brentwood.gov.uk

Policy SP06 should be modified by deletion of Point A entirely. Point B should be revised to include flexibility for the provision of supporting documentation on a site by- site basis in accordance with the relevant planning application validation list

Policy SP06: Effective Delivery of Development
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Policy SP06: Effective Delivery of
Development; particularly Point A and Point B.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. Points A and B of Policy SP06: Effective Delivery of Development are concerned
with securing the timely and efficient delivery of strategic sites and areas of
change.
5. The policy indicates a raft of additional tasks and steps for larger sites including
strategic and site-area masterplans, collaborative and partnership working to
derive scheme proposals.
6. While LLLP support the need for collaborative working with stakeholders, it is
concerned that the requirements set out in SP06 are overly onerous and
unjustified. It is not clear why the additional steps and documents are necessary
and how they would lead to more efficient or timely development delivery.
7. The planning application and decision-taking process as laid out in the NPPF
includes opportunities for extensive stakeholder and consultee engagement as
well as pre-application review and evolution of development proposals of all
scales. This allows for a coherent and effective approach to site development to
be undertaken already and therefore already provides the mechanisms to achieve
this in the way that paragraph 4.45 of the Local Plan envisages.
Conclusions
8. LLLP conclude that Point A and Point B of Policy SP06 are not:
* Justified - for the reasons identified in this representation, the approach is
not justified. The planning system already includes adequate opportunities
and mechanisms for early engagement, partnership and stakeholder work
and collaborative planning. There is no need for the additional measures
proposed in Policy SP06 at Points A or B and it is unclear as to which
size/scale of allocated sites the policy may be applied;
* Effective - the measures set out in SP06 will not necessarily lead to more
effective planning or decision-taking. Some of the steps may serve to slow
or restrict the ability to bring development sites forwards in a timely fashion.
There is a need to balance the collaborative and participatory approach
envisaged in SP06 with the timely determination of development proposals
for larger sites.
Modifications Required
9. Policy SP06 should be modified by deletion of Point A entirely. Point B should be
revised to include flexibility for the provision of supporting documentation on a site by- site basis in accordance with the relevant planning application validation list.