Comment

Preferred Site Allocations 2018

Representation ID: 18299

Received: 12/03/2018

Respondent: Essex County Council

Representation Summary:

Infrastructure Planning - Minerals and Waste

Full text:

Minerals and Waste -

ECC is the Mineral and Waste Planning Authority for Essex. The Mineral Local Plan (2014) and Waste Local Plan (2017) form part of the development plan in Brentwood and therefore should be referenced as such within the opening pages of the Draft Plan.

ECC's response to the draft Local Plan in 2016 remains relevant and is attached as Appendix 2.

Minerals -

The Essex Minerals Local Plan (2014) (MLP) provides up-to-date planning policy for minerals development in Essex until 2029. In particular, it gives certainty as to the location of future minerals development by identifying sites and locations for the extraction of mineral deposits. There are also procedures to reduce the demand for primary mineral use, recycle more aggregate and safeguard mineral resources, reserves and important facilities.

There are deposits of sand and gravel within Brentwood Borough which are subject to Policy S8 Safeguarding Mineral Resources of the MLP. In line with national planning policy, Policy S8 identifies a Mineral Safeguarding Area (MSA) which covers large areas of the County where surface development will be resisted unless evidence can be provided to confirm that the resources are not viable/suitable for prior extraction.

There are areas around the urban area of Brentwood that are covered by a MSA for sand and gravel. In 2016, a high level assessment concluded that some proposed allocations in the Draft Local Plan fell within MSAs for sand and gravel. Now that new site allocations are proposed, it is necessary for mineral safeguarding matters to be thoroughly considered prior to inclusion in the Pre Submission Plan. ECC has provided assistance to all other Essex LPA's in relation to their Local Plans in this respect, by running a GIS based assessment process and identifying text for inclusion in site allocation policies where necessary.

It is essential that the preferred site allocations included in the Draft Local Plan are considered in respect of their mineral safeguarding implications. A GIS layer of the preferred sites should be provided to the ECC Minerals and Waste team as soon as possible to enable this assessment to take place.

Waste -

ECC is the waste planning authority for the Borough, and is responsible for preparing planning policies, and also for assessing applications for waste management development. The Essex and Southend-on-Sea Waste Local Plan (2017) (WLP) is a statutory Development Plan which should be read alongside the Draft Local Plan. It sets out where and how waste management developments can occur, and is the planning policy against which waste management development planning applications are assessed. The WLP does not allocate any strategic waste management allocations in the Borough. The WLP also identifies Areas of Search to meet the need for additional small scale waste management facilities. It identifies two Areas of Search within Brentwood Borough. These Areas of Search are existing industrial estates at Childerditch Industrial Estate and West Horndon and are located away from residential and other uses sensitive to amenity impacts such as schools, retail, leisure and office development. The WLP seeks to focus any new proposals for waste management facilities, which support the local housing and economic growth, within these Areas of Search.

The Brentwood Local Plan should refer to ECC's role as the Waste Planning Authority and to the adopted WLP. The draft Local Plan 2016 contained limited reference to waste management facilities, and in particular advice for their provision in the proposed Development Management Policies. Some advice is provided in line with European, National and Planning Practice Guidance, which seeks the promotion of the waste management hierarchy within sustainable development. In particular, ECC recommends reference is made in appropriate policies in the Draft Local Plan to enabling the provision of waste management facilities in employment areas, by referring to 'any associated employment generating sui generis uses', given that the WLP does not allocate any strategic waste management allocations in Brentwood Borough. ECC continues to support references to renewable energy schemes and sustainable construction.