brentwood.gov.uk

LLLP consider that policy SP01 requires modification at D(a) and D(d) to ensure that it is positively framed and that the approach to securing sustainable development accords with the NPPF and is more flexible.

Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Section 4, Policy SP01: Sustainable
Development.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. Policy SP01 sets the overall approach and criteria for achieving sustainable
development in the Borough. LLLP supports the overall approach and intention of
the policy but has specific concerns with respect to criterion point D.
Criterion D
5. Point D of Policy SP01 states that development will be supported where it
contributes towards delivering the Strategic Objectives and meets 11 specific
criteria. LLLP have concerns about D(a) and D(d) as follows.
Criterion D(a)
6. Criterion D(a) states that development will be supported where it preserves and
enhances the character and settlement setting of the Borough's villages.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
7. As drafted the criterion appears to be overly prescriptive. "Preservation" of the
character and settlement setting is inflexible and by definition anticipates that there
is no change to the existing situation. The spatial strategy and growth proposals set
out in the Plan will, inevitably, lead to change to the character and setting of
settlements (including towns, villages and the countryside).
8. The NPPF does not require the preservation of character and setting and is couched
in more positive terms, particularly at paragraph 170 which seeks to inter alia: (a)
protect and enhance valued landscapes; and (b) recognise the intrinsic character
and beauty of the countryside.
Criterion D(d)
9. Criterion D(d) seeks to ensure that the transport network can satisfactorily
accommodate the travel demand generated and that traffic generation would not
give rise to adverse highway conditions or highway safety concerns or an
unacceptable loss of amenity.
10. LLLP consider that the phrasing of criterion D(d) is not consistent with the NPPF at
paragraph 102(d). This paragraph of the NPPF confirms that the environmental
impacts of traffic and transport infrastructure should be identified and assessed and
that appropriate opportunities for avoiding or mitigating any adverse effects are
identified.
11. Criterion D(d) of Policy SP01 makes no reference to the ability of development
schemes and proposals to mitigate any adverse effects that may be identified. The
policy wording needs to reflect the potential for adverse highways conditions to be
mitigated through appropriate interventions such as contributions to infrastructure
improvements
Conclusions
12. LLLP object to Policy SP01. The policy is not sound as it is not:
* Consistent with the NPPF - for the reasons identified in this representation,
Policy SP01 is not consistent with the NPPF and is considered to be too
prescriptive with respect to Criterion D(a) and Criterion D(d). The policy is
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
not positively framed for these criteria and would be overly restrictive for the
effective consideration of future development proposals.
Modifications Required
13. LLLP consider that policy SP01 requires modification at D(a) and D(d) to ensure that
it is positively framed and that the approach to securing sustainable development
accords with the NPPF and is more flexible.