Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 23143

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Thurrock Council has previously made representations on the Brentwood Local Plan at the draft 2016 Local Plan consultation and the 2018 Preferred Site Allocations regarding the lack of sufficient evidence base to support the policies and proposals in the emerging Local Plan.

It is recommended that specific additional evidence base required includes:
* An updated SHMA to take account of the Government policy requirements not to use the 2016-based household projections;
* Further evidence to have assessed the various spatial growth options;
* A more fully developed transport evidence base that includes cumulative and site specific impacts of development on the local and strategic highway network and to identify further infrastructure and /or mitigation measures required together with costing and phasing;
* An up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability.

Change suggested by respondent:

It is considered the Brentwood Draft Local Plan and supporting evidence base will require further revision and consultation with ongoing duty to cooperate with adjoining local authorities. In particular the preparation of the draft Brentwood Local Plan should be reviewed to take account of further technical evidence and potentially the outcome of other evidence including the testing of other spatial options being considered by the South Essex authorities as part of the preparation of a Joint Strategic Plan.

It is recommended that specific additional evidence base required includes:
* An updated SHMA to take account of the Government policy requirements not to use the 2016-based household projections;
* Further evidence to have assessed the various spatial growth options;
* A more fully developed transport evidence base that includes cumulative and site specific impacts of development on the local and strategic highway network and to identify further infrastructure and /or mitigation measures required together with costing and phasing;
* An up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability

Full text:


Evidence: Thurrock Council has previously made representations on the Brentwood Local Plan at the draft 2016 Local Plan consultation and the 2018 Preferred Site Allocations regarding the lack of sufficient evidence base to support the policies and proposals in the emerging Local Plan.

It is acknowledged that with the publication of the Pre-Submission Brentwood Local Plan (Regulation 19) that significant progress has been made with the provision of new and updated evidence across a range of topic areas. Brentwood Council through its collaboration and support of the South Essex Joint Strategic Plan (JSP) has also been involved in the commissioning of technical evidence to support the JSP including the Strategic Growth Locations study (SGLS), Employment Land Review and Infrastructure Framework. The South Essex authorities are also intending to commission further technical evidence including Green and Blue Infrastructure, a Strategic Green Belt Review and viability work to support the JSP.

However Thurrock Council considers that there are still key elements of the current Brentwood Local Plan base evidence that provide insufficient detail, are out of date or are missing and therefore the local plan is not fully justified in its policies and proposals. Detailed comments regarding the lack of need to update evidence are made in other representations by Thurrock Council on the Pre-Submission Brentwood Local Plan (Regulation 19).

Thurrock Council considers the Brentwood Local Plan is currently unsound because of insufficient or lack of up to date evidence regarding:
* The transport modelling and mitigation measures to support the overall spatial strategy, transport policies and key development locations such as Dunton Hills Garden Village (DHGV);
* The Infrastructure Delivery Plan (IDP) has not been sufficiently developed or contain enough detail to support the growth strategy, policies and site allocations in the plan;
* The SHMA needs to be reviewed and updated to reflect the Government approach to assessing housing need;
* There is insufficient evidence across a range of evidence topics to support the Dunton Hill Garden Village (DHGV) proposal.


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