Policy 10.7: Infrastructure and Community Facilities
Comment
Draft Local Plan
Representation ID: 13214
Received: 03/03/2016
Respondent: Sport England
Concerns are raised however about how the proposed policy will make provision for community sports facility infrastructure to be provided by new development in practice. This is pertinent because for the majority of developments proposed in the plan, it will only be practical and appropriate to make provision for indoor or outdoor sport through developer contributions being secured towards off-site projects rather than direct on-site provision being made. There are concerns because at present no specific priority sports facility projects have been identified and the conventional standards based approach for outdoor sport is no longer considered robust.
The intention to use policy 10.7 to require new developments to meet on and off site infrastructure requirements which would include sports facilities as set out in paragraph 10.40 is welcomed. While no objection is made to the wording of policy 10.7, concerns are raised however about how the proposed policy will make provision for community sports facility infrastructure to be provided by new development in practice. This is pertinent because for the majority of developments proposed in the plan, it will only be practical and appropriate to make provision for indoor or outdoor sport through developer contributions being secured towards off-site projects rather than direct on-site provision being made. In particular, there are the following concerns
* While it is expected that this will be addressed through the Council's emerging evidence base for sport (the Sport and Leisure Study), at present there are no specific sports facility projects identified in the local plan or any published IDP for meeting current or future needs. Unless priority community sports facility infrastructure projects (justified by a robust evidence base) are included in an IDP with appropriate feasibility work undertaken to assess costs and deliverability, it is considered that the scope for using CIL receipts or developer contributions secured through planning obligations towards sports infrastructure will be limited;
* The local plan's current approach (as set out in policy 10.8) to providing for outdoor sports facility needs is focused around meeting conventional quantity standards derived from the current evidence base and it has not been confirmed in the plan how indoor sports facility needs generated by new development will be addressed. In particular, there are no specific priority facility projects identified for meeting current or future needs e.g. new/enhanced leisure centre projects, new playing field/outdoor sports projects etc. This approach would not be consistent with Sport England's current guidance on assessing needs and strategy preparation which is focused around identifying sport specific needs and developing specific proposals to respond to such needs. Our current guidance does not endorse a standards led approach to provision and the NPPF (unlike PPG17 which it replaced) does not specifically advocate the use of standards for providing sports facilities. There are also concerns about the compatibility of the standards approach with the CIL Regulations due to a more forensic approach being taken in practice to the interpretation of Regulation 122 in relation to the tests of the use of planning obligations to secure sports facilities and the pooling limits that are now in place for developer contributions towards sport where planning obligations are still used. Whether sport is secured through CIL (through sports facility projects being identified on the Regulation 123 list) or through developer contributions secured by planning obligations, an up-to-date evidence base with a strategy that includes specific projects is now considered necessary for ensuring that new developments meet the additional needs that they generate for sport. Authorities that continue to rely on standards and securing developer contributions towards generic infrastructure types (such as outdoor sport, indoor sport etc) are now struggling to secure provision in practice due to the constraints imposed by the CIL regulations.
To address the above concerns and to ensure that the approach set out in the policy can deliver with respect to community sports infrastructure, it is requested that the emerging evidence base for sport is used to identify strategic priority projects (in the strategy and action plan documents that evolve from the evidence base) which should then be used for informing what projects will be included in an IDP. Following feasibility work, priority projects included in the IDP should be assessed to determine which will be funded by a future CIL (through inclusion on a CIL Regulation 123 list) and which will be funded by planning obligations (through an approach set out in a complementary Planning Obligations Strategy that is consistent with the CIL regulations and which accounts for the constraints imposed by the pooling restrictions on developer contributions). It should be noted that the inclusion of generic infrastructure types (e.g. sport, leisure, outdoor sport) in CIL Regulation 123 lists or planning obligations strategies is not favoured as this is more likely to preclude developer contributions being secured through planning obligations which is important in the context of the likelihood that CIL will only have a limited ability to fund community sports projects in view of competing infrastructure demands. In practice, it would be preferable for CIL to only include a very small number of identified strategic projects (e.g. one or two new/improved leisure centres) and for planning obligations to be used for securing funding for other identified sports facility projects to maximise the potential for the implementation strategy to provide adequately for sport.
