Appendix 4: Proposed changes to the Brentwood Policies Map

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Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 23731

Received: 19/03/2019

Respondent: JTS Partnership LLP

Agent: JTS Partnership LLP

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Appendix 4 of the pre-submission, Regulation 19 Document identifies that the production of a new Policies Map will require changes to the 2005 Proposals Map. Maps setting out the changes to the Plan were stated to be published as part of the
Regulation 19 but this has not happened. As such, the plan preparation and consultation process has not adhered to requirements in failing to publish all relevant documents for consultation. The assessment of the site boundaries / inclusion of Protected Urban Open Space, particularly land at Playfield at Brentwood Ursuline is unknown and formal representation is not possible.

Change suggested by respondent:

Publication of the Policies Proposals Map to enable it to be consulted upon and to
provide context to the references to it within the draft Submission Plan.

Full text:

The Plan is not legally compliant as not all submission documents required to form a
Local Plan, namely a Policies Map, have been produced during all the stages of
consultation. The Appendix 4 of the pre-submission, Regulation 19 Document identifies that the production of a new Policies Map will require changes to the 2005 Proposals Map. Maps setting out the changes to the Plan were stated to be published as part of the Regulation 19 but this has not happened. As such, the plan preparation and consultation process has not adhered to requirements in failing to publish all relevant documents for consultation. In particular, the adopted Replacement Local Plan (2005) identifies land within Protected Urban Open Space (PUOS), a matter addressed with Emerging Policy BE23. The policy makes specific reference to the Brentwood Policies Map in identifying such designated areas. "POLICY BE23: Open Space, Sport And Recreational Facilities 1. Within the borough's urban areas, permission will not be granted for development of land allocated on the Brentwood Policies Map as Protected Urban Open Space or Local Green Space unless it can be demonstrated..." However, in assessing open spaces position within the Borough, the Council rely on the Sport Leisure and Open Space Assessment, 2016, which considers the contribution sites with the PUOS designation make, assessed against three criteria: * Public Accessibility; * Recreational Value; and * Amount Value. Sites such as land at Playfield at Brentwood Ursuline (Sport Leisure and Open Space Assessment, 2016, Appendix 12, Site ID:19b) score very low against these criteria and, therefore, the justification for its retention within the PUOS designation does not exist. We have made representations on this land through the Local Plan Review process, including specific reference at the Call for Sites, 2009 and the Issues and Options Consultation 2013. More general comment has been made in respect at the Council's spatial strategy of focusing on the sequential use of land, which prioritises brownfield land first and then considers growth in settlements in terms of their relative sustainability, at the strategic Growth Options consultation 2015 and the Preferred Sites Allocation consultation 2018. These representations have identified the little contribution the site at the Ursuline Playing field (Site ID: 19b) makes to open space and the worthiness of removing it from the designation to allow for its potential development as a parcel in a central urban area and very well located to the town centre, the public transport network, public open space and other services. However, without having had the opportunity to view the new Policies Proposal Map at any stage during the consultation process, the designation of this piece of land is unknown and, thus, the ability to make detailed comments on such matters has been denied. In addition, the soundness of the Plan is brought into question where decisions made on the extent and location of designations, such as Protected Urban Open Space, have not been published. Thus, no judgement can be made as to whether such decisions/designations are justified and supported by the evidence base and whether
the Plan, in this respect, is sound. If it is the case that the PUOS designation remains unchanged from the 2005 Proposals Map, this position is not supported by the evidence base which scores the subject site (Site ID: 19b) very lowly against the assessment criteria. However, without confirmation in the form of a new Policies Map, this position is unclear and the Respondent is prejudiced by it. The Respondent in this case would wish to reserve the right to make representation on
the extent of the Protected Urban Open Space designation, as they see fit, once the
Policies Proposal Map has been made publically available.

Attachments: