Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 22346
Received: 18/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Local Plan needs to be supported by transport modelling(site specific, local and cumulative impacts, infrastructure, and/or mitigation measures, costings and phasing).
ECC as Highway Authority and BBC need confidence, and assurance that identify transport mitigation measures (in site allocation policies and viability and IDP work).
BBC have own highway consultants, ECC to check outputs, confirm satisfaction, and ensure mitigation measures identified and accounted for.
BBC and ECC meetings with BBC's transport consultants (PBA) to progress outstanding work, set out in PBA note - 30-01-2019.
ECC as Highway Authority cannot, at this stage, endorse transport evidence (incomplete and not inform IDP.
BBC need to complete the transport modelling, in order to clearly illustrate the site specific, local and cumulative impacts of the Local Plan growth, and identify any infrastructure and/or mitigation measures which would be required, together with costings and phasing.
BBC (together with ECC) need the confidence, and assurance that it can identify up-front the required developer funded transport mitigation measures, and that such mitigation measures are covered within the Local Plan site allocation policies and accounted for in both viability and IDP work.
1. Positively prepared
2. Justified
3. Effective
4. Consistent with National Policy.
In line with paragraph 31 of the NPPF, a Local Plan needs to be supported by transport modelling that clearly illustrates the site specific, local and cumulative impacts of the Local Plan growth, and identifies any infrastructure and/or mitigation measures which would be required, together with costings and phasing.
ECC as Highway Authority (including BBC as the Local Planning Authority) need the confidence, and assurance that it can identify up-front the required developer funded transport mitigation measures, and that such mitigation measures are covered within the Local Plan site allocation policies and accounted for in both viability and IDP work.
It should be noted that as BBC have their own highway consultants, rather than ECC. This requires ECC as the Highway Authority to check outputs to confirm its satisfaction, and to ensure the mitigation measures are identified and accounted for.
Following the BBC's 2018 consultation, BBC and ECC have held meetings with BBC's transport consultants (PBA) to help progress the additional work needed to be undertaken to address the full range of issues previously raised.
BBC has published a note from PBA (dated 30th January 2019) as part of their evidence base for this consultation, which sets out the transport work that is still outstanding.
ECC confirms that these matters are being discussed and ECC will continue to work with BBC to address these matters. Once this work is completed and verified by ECC, BBC will need to publish a revised and consolidated transport assessment as part of the Plan's evidence base.
ECC as Highway Authority cannot, at this stage, endorse the transport evidence as it is incomplete, and this is required to inform the IDP which shows mitigation, costs and phasing.