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Object

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

Representation ID: 22282

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Narrative requires clearer references to evidence base to justify spatial strategy. Relies on DHGV & BEP along A127.Lack of clarity on transport impacts and infrastructure,particularly sustainable transport.LP needs supporting by transport modelling.BBC and ECC working together to progress work.BEP unclear how access can be achieved directly from J29 M25 due to LTC.BBC need to demonstrate suitable access arrangements for all modes of travel and demonstrate what discussions with HE,ECC and site promoter to ensure access arrangements are deliverable and agreed.DHGV needs to reply upon sustainable transport measures,to mitigate impacts on highway network, to be informed by outputs of transport evidence.

Change suggested by respondent:

BBC need to include within the Plan evidence, particularly in respect of transport, the site specific, local and cumulative impact on the local and strategic transport network, to demonstrate that the spatial strategy is the most appropriate.

Full text:

1. Positively prepared
2. Justified
3. Effective
4. Consistent with National Policy

The Plan's narrative requires clearer references to the evidence base to ensure justification of the spatial strategy.

The spatial strategy places a reliance on the provision of the two largest strategic sites (DHGV and BEP) along the A127, referred to as the 'Southern Brentwood Growth Corridor', for some 2,700 homes (up to 4,000 homes beyond the Plan period), and 25.85ha of employment land. However, there is a lack of clarity at this stage, on the transport impacts of development in such locations and the necessary supporting transport infrastructure requirements, particularly sustainable transport (necessary due to the location on the A127 and capacity constraints).

A Local Plan needs to be supported by transport modelling to demonstrate the site specific, local and cumulative impact on the local and strategic transport network, to demonstrate that the spatial strategy is the most appropriate. Since the 2018 consultation BBC and ECC have worked together to progress the additional work needed to be undertaken to provide the transport and highway modelling work to support the Local Plan. This work is still on-going and has not been completed or signed-off.

Specifically, in respect of the BEP, it is currently unclear how access can be achieved directly from J29 of the M25 as a consequence of the Lower Thames Crossing improvements to this junction, which includes a segregated left turn slip road from the A127 to M25 southbound.

BBC therefore need to demonstrate that suitable access arrangements for all modes of travel can be achieved, including appropriate mitigation/improvements. BBC should also demonstrate what discussions have taken place with Highways England, ECC as Highway Authority, and the site promoter to ensure that access arrangements are deliverable and agreed.

In respect of DHGV, due to its location the site will need to reply upon and embed sustainable transport measures, as required in the DHGV policies, to mitigate impacts on the highway network. Such measures will be informed by the outputs of the transport evidence, which is still to be completed.