The Promoters of DHGV fully support the need to provide a variety of house types including those suitable for specialist elderly persons accommodation. The precise nature of elderly persons accommodation requires further assessment before inclusion of references in policy to a prescriptive form of accommodation.
See additional documents and reference under Specialist Accommodation Needs.

Specialist Accommodation Needs and Supply - Registered Care

ECC acknowledges BBC is seeking to meet its identified needs for registered care provision, (424 spaces between 2013 and 2033) as identified in the SHMA. However ECC seeks clarification on the suitability of the proposed sites for the provision of specific registered care accommodation (424 spaces across 4 large preferred housing allocation sites), as well as information on any additional infrastructure requirements such accommodation may require.

ECC seeks careful consideration of locations of developments with specific allocations of homes for older people. Easy access to primary care services including GP, local facilities including pharmacists and shops and also public transport links are vital. This would also be applicable for permission given for conversions of buildings of previous use to residential care homes for older and vulnerable people.

Furthermore ECC seeks clarification on whether the location of such accommodation, on four large housing sites, has implications for the general housing capacity of the preferred housing sites. This should also be considered in combination with the location of the required Gypsy and Traveller pitches, which are proposed on 3 of the 4 same large housing sites (see comments below).

In order to meet its statutory obligations as the provider of adult social care, control the costs of adult social care and improve the lives of residents, ECC is committed to influencing the provision of a range of housing options for the older population. Consequently, ECC is keen to support and enable older people to live independently.

At present a gap exists in the provision of Independent Living housing across Essex. There are not sufficient numbers of Independent Living units to relieve pressure for residential care placements. A target of 2,825 Independent Living units (available as rental or ownership units) has been set by ECC to be delivered by 2020 in the County. Not including units either in development or completed to date, there are 2,178 units remaining to be delivered across Essex. Within Brentwood, by 2020, 153 units are required; 26 units are already provided, which leaves 127 still to be provided by 2020.

A programme has been developed by ECC to increase the supply of Independent Living units across Essex. It is therefore recommended that reference to the ECC Independent Living programme and its role in housing delivery should be made in progressing the Plan.

Specialist Accommodation Needs and Supply - Gypsy & Traveller

ECC notes that BBC has been working in partnership with Essex local authorities, through jointly commissioning the Gypsy and Traveller Accommodation Assessment (GTAA) (2017) to provide a robust assessment of current and future need for Gypsy and Traveller and Travelling Showpeople families and has used this data to inform how it addresses this in its Draft Local Plan.

ECC acknowledges BBC is seeking to meet its identified needs (78 pitches between 2016 and 2033), as identified in the Brentwood GTAA Need Summary Report October 2017, and is seeking to follow a sequential approach to site identification. ECC recommends that reference should be made to the most up to date position which is from the Greater Essex GTAA for 2016-2033 which was endorsed by EPOA on 25th January 2018 and published in February 2018.

ECC also seeks clarification on the suitability of the proposed sites for the provision of specific Gypsy and Traveller accommodation (58 pitches across 4 large preferred housing allocation sites), as well as information on any additional infrastructure requirements such accommodation may require.

Furthermore ECC seeks clarification on whether the location of such accommodation, on four large housing sites, has implications for the general housing capacity of the preferred housing sites. This should also be considered in combination with the location of the required registered care facilities, which are proposed on three of the four same large housing sites (see ECC comments above).

ECC notes and welcomes reference to the GTAA recommendations for BBC to engage with other Essex authorities to establish whether there is a need for investment in more formal transit sites or emergency stopping places.

ECC recommends that BBC should reference the transit recommendations as set out in the published Greater Essex GTAA (2018), which recognises and seeks to address the strategic cross boundary matters at a larger 'Greater Essex' level, incorporating data from local authorities; the Essex Countywide Traveller Unit (ECTU) and other sources. There are a range of site options available to address enforcement and unauthorised encampment issues (ie not just Transit sites), but also emergency stopping places, temporary stop and stopping places and negotiated stopping places. There is a need for further investigation and analysis to provide a more robust appraisal of current and future transit needs, to be undertaken.