While no changes are sought to the policy itself it is requested that the above advice is considered and followed to ensure that the policy can deliver in practice in relation to community sports infrastructure.
Comment
Draft Local Plan
Representation ID: 13389
Received: 17/03/2016
Respondent: Mr. Michael R. M. Newman
The provision of new GP practises may well be catered for but employing GPs to fill them is another matter entirely, as there is a national shortage of GPs in NHS England.
The provision of of new GP practises may well be catered for but employing GPs to fill them is another matter entirely, as there is a national shortage of GPs in NHS England.
Support
Draft Local Plan
Representation ID: 13526
Received: 14/03/2016
Respondent: Ms Jill Griffiths
Any further development, no matter where, must have the infrastructure to support well this development.
1. Any further development, no matter where, must have the infrastructure to support well this development.
2. Green Belt in and around villages must be protected at all costs. Too many villages have been swallowed up by indiscriminate development.
3. This applied to local development of existing buildings where a change of use is recognised and/or planning permission. This has happened in Blackmore.
4. On top of this, buildings have been bought and been allowed to rot, this has and is happening in Blackmore too.
Comment
Draft Local Plan
Representation ID: 13536
Received: 22/03/2016
Respondent: Essex Bridleways Association
Policy 10.7 - Infrastructure and Community Facilities
We note in paragraph 10.40 that the various types of green infrastructure are specified and the list includes footpaths only; no mention of any other type of right of way is made. We request that this is amended to include all designations of public rights of way. We note that in paragraph 10.43 that 'appropriate access to, and linkages between, these assets need to be maximised'. This we agree with but we would like to see the inclusion of bridleway access made within this Policy.
Policy 10.7 - Infrastructure and Community Facilities
We note in paragraph 10.40 that the various types of green infrastructure are specified and the list includes footpaths only; no mention of any other type of right of way is made. We request that this is amended to include all designations of public rights of way. We note that in paragraph 10.43 that 'appropriate access to, and linkages between, these assets need to be maximised'. This we agree with but we would like to see the inclusion of bridleway access made within this Policy.
Comment
Draft Local Plan
Representation ID: 13815
Received: 04/04/2016
Respondent: B. Impey
It is almost impossible to get a doctors appointment if one is needed quickly so new surgeries will need to be built. Having more doctors at the present surgeries will not solve the problem, it would almost impossible to ring for an appointment on the day. Also surgeries have limited car parking.
Could utility services cope as they do at present if all the proposed houses are built.
Regarding the draft plan for the building of numerous houses in the area I hope the larger picture is looked at before final decisions are made such as schools, doctors, car parking, transport and utility services.
1. The proposed building of 250 houses in Honeypot Lane. A few months ago the govenors of St Peters school in South Weald applied for planning permission to extend the school. Planning permission was refused. This was obviously requested because it was considered to be necessary. Now if 250 houses are planned to be built near the school where will the children attend school. Obviously St.Peters will not be able to take them and other schools will have to accomodate children where more houses are being planned.
2. Doctors. It is almost impossible to get a doctors appointment if one is needed quickly so new surgeries will need to be built. Having more doctors at the present surgeries will not solve the problem, it would almost impossible to ring for an appointment on the day. Also surgeries have limited car parking.
3. More care parks would need to be built. When I shop in Brentwood I usually arrive at the multi storey at about 9.00am and have to park on the 9th or 11th floors. There are not many more floors left for general public parking.
4. More people would presumably need to use buses. Services now seem to be cut rather than the other way round.
5. Could utility services cope as they do at present if all the proposed houses are built.
I am not against new houses being built provided that all the points raised are taken into consideration and any others that I have not mentioned.
Object
Draft Local Plan
Representation ID: 14546
Received: 19/04/2016
Respondent: Amanda Burton
* We do not have schools , doctors, hospital facilities to cope.
* Local hospital is on Black Alert most of the time. With no extra funding to be able to cope with this ludicrous development.
* Our local roads are congested already causing both noise and air pollution.
