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To ensure more effective collaboration and joint working it is suggested that Brentwood Council should progress key strategic matters through the South Essex Joint Strategic Plan process as well as with individual local authorities on cross-boundary matters.

Brentwood Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. In addition to the preparation of the SGLS study which includes a high level housing land and capacity assessment, the South Essex authorities are in the course of commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a Strategic Green Belt review and further infrastructure studies.

The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Brentwood and the future approach to be taken in the Local Plan.

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

Notwithstanding any additional text to the plan setting out key cross-boundary issues it is considered that the Duty to Cooperate has not been met as Brentwood Council has not undertaken effective and on-going engagement regarding the Dunton hills Garden village.

The Brentwood Pre-Submission Local Plan has also therefore not been prepared with a positive and justified strategy.

Whilst in all other respects the Brentwood Plan appears to meet legal requirements it is considered that the Duty to cooperate requirements have not been fully complied with in particular with regard to development of the evidence base and the lack of proper response and agreed outputs by Brentwood Council for evidence and a response on Dunton Hills Garden Village (DHGV).

The National Planning Policy Framework 2018 (updated 2019) sets out in paragraphs 24 to 27 how local authorities should maintain effective cooperation under the Duty to Cooperate. Paragraph 26 highlights that cooperation needs to be effective and on-going between strategic policy-making authorities and relevant bodies to ensure the production of a positively prepared and justified strategy.

Paragraph 27 of the revised NPPF states that in order to demonstrate effective and on-going joint working, strategic policy-making authorities should prepare and maintain statements of common ground.

The updated Planning Policy Guidance for Plan Making (September 2018) includes a section for maintaining effective cooperation and expands on the detail on and for preparing statements of common ground. It is recognised that the duty to cooperate is not a duty to agree and such statements should include agreements and disagreements between strategic plan-making authorities.

There has been ongoing engagement with Brentwood Council under the Duty to Cooperate since the 2016 draft consultation Local Plan. It is recognised that Brentwood has undertaken consultation and engagement on its various technical studies such as the SHMA, employment study and Green Belt review through workshops, meetings and correspondence. There has been a specific workshop on the A127 and more recently Dunton Hills Garden Village. An officer working group set up to consider strategic transport matters and duty to cooperate has resulted in a Statement of Common Ground signed by South Essex authorities, the LB Havering and Highways England in 2018.

In addition a number of meetings have taken place between officers of Thurrock and Brentwood Council regarding the Brentwood Local Plan. At these DTC meetings Thurrock Officers have reiterated the objection to the Brentwood spatial strategy, Dunton Garden village and suggested that alternative options are investigated including potential development at West Horndon and in the A12 Corridor. More recently Thurrock Council has engaged with Brentwood on the preparation of the new Thurrock Local Plan. The new Thurrock local Plan is at issues and Options stage (regulation 18).

It is recognised that Brentwood Council has engaged more effectively on collaboration and joint working on strategic matters through membership of the Association of South Essex Councils (ASELA) and in the preparation of a South Essex Joint Strategic Plan (JSP).

Since the summer of 2017 the leaders and chief executives of the South Essex Councils with the inclusion of Brentwood Borough Council and Essex County Council have also come together to develop a shared long term place vision for South Essex and develop the scope for greater strategic collaboration. By late 2017 work on the vision has resulted in the South Essex 2050 Ambition which includes agreement on the key policy themes to be supported, identifies six growth areas to be promoted and the establishment of new joint working arrangements including strategic planning.

In early 2018 the leaders and chief executives have committed to continuing with the vision and formalising the collaboration by forming an Association as agreed in a MOU and known as the Association of South Essex Local Authorities (ASELA). The aims of ASELA include providing place leadership, and the opening up of space for housing, business and leisure development by developing a joint spatial strategy.

More recently, as a member of ASELA, Brentwood Council have signed the Statement of Common Ground for the JSP and Planning Memorandum (MOU) in June/July 2018. A key issue for Brentwood is how the preparation of the Brentwood Local plan will align with the preparation of the South Essex Joint Strategic Plan.

