Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 22374
Received: 18/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Principle of car limited development (CLD) policy is supported.
Policy references CLD being considered at Brentwood Town Centre,District Shopping Centres,railway stations,strategic employment sites.Unclear why locations separated or is intention to refer to locations individually?
Considered reasonable that CLD considered at 'District Shopping Centres'.
Unclear how CLD considered at Strategic Employment Allocations(inc. Brentwood Enterprise Park).Unclear how employees expected to travel via safe and direct walking and cycling routes given location(M25, J29) without significant improvements to sustainable transport network,including provision of new passenger transport services.
Criteria b and c repeats Policy BE13.
Unclear how methods identified in criteria d. would be implemented.
It is recommended that the policy wording is amended to address the points raised in order to remove ambiguity and provide clarity for the decision maker in relevant planning applications.
3. Effective
4. Consistent with National Policy
The principle of the policy to consider car limited development in appropriate locations is supported. NPPF, paragraph 102, seeks to promote opportunities for walking, cycling and public transport use, along with ensuring parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.
The policy makes reference to car limited development being considered at Brentwood Town Centre or District Shopping Centres, railway stations or strategic employment sites. As worded it is unclear why locations have been separated into the two alternatives, or in drafting the policy is the intention to refer to all these locations individually when considering car-limited development?
Paragraph 2.34 of the LP defines the 'District Shopping Centres' as being Shenfield Hutton Road, Ingatestone High Street, Warley Hill (Brentwood Station). It is considered reasonable that car limited development could be considered at these locations, as they are in close proximity to walking, cycling and passenger transport modes, including rail stations. However, they would need to consider other policies in the plan.
However, it is unclear how car limited development will be considered at Strategic Employment Allocations, of which only Brentwood Enterprise Park is thus defined. It is unclear how it would be expected that employees will be expected to travel via safe and direct walking and cycling routes given its location at M25, J29, without significant improvements to the sustainable transport network, including the provision of new passenger transport services.
However, criteria b and c, as worded, is repeated through Policy BE13 - Sustainable Means of Travel and Walkable Streets, which prioritises cycle and pedestrian movements and access to public transport.
It is unclear how the methods identified in criteria d. would be implemented.