Comment

Representation ID: 19834

Received: 12/03/2018

Respondent: AECOM

The Duty to Cooperate - there is insufficient evidence of meaningful duty to cooperate
discussions and no clear mechanism set out as to how the South Essex authorities
shall consider and apportion the unmet needs of their partners. There are also
unresolved matters related to the location of Dunton Hills Garden Village and its
relationship to the west of Basildon.

Comment

Representation ID: 19836

Received: 12/03/2018

Respondent: AECOM

Green Belt - the removal of Parcel 17 from the Green Belt is supported, however, it is
considered that the assessment of Parcel 17 overstates the lands contribution to a
number of the Green Belt 'purposes'.

Object

Representation ID: 19839

Received: 12/03/2018

Respondent: Clearbrook Group Plc

Agent: Strutt & Parker LLP

Green Belt assessment: Site 146 is within Parcel 19 which was assessed as making a high overall contribution to the Green Belt. However, Parcel 19 is 682.28 ha whilst site 146 is 0.74 ha or 0.1% of the Parcel. Impact of the development of Parcel 14 would have a very different impact on the Green Belt than development of site 146. Impact of development within Parcel 14 would have varying impacts on the Green Belt depending on its location and scale. As such, the Green Belt assessment does not provide robust justification for the rejection of the site.

Comment

Representation ID: 19846

Received: 12/03/2018

Respondent: Iceni Projects Limited

The site assessment methodology does not assess sites on their planning merit, rather exploring whether they fit the Spatial Strategy. Key documents such as the HELAA (Stage 1) has not been published for review as part of this consultation.

Comment

Representation ID: 19847

Received: 12/03/2018

Respondent: Iceni Projects Limited

It is acknowledged that Green Belt is required to be released to meet the housing demand in the Borough. However, to justify any release, a thorough assessment of "exceptional circumstances" is required to clearly and unambiguously identify those sites which are the most sustainable to be released. It is not explicit within either the consultation document or supporting evidence base that this has been undertaken.

Comment

Representation ID: 19856

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

Some evidence base documents remain outstanding. Notably this includes transport studies to consider the higher level of growth proposed and the Housing and Economic Land Availability Assessment (HELAA). The last transport information was published in February 2016, comprising draft highway modelling. The implications of housing and employment growth across the Borough for transport are key considerations that require thorough assessment. This should be undertaken prior to the Reg 19 Local Plan consultation to inform the relevant Policies and ensure a comprehensive planned approach.

Comment

Representation ID: 19857

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

The Site Selection Methodology details a 5 No. stage process for assessing sites, as follows:
1. HELAA
2. Local Plan Spatial Strategy
3. Sustainability Appraisal (SA)
4. Detailed Site Assessment
5. Whole Plan Viability Testing
However, the published Site Selection Methodology only includes a very high-level assessment of sites, which does not follow the detailed 5 No. stage process of assessing sites, being at a very high-level and considering the general location of sites rather than detailed assessments.

Comment

Representation ID: 19859

Received: 12/03/2018

Respondent: Croudace Strategic Ltd

Agent: Strutt & Parker LLP

The Site Selection Methodology refers to the need for more detailed site assessment work, stating at Paragraph 3.23 that this will be 'produced later as emerging evidence is published', with Paragraph 3.40 stating that further work will include 'further updates to the HELAA, detailed site assessments and viability assessment'. The HELAA, detailed site assessment and viability assessment are key aspects of the 5 stage process of assessing sites and the absence of these raises concerns at the assessment that has been undertaken of additional allocated sites.

Object

Representation ID: 19862

Received: 12/03/2018

Respondent: Rapleys LLP

The Brentwood Leisure Park at Warley Gap should have been included in the Plan. In our opinion the Site Selection Methodology is misguided in regards to this site for the following reasons: The site is brownfield land, close to and well connected to the existing urban area; can sustainably accommodate residential development without adversely affecting the openness of the Green Belt; Residential use on the site is in principle supported by Planning Officers in respect of the pending outline application, subject to meeting all relevant requirements of the Development Plan.

Comment

Representation ID: 19901

Received: 26/03/2018

Respondent: Environment Agency

It is encouraging to see the emphasis on protecting green belt land and the promotion of green infrastructure in the Local Plan. We recommend that more detail is included in the Local Plan with regards to the rivers within the borough, their ecological status and potential opportunities for improving these through drivers such as the Water Framework Directive (WFD) and Eel Regulations. Any development proposals need to be compliant with the WFD in ensuring no deterioration and where possible seek enhancements.

Comment

Representation ID: 19903

Received: 26/03/2018

Respondent: Environment Agency

Although we note that flooding has been considered in the SA, there is nothing within
the Preferred Site Allocations draft Local Plan in regards to flood risk. We would
prefer to see an approach included in the Local Plan to manage and communicate
the risks and consequences of flooding arising from all sources of flood risk.

Comment

Representation ID: 19908

Received: 26/03/2018

Respondent: Environment Agency

General flood risk advice: The sequential approach should be applied within specific sites in order to direct development to the areas of lowest flood risk. If the whole site is at high risk, an FRA should assess the flood characteristics across the site and direct development towards those areas where the risk is lowest. We strongly advise that proposals for "more vulnerable" development, as defined in Table 2 of the Flood Risk and Climate Change section of the PPG. We are likely to raise an objection where this is not achieved in line with Paragraph 060 of the NPPF's PPG.

Comment

Representation ID: 19949

Received: 26/03/2018

Respondent: Historic England

GI: Landscape, parks and open space often have heritage interest, and it would be
helpful to highlight this. It is important not to consider 'multi-functional' spaces only in
terms of the natural environment, health and recreation. It may be helpful to make
further reference in the text to the role GI can have to play in enhancing and
conserving the historic environment.

