MM22

Showing comments and forms 1 to 15 of 15

Support

Schedule of Potential Main Modifications

Representation ID: 29483

Received: 03/11/2021

Respondent: Essex County Council

Representation Summary:

3. Effective

The inclusion of the additional wording in paragraph 5.92 ensures the current situation is reflected. Both stations have existing forecourts, and the policy should be seeking to improve these.

This modification addresses ECC’s Reg.19 Rep 22348 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Full text:

3. Effective

The inclusion of the additional wording in paragraph 5.92 ensures the current situation is reflected. Both stations have existing forecourts, and the policy should be seeking to improve these.

This modification addresses ECC’s Reg.19 Rep 22348 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Support

Schedule of Potential Main Modifications

Representation ID: 29485

Received: 03/11/2021

Respondent: Essex County Council

Representation Summary:

3. Effective

The inclusion of the additional wording at the end of paragraph 5.96 point b. ensures the proposed improvements can be appropriately funded.

Full text:

3. Effective

The inclusion of the additional wording at the end of paragraph 5.96 point b. ensures the proposed improvements can be appropriately funded.

Object

Schedule of Potential Main Modifications

Representation ID: 29538

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Not Effective

ECC as highway and transportation authority considers that the words ‘(where appropriate)’ in the first paragraph of the Policy are unnecessary. The words ‘reasonable and proportionate’ provide the necessary clarity to applicants and decision makers.

Full text:

3. Not Effective

ECC as highway and transportation authority considers that the words ‘(where appropriate)’ in the first paragraph of the Policy are unnecessary. The words ‘reasonable and proportionate’ provide the necessary clarity to applicants and decision makers.

Object

Schedule of Potential Main Modifications

Representation ID: 29539

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Not Effective

ECC as highway and transportation authority welcomes inclusion of criterion c. it provides clarity on bodies to be engaged with on strategic transport infrastructure matters. However, clarification is sought on the definition of transport evidence. As currently written, it is unclear whether this relates to transport evidence for the Local Plan, that accompanies planning applications, and/or accompanies transport schemes from statutory bodies/stakeholders. Evidence accompanying planning applications and transport schemes provides detail and up-to-date positions which supplement the strategic overview of Local Plan evidence. It is recommended that this is clarified in supporting text to this policy.

Full text:

3. Not Effective

ECC as highway and transportation authority welcomes inclusion of criterion c. it provides clarity on bodies to be engaged with on strategic transport infrastructure matters. However, clarification is sought on the definition of transport evidence. As currently written, it is unclear whether this relates to transport evidence for the Local Plan, that accompanies planning applications, and/or accompanies transport schemes from statutory bodies/stakeholders. Evidence accompanying planning applications and transport schemes provides detail and up-to-date positions which supplement the strategic overview of Local Plan evidence. It is recommended that this is clarified in supporting text to this policy.

Object

Schedule of Potential Main Modifications

Representation ID: 29540

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Not Effective

Clarification is sought with regards to the status and progress with South Brentwood Growth Corridor Masterplan referenced in criterion i in paragraph 5.102. BBC should consider providing further narrative in the paragraph to explain this.

This reflects ECC’s Reg.19 Rep 22350 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Full text:

3. Not Effective

Clarification is sought with regards to the status and progress with South Brentwood Growth Corridor Masterplan referenced in criterion i in paragraph 5.102. BBC should consider providing further narrative in the paragraph to explain this.

This reflects ECC’s Reg.19 Rep 22350 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Object

Schedule of Potential Main Modifications

Representation ID: 29541

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

2. Not Justified
3. Not Effective

The modification does not reflect in the supporting text the most up to date position and reference to the Transport Assessment for the Local Plan. Whilst it is recognised that this is proposed to be addressed in paragraph 5.93, it also needs reflecting in paragraphs 5.96 c., 5.101, and 5.104.

Full text:

2. Not Justified
3. Not Effective

The modification does not reflect in the supporting text the most up to date position and reference to the Transport Assessment for the Local Plan. Whilst it is recognised that this is proposed to be addressed in paragraph 5.93, it also needs reflecting in paragraphs 5.96 c., 5.101, and 5.104.

Object

Schedule of Potential Main Modifications

Representation ID: 29571

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Effective

The inclusion of additional wording to paragraph 5.102 at iv. ensures applicants and decision makers are aware of the A127 Task Force and its work.

