4.33

Showing comments and forms 1 to 1 of 1

Object

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

Representation ID: 22287

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

ECC position = supporting Local Plans but ensuring do not place unnecessary burden on ECC and public purse.
IDP in current form has significant infrastructure cost implications and unanswered questions for ECC (primary infrastructure provider). Places much greater risk on public purse (mitigation costs, delivery implications, viability unclear). IDP cannot be supported in current form.

Plan must be supported by completed IDP (costs, phasing, delivery and viability), needs to be agreed with ECC.

BBC needs to engage with ECC. Significant work still required. ECC will continue to be engaged to ensure appropriate IDP in place ahead of submission and examination.

Change suggested by respondent:

The Plan must be supported by a completed IDP that reflects the evidence base, discussions with ECC for those areas where we have responsibility, and include infrastructure costs, phasing, delivery and viability.

BBC needs to engage with ECC as a major infrastructure provider to prepare its final IDP to support its Plan. Significant work, particularly in respect of costings, phasing, deliverability and viability is still required. ECC will continue to be engaged in this process with BBC to ensure that an appropriate IDP is in place ahead of submission and examination.

Full text:

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

The NPPF at paragraph 34 requires plans to include levels and types of infrastructure required, and such local plan policies should not undermine the deliverability of the plan.

The ECC position since 2014 (as outlined in a Full Council motion on 14 October 2014 and then reiterated in 2017) is one of supporting borough, city and district Local Plans but ensuring these do not place an unnecessary burden on ECC and the public purse, by ensuring developers meet their infrastructure costs responsibilities. Without a sound evidence base, particularly a complete IDP, the impacts of growth and required works and costs for mitigation cannot be determined.

ECC recognises that the IDP is a 'living document' and note that the currently published version (October 2018) needs to be substantially updated prior to submission to reflect the Plan's final site allocations with refined costings.

In its current form there are significant infrastructure cost implications and unanswered questions for ECC to be comfortable as a primary infrastructure provider. This, places a much greater risk on the public purse, as ECC does not know what is expected or indeed what the mitigation costs will be, and the implications for deliverability and viability are unclear. The IDP cannot be supported in its current form.

The working assumption should be that each new home built contributes £35,000 for necessary infrastructure in addition to the affordable housing requirement, and ECC will be looking very carefully at the level of developer funded infrastructure contributions.

The Plan must be supported by a completed IDP that reflects the evidence base, discussions with ECC, and include infrastructure costs, phasing, delivery and viability.

Therefore BBC needs to engage with ECC to prepare its final IDP to support its Plan. Significant work, particularly in respect of costings, phasing, deliverability and viability is still required. ECC will continue to be engaged in this process with BBC to ensure that an appropriate IDP is in place ahead of submission and examination.