It is acknowledged that additional or updated elements of evidence base has been produced by Brentwood Council since the last local plan consultation of 2016 including a strategic Housing Market assessment update 2018, draft Green Belt review and economic assessment. However other elements of the evidence base do not appear to have been produced or published to support the site proposals in the draft plan such as the HELAA, adequate transport assessment and mitigation and other infrastructure assessments.

Thurrock Council considers that there are key strategic issues and cross-boundary matters of importance in relation to the preparation of the Brentwood Local Plan that remain outstanding and should be addressed through further effective engagement and collaboration between Brentwood Council and Thurrock Council and with the other South Essex authorities under the Duty to cooperate. The key matters include:

* Confirmation of the Brentwood Objectively Assessed need and whether the borough can accommodate its need;
* The spatial strategy and alternative options within the A12 and A127 corridors to accommodate the growth;

* The Thurrock Council concerns regarding the justification of Dunton Garden Village and the need to consider alternative options including at West Horndon;
* Transport and other infrastructure Issues;
* Further development of the Brentwood Local Plan evidence base;
* The development of the South Essex Joint Strategic Plan and evidence.

In particular in recognition of the Thurrock concern about Dunton Hills Garden Village and due to its location close to and adjoining the boundaries between the two authorities Thurrock Council requests further engagement on this development and considerations of alternative options along the A127 Corridor and elsewhere.
Following representations on the earlier Preferred Site Allocation consultation 2018, a number of South Essex planning authorities including Basildon, Thurrock and Essex County Council sought further clarification with Brentwood regarding their concerns regarding the Dunton Hills Garden Village proposal including any comments on a draft of a DHGV development framework. Several joint meetings were held with Brentwood Council to identify the key issues and areas of concern.

Thurrock Council along with Basildon Borough Council and Essex County Council had submitted a joint report to Brentwood in September 2018 highlighting concerns to Brentwood Council regarding the Dunton Hills Garden Village proposal. No response on the matters set out in the document has been received from Brentwood Council.

The Pre-submission Brentwood Local Plan was approved by Brentwood Council in November 2018 without outstanding matters with adjoining the issues regarding Dunton Hills Garden Village having been clearly addressed and outcomes identified despite requests from the three other authorities including Thurrock.

A Duty to Cooperate Position Statement published as part of the Pre-submission consultation but does not include sufficient information about the key issues regarding cross-boundary matters between authorities. It is notes that the statement is intended to have Statements of Common Ground appended at a future date.

The South Essex authorities are considering spatial options to assess the capacity of South Essex to deliver its growth ambitions and have commissioned a strategic Growth Locations Study (SGLS) as part of the evidence to inform the Joint Strategic Plan preparation. In consideration of locations and strategic sites for growth a range of options will form part of the options testing as part of this study. Thurrock Council has previously considered it is premature for the Brentwood Plan to progress with the development of a large settlement such as Dunton Hills Garden village until the outcome of this options testing is known and the locations and nature of growth has been advanced with a degree of certainty and agreement with adjoining authorities due to the cross boundary implications.

To ensure more effective collaboration and joint working it is suggested that Brentwood Council should progress key strategic matters through the South Essex Joint Strategic Plan process as well as with individual local authorities on cross-boundary matters.

Brentwood Council will need to consider how much additional evidence base for housing need and capacity can be prepared in partnership with adjoining authorities and the other South Essex authorities. In addition to the preparation of the SGLS study which includes a high level housing land and capacity assessment, the South Essex authorities are in the course of commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a Strategic Green Belt review and further infrastructure studies.

The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Brentwood and the future approach to be taken in the Local Plan.

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

Notwithstanding any additional text to the plan setting out key cross-boundary issues it is considered that the Duty to Cooperate has not been met as Brentwood Council has not undertaken effective and on-going engagement regarding the Dunton Hills Garden village.

The Brentwood Pre-Submission Local Plan has also therefore not been prepared with a positive and justified strategy.