Comment

Representation ID: 19950

Received: 26/03/2018

Respondent: Historic England

Setting: Site allocations which include a heritage asset (for example a site
within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from
a heritage asset may cause harm to its significance, reducing the suitability of the site
allocation in sustainable development terms. We would expect to see this reflected
in the policy wording and supporting text.

Comment

Representation ID: 19957

Received: 14/03/2018

Respondent: Rochford District Council

Rochford District Council raises no objection to Brentwood's fulfilment of the Duty to Co-operate, but would highlight the need to continue to work collaboratively with all other South Essex authorities on cross-boundary strategic planning matters, further to the intentions of the South Essex 2050 Memorandum of Understanding.

Comment

Representation ID: 19959

Received: 12/03/2018

Respondent: Basildon Borough Council

DtC issues surrounding Basildon's unmet housing need: Basildon Borough Council formally requests that Brentwood Borough Council considers whether it can assist in meeting some of Basildon Borough's unmet need in the Brentwood Borough Local Plan.

Comment

Representation ID: 19962

Received: 12/03/2018

Respondent: Basildon Borough Council

It is not clear how any of the proposed housing allocations included in the Draft Local Plan: Preferred Site Allocations 2018 have been put forward, and how the sites are justified as being suitable, without the availability of crucial supporting evidence including land supply, Green Belt, landscape, ecology and infrastructure.

Comment

Representation ID: 19965

Received: 12/03/2018

Respondent: Basildon Borough Council

GTAA and wording within the LDP: There is concern that no acknowledgement has been made of the fact that there may be unmet needs arising from Greater Essex authorities for the provision of accommodation for Gypsies, Travellers & Travelling Showpeople within the Brentwood Preferred Site Allocations Report, which is considered to be a shortcoming that could be rectified with appropriate wording.

Comment

Representation ID: 19969

Received: 12/03/2018

Respondent: Basildon Borough Council

It is noted that some of the evidence base which will inform and support BBC's emerging Local Plan are still underway, including key supporting evidence such as Green Belt, landscape, ecology, transportation and infrastructure evidence. In the absence of this evidence base, it is not possible for Basildon Council to comment on whether the forthcoming evidence will be comprehensive and appropriate for what the Local Plan will cover.

Comment

Representation ID: 19992

Received: 28/03/2018

Respondent: Thurrock Borough Council

Brentwood Draft Local Plan and supporting evidence base will require further revision and consultation with ongoing duty to cooperate with adjoining local authorities. In particular the preparation of the draft Plan should be reviewed to take account of the outcome of testing of other spatial options being considered by the South Essex authorities as part of the preparation of a Joint Strategic Plan.

Comment

Representation ID: 19996

Received: 28/03/2018

Respondent: Thurrock Borough Council

Elements of the evidence base do not appear to have been produced or published to support the site proposals in the draft plan such as the HELAA, transport and other infrastructure assessments.

Comment

Representation ID: 19997

Received: 28/03/2018

Respondent: Thurrock Borough Council

The South Essex Authorities are considering the commissioning of additional elements of evidence base to support the preparation of the joint strategic planning including a review of the South Essex SHMA, a spatial options study including a high level housing land and capacity assessment and further infrastructure studies. The outcome of these studies and the preparation of the joint strategic planning will have implications for the nature and scale of housing provision across South Essex including Brentwood and the approach to be taken in the Local Plan.

Comment

Representation ID: 20048

Received: 05/03/2018

Respondent: National Highways

We understand that modelling is currently being undertaken to determine what the impact of development could be on the highway network and therefore what measures may be required to mitigate these impacts. It is therefore unclear at this stage whether it will be possible to sufficiently mitigate the impact of the allocated development locations or whether the impact will be too great to feasibly ensure that the network operates within capacity at the end of the plan period. Further discussion of this will take place in the Evidence Base section below.

Comment

Representation ID: 20050

Received: 05/03/2018

Respondent: National Highways

We consider that the trip generation and distribution assumed by PBA is broadly reasonable. Some concerns have been raised regarding the assignment of trips across the network, primarily the decision to assign all trips between two zones to the same route, whereas in reality we consider that a number of different routes may be used, particularly if routes become congested and users change to an alternative route to avoid the congestion. We consider that the current methodology could result in a robust impact on the SRN and therefore may be reasonable to take forward

Comment

Representation ID: 20051

Received: 05/03/2018

Respondent: National Highways

Current methodology prepared by PBA is broadly reasonable. If, however, the local highway authority plans to deter drivers from making use of certain routes or congestion hotspots cause a significant change in route choice, the total development trips on the strategic road network could alter from that presented within the Highway Modelling Report. The assessment undertaken to date suggests very high impacts to the SRN.

Comment

Representation ID: 20052

Received: 05/03/2018

Respondent: National Highways

Junction capacity assessments of the SRN have not been presented within the Modelling Report, despite experiencing significant increases in trips at the junction as a result of development. It is recommended these are undertaken to determine the predicted operation of the junctions following LP development and to determine what measures may be required to mitigate the impact. Consideration may also need to be given to undertaking merge/diverge assessments at various locations to determine whether changes are required to support the LP development.

Comment

Representation ID: 20245

Received: 05/02/2018

Respondent: Mrs Wendy Garnett

Please have a viable study done of all roads/crossing light phases in the town to help the traffic flow due to the tremendous increase in dwellings in the town centre which will grind to a halt once all the residents are in place - if not before with the interim contractor's vehicles.