This modification in part addresses ECC’s Reg.19 Rep 22351 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

However, to reflect the current position and to avoid repetition with existing text within other parts of paragraph 5.102 the final sentence of iv. should be deleted.

Full text:

3. Effective

The inclusion of additional wording to paragraph 5.102 at iv. ensures applicants and decision makers are aware of the A127 Task Force and its work.

This modification in part addresses ECC’s Reg.19 Rep 22351 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

However, to reflect the current position and to avoid repetition with existing text within other parts of paragraph 5.102 the final sentence of iv. should be deleted.

Object

Schedule of Potential Main Modifications

Representation ID: 29624

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Not Effective

Strategic transport infrastructure is required to be delivered to support the Local Plan growth. It is not considered that the word “critical” is necessary in this context. It is therefore recommended that paragraph 5.90 is modified to reflect this.

Full text:

3. Not Effective

Strategic transport infrastructure is required to be delivered to support the Local Plan growth. It is not considered that the word “critical” is necessary in this context. It is therefore recommended that paragraph 5.90 is modified to reflect this.

Support

Schedule of Potential Main Modifications

Representation ID: 29715

Received: 10/11/2021

Respondent: Gita Mackintosh

Representation Summary:

Please keep some parking. Not everyone wants to use public transport after a long day. Whilst the idea of public transport is great it’s unreliable and with covid people don’t want to mix too much.

Full text:

Please keep some parking. Not everyone wants to use public transport after a long day. Whilst the idea of public transport is great it’s unreliable and with covid people don’t want to mix too much.

Support

Schedule of Potential Main Modifications

Representation ID: 29810

Received: 24/11/2021

Respondent: Transport for London

Agent: Transport for London

Representation Summary:

Support Policy BE08 Strategic Transport Infrastructure, particularly Part A & D.
Part C needs further consideration when finalising the Plan, account needs to be taken of the strategic and cross boundary impacts. TfL manages the A127 and A12 which form part of the Transport for London Road Network (TLRN) within London. Removing existing highway capacity constraints may simply transfer the problem downstream to pinch points within London and so first consideration should be given to non-highway measures and/or improvements to walking and cycling that may help to mitigate traffic impacts.

Full text:

Thank you for consulting Transport for London (TfL). We have the following observation on the potential main modifications:

STRATEGIC POLICY BE08: STRATEGIC TRANSPORT INFRASTRUCTURE

We welcome the modifications to this policy which require reasonable and proportionate contributions to required mitigation measures to strategic transport infrastructure. Given that TfL Rail serves Brentwood and Shenfield stations and we provide cross boundary bus services to Brentwood, we particularly support:

A - circulation arrangements, public realm and multimodal integration around Brentwood, Shenfield and Ingatestone stations
D - additional and/or improved pedestrian, cycling infrastructure and bus services connecting development to key destinations such as railway stations, education facilities, employment, retail and leisure.

When considering C - improvements to the highway, account needs to be taken of the strategic and cross boundary impacts. TfL manages the A127 and A12 which form part of the Transport for London Road Network (TLRN) within London. Removing existing highway capacity constraints may simply transfer the problem downstream to pinch points within London and so first consideration should be given to non-highway measures and/or improvements to walking and cycling that may help to mitigate traffic impacts.

We hope that these points can be taken into account when finalising the Local Plan
Best wishes
Richard Carr

Object

Schedule of Potential Main Modifications

Representation ID: 30064

Received: 29/11/2021

Respondent: CEG Land Promotions Limited

Agent: Lichfields

Legally compliant? Yes

Sound? No

Representation Summary:

Reviewing the wording of the proposed amendments to Policy BE08 (formerly BE11), the policy as
written is not justified. This is because contributions could be sought from developments for specific
infrastructure that do not directly relate to it as required by Paragraph 57 of the NPPF and article 122
of the 2021 Community Infrastructure Levy Regulations (as amended). For example, Dunton Hills
Garden Village on the proposed wording could be required to contribute to circulation arrangements,
public realm and multimodal integration around Brentwood, Shenfield and Ingatestone stations;
which would not be appropriate.

Full text:

See attached.