ECC recommends that as part of the Plan preparation process any policy provision and supporting text should be flexible enough to allow the outcomes of the further work to be incorporated.

Background
By way of background, RPS submitted representations to the draft Brentwood Local Plan Regulation 18 consultation in March 2016 (referred to 'March 2016 Representations'), which set out the policy context regarding travelling showpeople's plots and sites (also referred to as a showmen's yard). Our representations sought the allocation of land at the former Chequers Public House on Chequers Road for use as a showmen's yard/travelling showpeople's site. Those representations set out a number of objections to the draft Local Plan which then excluded provision for showpeople's provision and explained why the site should be appropriate for designation as a Travelling Showpeople's Site. Those representations remain relevant here (we will explain below) but are not specifically repeated for brevity reasons. It is requested that the Council apply those representations to this consultation, in conjunction with further representations below.

It is noted here that the only relevant change to those representations would relate to a planning permission which was granted for the demolition of the public house and its replacement with a single dwelling (Ref: 16/00344/FUL), which were under consideration at the time when those representations were made. The proposals for a showmen's yard on the property associated with that application were withdrawn before determination.

In more recent developments, our client has recently submitted an application for a Lawful Development Certificate (Section 191 application) for an existing use of the land for storage purposes (Class B8). This application is currently being considered by the Council under reference: 18/00323/S191. It relates to a significant portion of the land towards the rear of the former public house, which was assessed in our March 2016 Representations as being a suitable location for travelling showpeople's plots and yard.


Representations
Paragraphs 46-49
RPS objects to the references in Paragraphs 46-49 on the basis that it makes no reference to a provision of showpeople's plots in accordance with Government guidance (Planning Policy for Travellers), for which RPS considers there is a need. Reference is made to the Brentwood Gypsies and Travellers Accommodation Assessment (GTAA) (October 2017), which identified that there were no travelling showpeople living or located within Brentwood at the present time and so there was no current or future need for additional plots. However, this does not necessarily reflect the situation regarding neighbouring authorities, where a shortfall in provision exists (in this case Thurrock District) and where these authorities may not be able to accommodate this need within their own administrative area due to a variety of factors. In this case Brentwood Council would have an obligation to assess whether it could assist Thurrock District in identifying suitable alternative provision for showmen's yards through the Duty to Co-operate (NPPF Paragraphs 178 and 179). Indeed, we have written extensively about this in our original March 2016 Representations, and this does not appear to be reflected in this current draft Local Plan document or in the background GTAA. It also does not reflect the fact that an application for a showmen's yard was submitted in 2016, which although no decision was taken, did provide substantial information regarding the need for plots in Brentwood and the suitability of the site for such purposes. We therefore object to this paragraph as it is unsound based on the evidence we have already put forward.

Paragraphs 73-74
RPS objects to Paragraphs 73 and 74 and its table as it provides no plots for travelling showpeople. The Council should be allocating provision for travelling showpeople in Brentwood to accommodate the need arising in neighbouring Thurrock, which cannot be accommodated within Thurrock, given a suitable site exists (our client's site at Chequers Road). We assessed in detail why it is suitable site for a Showpeople's Yard in our March 2016 Representations, and a current application to confirm the site's existing use as Class B8 (storage) is currently being considered by the Council, which would confirm that site's suitability for one of three key elements of a showpeople's site (these being storage, maintenance and residential).

In conclusion, our objection regarding the draft Local Plan made in March 2016 remains the same, in that we consider that the Local Plan would be 'unsound' without the provision of plots to accommodate need, which relates to a Duty to Co-operate with a neighbouring authority, particularly where a suitable site (at Chequers Road) is available.

