Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 22283
Received: 18/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Attention is drawn to ECC Full Council Motion in October 2014, reaffirmed in July 2017 - Essex County Council will not support Local Plans unless adequate resources are identified from developers, local councils and/or Government grants to ensure sufficient infrastructure is provided in timely manner and in way that balances needs to promote economic growth and provide housing for residents whilst protecting quality of life.
Policy should be amended to clarify and strengthen intent to effectively secure and deliver necessary infrastructure and contributions so ECC's role as infrastructure provider is not jeopardised. In line with NPPF paragraphs 20 & 34.
Amend Policy SP04 B. b. as follows -
b. on-site construction of new provision;
c. off-site capacity improvement works;
Amend Policy SP04 F. as follows -
F. Exceptions to this Policy will only be considered whereby:
a.it is proven that the benefits of the development proceeding without full mitigation outweigh the collective harm;
b. a fully transparent open book Viability Assessment has proven that the full mitigation cannot be afforded, allowing only the minimum level of developer profit and land owner receipt necessary for the development to proceed. The viability assessment may be subject to an independent scrutiny by appointed experts;
c. a full and thorough investigation has been undertaken to find innovative solutions to issues and all possible steps have been taken to minimise the residual level of unmitigated impacts; and ...'
1. Positively prepared
2. Justified
3. Effective
4. Consistent with National Policy
Attention is drawn to the ECC Full Council Motion in October 2014, reaffirmed in July 2017, which states that 'Essex County Council will not support Local (Development) Plans unless adequate resources are identified from developers, local councils and/or Government grants to ensure that sufficient infrastructure, including roads, schools, medical facilities, parking, sewerage and drainage, is provided in a timely manner and in a way that balances the needs to promote economic growth and provide housing for residents whilst protecting their quality of life'.
The Policy should be amended to clarify and strengthen intent in order to effectively secure and deliver the necessary infrastructure and contributions so that ECC's role as an infrastructure provider is not jeopardised. This is in line with paragraphs 20 and 34 of the NPPF.