Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 23866
Received: 19/03/2019
Respondent: Brentwood School
Agent: JTS Partnership LLP
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The Green Belt evidence base has not been finalised with the Green Belt Study, Parts 1 and 2 still working drafts with particular consideration to the Area Appraisal for Site Assessment 55 East of Middleton Hall Lane. The evidence base does not conclude what is practically on the ground and the purposes of Green Belt which are considered to be assessed.
The Local Authority should finalise its Green Belt Evidence Base.
Chapter 7 Community Infrastructure Policy PC15:Education Facilities
It is recommended that there is minor changes to the wording within the Policy. Under Policy B delete the word demonstrable before need. It is also considered unnecessary to have the additional wording that relates to the ECC's Developer's Guide to Infrastructure Contributions. If the proposals are clearly associated with educations requirements which will be a matter of fact and degree then there is no need to turn to other schedules. Furthermore the link to the Essex County Council document does not provide a clear schedule of criteria to which the decision maker or applicant can turn. It is confusing and should be deleted. We would recommend that the policy should now read "Where there is a need for new educational facilities, planning permission will be granted for appropriate and well-designed proposals."
As explanation for such minor change it will generally be the education provider whether independent school, religious order or County Education Authority who will know what is needed to improve their overall education facilities either through direct education floorspace or ancillary or associated floorspace.
Comment is also made on Policy PC16: Buildings for Institution Purposes In Policy A delete demonstrable before need. The Policy now reading "A. Where there is a need for the facilities.........." Comment is also made in relation to the general text of paragraph 7.105. This is an unnecessary inclusion within the Plan. There may from time to time be need for minor loss of existing residential accommodation to facilitate a bigger objective of educational community facilities. An example given is the recent redevelopment of the Brentwood Prep School Site where the demands for new form of entry and enlarged educational facilities necessitated the loss of an existing caretakers house. The Local Plan will not be effective with respect to the policy issue raised as it creates an unnecessary hurdle by reference to using the word demonstrable and is confusing and not necessary to relate to another document such as the Essex County Council Developers Guide to Infrastructure Contributions. I have set out the modification to PC15 Education Facilities above but for ease of reference repeat here:
B. "Where there is a need for new educational facilities, planning permission will be granted for appropriate and well-designed proposals."
The provision of educational facilities is an important part of the Local Plan and subject to any response of the Local Authority the point is best made orally.