We therefore request that the land at Chequers Road is allocated for such purpose to provide plots in accordance with the Government's guidance on the matter.

Please don't hesitate to contact me to discuss any matters raised in this letter.

Background
By way of background, RPS submitted representations to the draft Brentwood Local Plan Regulation 18 consultation in March 2016 (referred to 'March 2016 Representations'), which set out the policy context regarding travelling showpeople's plots and sites (also referred to as a showmen's yard). Our representations sought the allocation of land at the former Chequers Public House on Chequers Road for use as a showmen's yard/travelling showpeople's site. Those representations set out a number of objections to the draft Local Plan which then excluded provision for showpeople's provision and explained why the site should be appropriate for designation as a Travelling Showpeople's Site. Those representations remain relevant here (we will explain below) but are not specifically repeated for brevity reasons. It is requested that the Council apply those representations to this consultation, in conjunction with further representations below.

It is noted here that the only relevant change to those representations would relate to a planning permission which was granted for the demolition of the public house and its replacement with a single dwelling (Ref: 16/00344/FUL), which were under consideration at the time when those representations were made. The proposals for a showmen's yard on the property associated with that application were withdrawn before determination.

In more recent developments, our client has recently submitted an application for a Lawful Development Certificate (Section 191 application) for an existing use of the land for storage purposes (Class B8). This application is currently being considered by the Council under reference: 18/00323/S191. It relates to a significant portion of the land towards the rear of the former public house, which was assessed in our March 2016 Representations as being a suitable location for travelling showpeople's plots and yard.


Representations
Paragraphs 46-49
RPS objects to the references in Paragraphs 46-49 on the basis that it makes no reference to a provision of showpeople's plots in accordance with Government guidance (Planning Policy for Travellers), for which RPS considers there is a need. Reference is made to the Brentwood Gypsies and Travellers Accommodation Assessment (GTAA) (October 2017), which identified that there were no travelling showpeople living or located within Brentwood at the present time and so there was no current or future need for additional plots. However, this does not necessarily reflect the situation regarding neighbouring authorities, where a shortfall in provision exists (in this case Thurrock District) and where these authorities may not be able to accommodate this need within their own administrative area due to a variety of factors. In this case Brentwood Council would have an obligation to assess whether it could assist Thurrock District in identifying suitable alternative provision for showmen's yards through the Duty to Co-operate (NPPF Paragraphs 178 and 179). Indeed, we have written extensively about this in our original March 2016 Representations, and this does not appear to be reflected in this current draft Local Plan document or in the background GTAA. It also does not reflect the fact that an application for a showmen's yard was submitted in 2016, which although no decision was taken, did provide substantial information regarding the need for plots in Brentwood and the suitability of the site for such purposes. We therefore object to this paragraph as it is unsound based on the evidence we have already put forward.

Paragraphs 73-74
RPS objects to Paragraphs 73 and 74 and its table as it provides no plots for travelling showpeople. The Council should be allocating provision for travelling showpeople in Brentwood to accommodate the need arising in neighbouring Thurrock, which cannot be accommodated within Thurrock, given a suitable site exists (our client's site at Chequers Road). We assessed in detail why it is suitable site for a Showpeople's Yard in our March 2016 Representations, and a current application to confirm the site's existing use as Class B8 (storage) is currently being considered by the Council, which would confirm that site's suitability for one of three key elements of a showpeople's site (these being storage, maintenance and residential).

In conclusion, our objection regarding the draft Local Plan made in March 2016 remains the same, in that we consider that the Local Plan would be 'unsound' without the provision of plots to accommodate need, which relates to a Duty to Co-operate with a neighbouring authority, particularly where a suitable site (at Chequers Road) is available.

We therefore request that the land at Chequers Road is allocated for such purpose to provide plots in accordance with the Government's guidance on the matter.

Please don't hesitate to contact me to discuss any matters raised in this letter.

See attached.

See attached.

See attached.