Object

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

Representation ID: 23972

Received: 15/05/2019

Respondent: CEG Land Promotions Limited

Agent: Nathaniel Lichfield & Partners

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Policy is confusing. Need to either designate and propose new centres o designate existing and proposed centres which appears to be the approach the Council is taking. . In the latter scenario it is reasonable to defer the designation of the Primary Shopping Area to a later review once the centres are built. Whatever approach is adopted the way the District Shopping Centre and Local Centres are presented should be consistent with Policy R01.

Change suggested by respondent:

Policy PC08: Retail Hierarchy of Designated Centres

For consistency with Policy R01 the following modification is proposed:

A. The Council will promote the continued roles and functions of the existing and proposed Designated Centres to positively contribute towards their viability, vitality, character and structure....

Figure. 7.7: Brentwood - Designated Centres on the Retail Hierarchy

DHGV should be added to the list of Local Centres.

The centres at DHGV should be denoted as 'proposed' or a footnote added to clarify this.

Footnote no. 10 should be amended to state the Primary Shopping Areas will be designated in a Local Plan review.

Paragraph 7.54 iv. should be redrafted to ensure consistency with Policy R01 and Policy PC08.

Full text:

Policy PC08, Retail Hierarchy of Designated Centres (page 187)

CEG supports the Council in its promotion of the designated centres, although it is suggested that reference is made to existing and proposed designated centres, considering the fact the District Shopping Centre at Dunton Hills Garden Village (DHGV) doesn't yet exist.

CEG notes that Policy R01 which deals with the DHGV Strategic Allocation proposes a District Shopping Centre with additional Local Centres in line with Policy PC08. Policy R01 deals with the specific requirements of DHGV. Policy PC08 refers to the Designated Centres set out in Figure 7.7 but this only refers to the District Shopping Centre at DHGV and not the Local Centres. To ensure consistency and to ensure the Plan is positively prepared the list of Local Centres in Figure 7.7 should include reference to local centres at DHGV.

The explanatory text which follows Figure 7.7 refers to DHGV (paragraph 7.54 iv) and also needs to be brought into line with Policy R01. It should refer to the 'provision of', rather than the 'potential for', a District Shopping Centre; and that the Local Centres are additional to, rather than potentially instead of, the District Shopping Centre.

The last sentence of paragraph 7.54 iv) is also confusing and creates further inconsistency. It indicates that the designation of these centres will be informed further by the South Brentwood Growth Corridor Masterplan and further retail evidence and considered as part of a future Local Plan review.

The Local Plan should either designate existing centres and propose new ones, which when they are built are designated as existing centres as part of a Local Plan review; or designate existing and proposed centres which appears to be the approach the Council is adopting here. In the latter scenario it is reasonable to defer the designation of the Primary Shopping Area to a later review once the centres are built. Whatever approach is adopted the way the District Shopping Centre and Local Centres are presented should be consistent with Policy R01.

CEG supports the recognition of the potential for use of upper floors for residential use in Designated Centres. This encouragement could be extended further to a more general statement of support for such uses in criterion C.

Attachments: