brentwood.gov.uk

Background
By way of background, RPS submitted representations to the draft Brentwood Local Plan Regulation 18 consultation in March 2016 (referred to 'March 2016 Representations'), which set out the policy context regarding travelling showpeople's plots and sites (also referred to as a showmen's yard). Our representations sought the allocation of land at the former Chequers Public House on Chequers Road for use as a showmen's yard/travelling showpeople's site. Those representations set out a number of objections to the draft Local Plan which then excluded provision for showpeople's provision and explained why the site should be appropriate for designation as a Travelling Showpeople's Site. Those representations remain relevant here (we will explain below) but are not specifically repeated for brevity reasons. It is requested that the Council apply those representations to this consultation, in conjunction with further representations below.

It is noted here that the only relevant change to those representations would relate to a planning permission which was granted for the demolition of the public house and its replacement with a single dwelling (Ref: 16/00344/FUL), which were under consideration at the time when those representations were made. The proposals for a showmen's yard on the property associated with that application were withdrawn before determination.

In more recent developments, our client has recently submitted an application for a Lawful Development Certificate (Section 191 application) for an existing use of the land for storage purposes (Class B8). This application is currently being considered by the Council under reference: 18/00323/S191. It relates to a significant portion of the land towards the rear of the former public house, which was assessed in our March 2016 Representations as being a suitable location for travelling showpeople's plots and yard.


Representations
Paragraphs 46-49
RPS objects to the references in Paragraphs 46-49 on the basis that it makes no reference to a provision of showpeople's plots in accordance with Government guidance (Planning Policy for Travellers), for which RPS considers there is a need. Reference is made to the Brentwood Gypsies and Travellers Accommodation Assessment (GTAA) (October 2017), which identified that there were no travelling showpeople living or located within Brentwood at the present time and so there was no current or future need for additional plots. However, this does not necessarily reflect the situation regarding neighbouring authorities, where a shortfall in provision exists (in this case Thurrock District) and where these authorities may not be able to accommodate this need within their own administrative area due to a variety of factors. In this case Brentwood Council would have an obligation to assess whether it could assist Thurrock District in identifying suitable alternative provision for showmen's yards through the Duty to Co-operate (NPPF Paragraphs 178 and 179). Indeed, we have written extensively about this in our original March 2016 Representations, and this does not appear to be reflected in this current draft Local Plan document or in the background GTAA. It also does not reflect the fact that an application for a showmen's yard was submitted in 2016, which although no decision was taken, did provide substantial information regarding the need for plots in Brentwood and the suitability of the site for such purposes. We therefore object to this paragraph as it is unsound based on the evidence we have already put forward.

Paragraphs 73-74
RPS objects to Paragraphs 73 and 74 and its table as it provides no plots for travelling showpeople. The Council should be allocating provision for travelling showpeople in Brentwood to accommodate the need arising in neighbouring Thurrock, which cannot be accommodated within Thurrock, given a suitable site exists (our client's site at Chequers Road). We assessed in detail why it is suitable site for a Showpeople's Yard in our March 2016 Representations, and a current application to confirm the site's existing use as Class B8 (storage) is currently being considered by the Council, which would confirm that site's suitability for one of three key elements of a showpeople's site (these being storage, maintenance and residential).

In conclusion, our objection regarding the draft Local Plan made in March 2016 remains the same, in that we consider that the Local Plan would be 'unsound' without the provision of plots to accommodate need, which relates to a Duty to Co-operate with a neighbouring authority, particularly where a suitable site (at Chequers Road) is available.

We therefore request that the land at Chequers Road is allocated for such purpose to provide plots in accordance with the Government's guidance on the matter.

Please don't hesitate to contact me to discuss any matters raised in this letter.