Attachments:

Object

Schedule of Potential Main Modifications

Representation ID: 30162

Received: 30/11/2021

Respondent: S&J Padfield and Partners (SJP)

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Representation Summary:

The proposed wording references the need for contributions from developments towards transport infrastructure to be reasonable and proportionate, but does not acknowledge the other tests of a legally-compliant contribution.

Full text:

See attached

Attachments:

Object

Schedule of Potential Main Modifications

Representation ID: 30228

Received: 01/12/2021

Respondent: St Modwen Properties PLC and S&J Padfield and Partners

Agent: Strutt & Parker LLP

Legally compliant? Yes

Sound? No

Representation Summary:

MM22 should be subject to further modifications making clear that contributions to transport infrastructure will only be sought where they are directly related to development proposal in question, and necessary to make it acceptable in planning terms.

Full text:

See attached

Attachments:

Object

Schedule of Potential Main Modifications

Representation ID: 30285

Received: 02/12/2021

Respondent: Stonebond Properties Ltd

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Representation Summary:

Current wording could result in the decision maker inferring proportionate contributions towards highway infrastructure should be required of developments, even if such infrastructure was not directly related to the development proposed and/or unnecessary to make the development acceptable in planning terms.

Full text:

See attached

Attachments:

Object

Schedule of Potential Main Modifications

Representation ID: 30841

Received: 06/01/2022

Respondent: National Highways

Legally compliant? Not specified

Sound? No

Representation Summary:

Our requirements moving forward are to assess each planning proposal on an individual basis under a situation of either no adopted Local Plan or an adopted Plan subject to immediate review. Mitigation requirements will be considered on an individual or if possible pooled basis depending upon the timing and location of individual applications. Any subsequent Local Plan (if an adopted Plan does not exist) or Local Plan review will then need to assess the impacts of all non-consented development at the time of submission and examination in public, including any non-consented development as part of an adopted Plan if applicable and suitable mitigation will be required for all non-consented development. We feel it important to make this point to clarify our position and avoid any uncertainty in future on the status of any Local Plan related development and the mitigation requirements of the M25 and A12 in Brentwood.

Full text:

Further to recent correspondences, please find below our comments on the Local Plan Potential Main Modifications.

As mentioned during the Local Plan Examination hearings on 27 and 28 July 2021, we would be content for the Plan to be adopted subject to an immediate review. On 27 July we stated that this would enable Brentwood Borough Council to prepare an up to date transport assessment covering impacts on the strategic road network (M25 and A12 outside London) that had in certain respects been hampered by the way existing evidence had been used guided by examination timescales.

As mentioned during the hearing of 28 July, should the Local Plan be adopted based upon existing incomplete evidence and mitigation for the M25 and A12 in Brentwood, National Highways (then Highways England) would still need to engage in the planning process to assess the impacts of each planning application coming forward and secure mitigation as necessary. This is because ordinarily when a Local Plan is adopted all required mitigation is identified for the Plan as a whole, negating the need for full and detailed assessment of subsequent planning applications covered by the full Plan as stated in DfT Circular 02/2013 Paragraph 21.

Bearing these points in mind and the current position of the proposed Local Plan our requirements moving forward are to assess each planning proposal on an individual basis under a situation of either no adopted Local Plan or an adopted Plan subject to immediate review. Mitigation requirements will be considered on an individual or if possible pooled basis depending upon the timing and location of individual applications. Any subsequent Local Plan (if an adopted Plan does not exist) or Local Plan review will then need to assess the impacts of all non-consented development at the time of submission and examination in public, including any non-consented development as part of an adopted Plan if applicable and suitable mitigation will be required for all non-consented development. We feel it important to make this point to clarify our position and avoid any uncertainty in future on the status of any Local Plan related development and the mitigation requirements of the M25 and A12 in Brentwood.

Therefore, our comments specific to the Schedule of Potential Main Modifications are as follows

Policy MG06: Local Plan Review
Paragraph D should be modified to state “a review of transport and highway issues to cater for all local plan growth including all growth without an existing planning permission up to the end of the review period in consultation with National Highways…”.

MM22 Strategic Policy BE08: Strategic Transport Infrastructure
Paragraph C should be modified to state “ improvements to the highway network as deemed necessary by transport evidence (either existing or through future transport assessments submitted as part of development planning applications) or as agreed by National Highways…”.

We hope you find these comments useful. We would be happy to discuss if you require clarification of further information.