* Our water drainage goes back to Victorian times therefore as much greenbelt as we can keep is advisable to soak up excess water.
* Road Infrastructure is insufficient, further road building will cause more pollution.
* The A127 is overcrowded and is the only road leading to the east.
* As a public Governor or Basildon hospital I can safely say the hospital is at breaking point and already has major financial problems and over subscription problems.
I OBJECT TO THIS PLAN ON THE FOLLOWING BASIS:-
* The proposed site is greenbelt. We should not build on greenbelt. It is an invaluable asset for our future generation and urban sprawl must not be allowed.
* It is not proven that we need housing for this many people (Local) being operative word/name.
* We do not have schools , doctors, hospital facilities to cope.
* Local hospital is on Black Alert most of the time. With no extra funding to be able to cope with this ludicrous development.
* Our local roads are congested already causing both noise and air pollution.
* Our water drainage goes back to Victorian times therefore as much greenbelt as we can keep is advisable to soak up excess water.
* The greenbelt protects London both from flood and acts as a lung for clean air.
* The proposed site has already got a flood problem.
* The original consultation was shamble so is not fit for purpose, consequent re-arrangements regarding Basildon and Brentwood that have been made with out due notification making the outcomes even more erroneous in law. Changing major decisions half way through already flawed process.
* Greenbelt can only be built on in exceptional circumstances. Circumstances regarding over population from another area are not valid.
* The entire demographic will change if we come out of EU and do not take all and sundry from Europe when free movement may be irradiated.
* Road Infrastructure is insufficient, further road building will cause more pollution.
* The A127 is overcrowded and is the only road leading to the east .
* As a public Governor or Basildon hospital I can safely say the hospital is at breaking point and already has major financial problems and over subscription problems.
Support
Draft Local Plan
Representation ID: 15182
Received: 28/04/2016
Respondent: CEG Land Promotions Limited
Agent: CODE Development Planners Ltd
CEG supports the requirement of policy 10.7 for all new development to meet on and off-site infrastructure requirements necessary to support development proposals and mitigate their impacts.
The substantial advantage of allocating a new self-sustaining village is that by definition the majority of infrastructure and community requirements will be provided and integrated on site.
See attached
Object
Draft Local Plan
Representation ID: 15438
Received: 09/05/2016
Respondent: North East London NHS Foundation Trust
Agent: Ingleton Wood LLP
NELFT provides community health and mental health services in Essex and the north east London Boroughs of Barking and Dagenham, Havering, Redbridge and Waltham Forest. The area within their jurisdiction includes the Borough of Brentwood. However, NELFT object to Section 10 of the draft Local Plan on the basis that it is not 'sound' in accordance with paragraph 182 of the National Planning Policy Framework (NPPF). More specifically, with regard to the provision of healthcare and associated facilities, it is considered that as drafted the plan does not deliver the most appropriate strategy and does not reflect an effective approach to cross boundary working on strategic issues. Although the draft Plan outlines the need to create healthy, inclusive communities and notes specific requirements relating to open space and community facilities, there is no specific strategic policy regarding the provision of healthcare facilities.
See attached.
Object
Draft Local Plan
Representation ID: 15440
Received: 09/05/2016
Respondent: North East London NHS Foundation Trust
Agent: Ingleton Wood LLP
As drafted the Local Plan does not identify an effective strategy to promote / require the delivery of adequate social infrastructure for the forecast growth within the Borough. It is requested that a specific policy seeking to promote and support, in principle, the provision of healthcare facilities is incorporated into the Local Plan. The policy should ensure that new and improved facilities are provided in light of assessment of the need for such facilities in the area and support the co-location of health and social care services where this would bring about improvements in access for the community. In addition, the policy should seek to secure the provision, enhancement and maintenance of health and social care facilities through planning obligations.
See attached.
