S021, S022 and S023 all cover Sustainable Transport and the document makes reference to the fact that sustainable transport is central to their plan making, which is supported in principle by ECC.

ECC acknowledges and supports the need for improvements for sustainable travel and the need for modal shift, however there are areas of the strategic highway network such as the A127 that will require significant mitigation measures if economic growth is to be realised.

ECC is concerned that the Objectives that cover transport and movement (S021, S022 and S023) do not recognise the need for highway infrastructure to facilitate movement of goods / commuters.

As Highway Authority, ECC acknowledges the following strategic objectives, namely SO2 (Growth in transport corridors); SO5 (Growth accommodated by existing or proposed infrastructure), SO19 - (secure delivery of transportation and community infrastructure). ECC also welcomes the addition of the specific transport and movement strategic objectives SO21 (public transport infrastructure and connections), SO22 (cycling, walking and green transport corridors), and SO23 (infrastructure for low carbon future) in the Draft Local Plan.

ECC also recommends that reference be made to ensuring that proposals address the need for strategic and general highways infrastructure.

In order that the strategic objectives are met it is imperative that timely and appropriate highway modelling is undertaken. Further comments relating to highways and transportation matters are provided in the Spatial Strategy section below.