1.19

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Object

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

Representation ID: 22563

Received: 19/03/2019

Respondent: Gerald Downey

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

Summary:
It's stated that the Sustainability Appraisal is a "systematic process". Note that the "Site Options Appraisal Findings Table C" from the original AECOM Interim SA
(Ref: AECOM Interim SA Report, Feb 2016; http://www.brentwood.gov.uk/pdf/12022016101306u.pdf) contained "24 Appraisal Criteria". The updated AECOM Interim SA (January 2018/2019), now contains just "17 appraisal criteria". What has happened to 7 of the criteria in this systematic update; including removal of "Protected Urban Open Space" of which some sites performed poorly. I have concerns about the SA process with the criteria changing at key stages in the plan making process.

Change suggested by respondent:

Review the 7 criteria that were dropped from 2016 to 2018, including Protected Urban Open Space" so that "apples can be compared to apples" over time. Check if including these 7 criteria would have had a significant impact on decisions made during the plan making process.

Full text:

Summary:
It's stated that the Sustainability Appraisal is a "systematic process". Note that the "Site Options Appraisal Findings Table C" from the original AECOM Interim SA
(Ref: AECOM Interim SA Report, Feb 2016; http://www.brentwood.gov.uk/pdf/12022016101306u.pdf) contained "24 Appraisal Criteria". The updated AECOM Interim SA (January 2018/2019), now contains just "17 appraisal criteria". What has happened to 7 of the criteria in this systematic update; including removal of "Protected Urban Open Space" of which some sites performed poorly. I have concerns about the SA process with the criteria changing at key stages in the plan making process.