Object
Draft Local Plan
Representation ID: 15441
Received: 09/05/2016
Respondent: North East London NHS Foundation Trust
Agent: Ingleton Wood LLP
Plan does not adopt a partnership approach to the provision of healthcare. As drafted the document notes that the Clinical Commissioning Group is responsible for planning, designing, buying and the performance management of NHS services. Whilst the Clinical Commissioning Group have a statutory duty to improve the health of the local populations, the approach proposed does not have regard to the role of other health care providers and bodies within the locality and therefore does not consider the local implications of the forecast growth within the plan. In order to ensure the Local Plan is 'sound' a collaborative working arrangement should be established between the Borough Council, Essex County Council, the Clinical Commissioning Group, public health bodies and healthcare organisations to develop a comprehensive plan to the delivery of healthcare to meet local needs across the plan period.
See attached.
Comment
Draft Local Plan
Representation ID: 15446
Received: 09/05/2016
Respondent: Basildon and Brentwood Clinical Commissioning Group (NHS)
We believe that there is a clear alignment between the vision for vibrant and thriving communities outlined in the Local Plan and BB CCG's strategic objectives of commissioning high quality and sustainable healthcare services which will support the local population to optimise and maintain their wellbeing and independence, and to reduce the inequalities in health outcomes evident between populations in different parts of our area. We acknowledge that achieving these objectives is not without its challenges, given the pressures that the local health economy, in common with many other areas nationally, is currently facing. The challenge is essentially increasing demand for services, primarily driven by demographic change (both more people requiring services and increasing complexity of needs), and significant constraints on the resources - financial, workforce and the physical capacity available to meet these demands and needs.
See attached leter.
Comment
Draft Local Plan
Representation ID: 15448
Received: 09/05/2016
Respondent: Basildon and Brentwood Clinical Commissioning Group (NHS)
Developing more effective ways of working: the CCG is acutely aware that simply expanding capacity to accommodate ever increasing demand is neither possible nor desirable. Therefore, the CCG is seeking to support more effective provision of services, by driving greater collaboration and integration between local health and social care providers working across the primary, community and acute hospital sectors. It is recognised that the delivery of more coherent services to our population requires the establishment, or re-establishment, of more effective working relationships between professional teams and organisations. A key element in facilitating this approach will be the direct alignment of community health and care teams with specific GP practices. In this way the practice becomes a hub around which the care provided to the registered population is coordinated.
In addition, as noted in the Local Plan, Brentwood Community Hospital represents a significant resource situated within the Borough, and the CCG is committed to ensuring that it is fully utilised to strengthen the community-based provision of healthcare, including sub-acute inpatient facilities, for our population.
See attached leter.
Comment
Draft Local Plan
Representation ID: 15449
Received: 09/05/2016
Respondent: Basildon and Brentwood Clinical Commissioning Group (NHS)
Developing more effective ways of working: Equally importantly, BB CCG is seeking to support a reduction in need, through the development of services that help our population to take greater control of their own health and also by working with partner organisations that can have a positive impact on health and wellbeing. Therefore, BB CCG recognises that, whilst on one hand the increase in population projected within the Local Plan is likely to increase pressure on services, on the other these pressures could be more than offset by the opportunity, outlined in the Plan, to address some of the wider determinants of health, including employment, education, housing and the local environment. BB CCG will welcome the opportunity to work with Brentwood Council and other local partners to support these developments.
See attached leter.
Object
Draft Local Plan
Representation ID: 15450
Received: 09/05/2016
Respondent: Basildon and Brentwood Clinical Commissioning Group (NHS)
Improved use of technology: BB CCG believes that there is a real prospect of using emerging technologies to provide new and effective ways for the local population to access health care advice and support from the place and at the time that is convenient for them. In this way we are expecting to both improve people's experience of health services, and deliver new approaches to provision that will allow projected increases in demand to be accommodated without placing unsustainable pressure on physical capacity.
See attached leter.
Comment
Draft Local Plan
Representation ID: 15451
Received: 09/05/2016
Respondent: Basildon and Brentwood Clinical Commissioning Group (NHS)
In summary, BB CCG welcomes this opportunity to contribute to the consultation on the Brentwood Borough Local Plan, and will continue to work in partnership with Brentwood Council in order to ensure that our strategic plans are aligned as closely as possible in order to deliver the best possible outcomes for our population.
See attached leter.
Comment
Draft Local Plan
Representation ID: 15454
Received: 09/05/2016
Respondent: Mid and South Essex STP
In reviewing the context, content and recommendations of the LDP Document and its current phase of progression, the following comments are with regard to the Healthcare provision on behalf of NHS England - Midlands & East (NHSE) and NHS Property Services (NHSPS). Within Brnetwood Borough, healthcare provision incorporates a total of 9 GP Practices, 13 pharmacists, 10 dental surgeries, a community clinic and 2 community hospitals. These are the healthcare services available that this Local Development Plan must take into account in formulating future strategies. Growth, in terms of housing and employment, is proposed across a wide area and would likely have an impact on future service provision. Existing GP practices do not have capacity to accommodate significant growth.
See attached.
Comment
Draft Local Plan
Representation ID: 15455
Received: 09/05/2016
Respondent: Mid and South Essex STP
In terms of optimal space requirements to encourage a full range of services to be delivered within the community there is an overall capacity deficit, based on weighted patient list sizes, within the 8 GP Practices providing services in the area. Of the 8 Practices in the area 2 currently have the capacity for growth and development Optimal space standards are set for planning purposes only. This allows us to review the space we have available and identify the impact development growth will have in terms of capacity and service delivery. Space capacity deficit does not prevent a practice from increasing its list size, however it may impact on the level and type of services the practice is able to deliver. The weighted list size of the GP Practice based on the Carr-Hill formula, this figure more accurately reflects the need of a practice in terms of resource and space and may be slightly lower or higher than the actual patient list.
See attached.
Comment
Draft Local Plan
Representation ID: 15456
Received: 09/05/2016
Respondent: Mid and South Essex STP
NHS England and the Basildon & Brentwood CCG (CCG) are currently working together to help plan and develop new ways of working within our primary care facilities, in line with the Five Year Forward View, to increase capacity in ways other than increasing physical space. We also endeavour to develop sustainable solutions through a proactive coordinated care approach, including hubs, not individual replacement of surgeries. With focus on premises for training and increasing capacity through technology. The CCG's emerging Strategic Estates Plan will contain further detail on this and the 3 year Primary Care Transformation Funding programme, due to commence in April 2016, will help to provide funding solutions for existing capacity issues.
See attached.
Comment
Draft Local Plan
Representation ID: 15458
Received: 09/05/2016
Respondent: Mid and South Essex STP
Existing health infrastructure will require further investment and improvement in order to meet the needs of the planned growth shown in this LDP document. The developments contained within would have an impact on healthcare provision in the area and its implications, if unmitigated, would; be unsustainable. It should be noted that the CCG are currently working with stakeholders to assess utilisation at Brentwood Community Hospital in order to establish future plans for the facility to ensure appropriate and effective utilisation.
See attached.
Comment
Draft Local Plan
Representation ID: 15471
Received: 09/05/2016
Respondent: Mid and South Essex STP
Policies should be explicit in that contributions towards healthcare provision will be obtained and the Local Planning Authority will consider a development's sustainability with regard to effective healthcare provision. The exact nature and scale of the contribution and the subsequent expenditure by NHS England will be calculated at an appropriate time as and if schemes come forward over the plan period to realise the objectives of the LDP.
See attached.
Comment
Draft Local Plan
Representation ID: 15477
Received: 09/05/2016
Respondent: Mid and South Essex STP
Plans and policies should be revised to ensure that they are specific enough in their aims, but are not in any way prescriptive or binding on NHS England to carry out certain development within a set timeframe, and do not give undue commitment to projects. Notwithstanding this, there should be a reasonably worded policy with the emerging LDP that indicates a supportive approach from the Local Planning Authority to the improvement, reconfiguration, extension or relocation of existing medical facilities. This positive stance should also be indicated towards assessing those schemes for new bespoke medical facilities where such facilities are agreed to in writing by NHS England. New facilities will only be appropriate where they accord with the latest up-to-date NHS England and CCG strategy documents.
See attached.
Comment
Draft Local Plan
Representation ID: 15478
Received: 09/05/2016
Respondent: Mid and South Essex STP
NHS England note the requirement for Brentwood Borough Council to deliver a plan for increased levels of housing growth for their area, resulting in approximately 7,240 new dwellings during the plan period 2013 - 2033 and have identified the anticipated impact on infrastructure arising from these proposals. The exact nature and scale of mitigation required to meet augmented needs of proposed developments will be calculated at an appropriate time, as and if schemes come forward over the plan period to realise the objectives of the LDP.
See attached.
Comment
Draft Local Plan
Representation ID: 15481
Received: 09/05/2016
Respondent: Mid and South Essex STP
For the smaller proposed housing allocation sites: One or more of the following will be necessary for mitigation: Contribution towards increasing capacity for local Primary care facilities, by means of extension, reconfiguration, refurbishment or possible relocation of an existing practice.
(With the exception of the West Horndon sites).
See attached.
Comment
Draft Local Plan
Representation ID: 15482
Received: 09/05/2016
Respondent: Mid and South Essex STP
Redevelopment of the two West Horndon Industrial sites and the Dunton Hills Village: New primary care facility required with potential to expand to accommodate the second phase of the Dunton development,outside of the plan period, as contained within the Basildon Borough Local Development Plan. Should the option of developing a Garden Suburb at the Dunton site, in conjunction with Basildon Borough
Council, be the option adopted it would be expected that joint mitigation would deliver infrastructure to accommodate the needs of the whole site and that of West Horndon Industrial Estates, Childerditch Lane and Station Road, phase to meet the housing trajectory for the developments.
See attached.
Comment
Draft Local Plan
Representation ID: 15508
Received: 23/03/2016
Respondent: Mountnessing Church of England (Voluntary Controlled) Primary School
Our school is sited on a large plot of land with space to build and expand. We are excited by the prospect of new housing and new families joining the village, but have concerns that our current building and school would not accommodate pupils from new developments.
There is potential to expand and hope that when the planning applications are considered, it is understood that we are eager to expand but would need significant support financially to be able to do this. Consultation with Essex Education department would be vital and developers would need to work closely with all stakeholders.
I write in response to the Local Development Plan and the effect it will have on Mountnessing C of E Primary School.
We currently intake 15 pupils per year group, which means that we have only 4 classes and 105 children in total. We are currently at capacity and turning pupils away daily due to restricted space and places available. The present building will only accommodate this number of pupils. We have 2 buildings in our school that are separated by a long private lane. The lower site is Victorian and only houses 2 classrooms, the school office and the head teachers room. The top site also houses 2 classrooms, the staff room, the kitchen and the school hall. We have one relocatable building that we use as a library and intervention room.
Our school is sited on a large plot of land with space to build and expand. We are excited by the prospect of new housing and new families joining the village, but have concerns that our current building and school would not accommodate pupils who should be able to join their local village school.
There is potential to expand and we would hope that when the planning applications are considered, you will bear in mind that we are eager to expand but would need significant support financially to be able to do this. Consultation with Essex Education department would be vital and developers would need to work closely with all stakeholders.
We would invite you to visit our school and see the potential for yourselves.
Comment
Draft Local Plan
Representation ID: 15724
Received: 11/05/2016
Respondent: British Horse Society
We note in paragraph 10.40 that the various types of green infrastructure are specified and the list includes footpaths only; no mention of any other type of right of way is made. We request that this is amended to include all designations of public rights of way. We note that in paragraph 10.43 that 'appropriate access to, and linkages between, these assets need to be maximised'. This we agree with but we would like to see the inclusion of bridleway access made within this Policy.
See attached
Comment
Draft Local Plan
Representation ID: 15747
Received: 11/05/2016
Respondent: Essex County Council
Reference to site/off-site related infrastructure being secured through planning obligations/section 106 agreements in Policy 10.7 is welcomed. At present the Draft Local Plan does not identify where necessary primary and early years and childcare infrastructure will be located or funded in relation to particular allocations. This will be essential.
Reference should be made, in Policy 10.7, to the adopted ECC Developers Guide to Infrastructure Contributions (2015), in relation to the level of contributions required from new development for the provision of essential infrastructure by ECC.
See attached