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

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Object

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

Duty to Cooperate

Representation ID: 23124

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Whilst in all other respects the Brentwood Plan appears to meet legal requirements it is considered that the Duty to cooperate requirements have not been fully complied with in particular with regard to development of the evidence base and the lack of proper response and agreed outputs by Brentwood Council for evidence and a response on Dunton Hills Garden Village (DHGV).
Thurrock Council considers that there are key strategic issues and cross-boundary matters of importance in relation to the preparation of the Brentwood Local Plan that remain outstanding and should be addressed through further effective engagement and collaboration between Brentwood Council and Thurrock Council and with the other South Essex authorities under the Duty to cooperate. The key matters include:

* Confirmation of the Brentwood Objectively Assessed need and whether the borough can accommodate its need;
* The spatial strategy and alternative options within the A12 and A127 corridors to accommodate the growth;
* The Thurrock Council concerns regarding the justification of Dunton Garden Village and the need to consider alternative options including at West Horndon;
* Transport and other infrastructure Issues;
* Further development of the Brentwood Local Plan evidence base;
* The development of the South Essex Joint Strategic Plan and evidence.

In particular in recognition of the Thurrock concern about Dunton Hills Garden Village and due to its location close to and adjoining the boundaries between the two authorities Thurrock Council requests further engagement on this development and considerations of alternative options along the A127 Corridor and elsewhere.

Attachments:

Object

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

Dunton Hills Garden Village Strategic Allocation

Representation ID: 23125

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Thurrock Council considers that there are key strategic issues and cross-boundary matters of importance in relation to the preparation of the Brentwood Local Plan that remain outstanding and should be addressed through further effective engagement and collaboration between Brentwood Council and Thurrock Council and with the other South Essex authorities under the Duty to cooperate. The key matters include:

* Confirmation of the Brentwood Objectively Assessed need and whether the borough can accommodate its need;
* The spatial strategy and alternative options within the A12 and A127 corridors to accommodate the growth;
* The Thurrock Council concerns regarding the justification of Dunton Garden Village and the need to consider alternative options including at West Horndon;
* Transport and other infrastructure Issues;
* Further development of the Brentwood Local Plan evidence base;
* The development of the South Essex Joint Strategic Plan and evidence.
In particular in recognition of the Thurrock concern about Dunton Hills Garden Village and due to its location close to and adjoining the boundaries between the two authorities Thurrock Council requests further engagement on this development and considerations of alternative options along the A127 Corridor and elsewhere.

Attachments:

Object

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

Evidence Base

Representation ID: 23143

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Thurrock Council has previously made representations on the Brentwood Local Plan at the draft 2016 Local Plan consultation and the 2018 Preferred Site Allocations regarding the lack of sufficient evidence base to support the policies and proposals in the emerging Local Plan.

It is recommended that specific additional evidence base required includes:
* An updated SHMA to take account of the Government policy requirements not to use the 2016-based household projections;
* Further evidence to have assessed the various spatial growth options;
* A more fully developed transport evidence base that includes cumulative and site specific impacts of development on the local and strategic highway network and to identify further infrastructure and /or mitigation measures required together with costing and phasing;
* An up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability.

Attachments:

Object

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

South Essex Joint Strategic Plan

Representation ID: 23144

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? Yes

Duty to co-operate? Yes

Representation Summary:

Thurrock supports: commitment to ASELA, Brnetwoods commitment to review the plan to ensure any opportunities for additional growth and infrastructure identified in the JSP can be realised; that the review would be an effective mechanism to align the plans in the future.
However, it is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

Attachments:

Object

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

Settlement Hierarchy

Representation ID: 23146

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is requested that Brentwood borough council clarify how the proposed settlement hierarchy is supported by the appropriate evidence base. Brentwood borough council should include appropriate reference to the evidence base on this matter in the supporting text

Attachments:

Object

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

3.6

Representation ID: 23148

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Section 3.6 of the Brentwood Local Plan should identify the key cross-boundary issues and challenges between Brentwood and adjoining authorities including Thurrock. It should set out how the plan seeks to address these including any future reviews of the plan and through joint working on the South Essex JSP.

Brentwood Council should prepare Statements of Common Ground on strategic cross- boundary matters in accordance with the requirements of the National Planning Policy Framework and Planning Policy Guidance.

Attachments:

Object

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

Spatial Strategy Driving Factors

Representation ID: 23150

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Thurrock Council has previously objected to the spatial strategy through its various iterations in previous stages of Brentwood Local Plan consultation and those objections remain. It is unclear why the spatial strategy should advocate a free-standing greenfield settlement in the Green Belt and why this should be the preferred location for development compared to existing settlement expansion or green field urban extensions which are likely to be more sustainable, less constrained and are closer to existing transport and other existing infrastructure and services.

The development of the Brentwood Local Plan spatial strategy appears to have:
* not considered a suitable range of reasonable alternative options that are easier to deliver and/or less constrained;
* put forward a large free standing settlement at Dunton Hills at an early stage which has pre-determined the spatial approach without being supported by the evidence;
* not assessed reasonable options for a free standing settlement or large scale settlement expansion elsewhere in the borough that should have been tested through local plan development evidence and SA process;
* developed a spatial strategy without key elements of the evidence base including land availability transport assessment;
* not taken account of the emerging spatial options being pursued by the adjoining authorities such as Thurrock and through the joint work of the South Essex authorities.

Attachments:

Object

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

Local Housing Need

Representation ID: 23157

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The Pre-Submission Brentwood Local Plan (Regulation 19) fails to take into account the latest Government approach (as published in February 2019) to housing need assessment and use of the appropriate household and demographic data and is therefore considered unsound. The baseline housing target in the pre-submission plan of 350 dwellings per annum is now considered inappropriate and out of date. The upper end flexible target of 456 dwellings per annum is now just above the baseline requirement of 452pa as set out in the standard methodology approach.

Attachments:

Object

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

POLICY SP02: MANAGING GROWTH

Representation ID: 23159

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Thurrock Council seeks further clarification as to whether level of growth proposed for Brentwood could be accommodated in the plan in light of the concerns with regard to the assessment of housing need being required to be altered to meet Government policy at 452 dpa and due to the current concerns regarding the proposed strategic location at Dunton Hills Garden Village to accommodate this growth. Thurrock Council would wish to further engage with Brentwood Council to discuss other alternative options in the borough including at West Horndon.
It is considered that a number of the policies including SP02 should be amended to make reference to the circumstances and triggers in which the Brentwood Local Plan would need to be reviewed including failure to deliver the housing within the plan and /or a different spatial strategy or growth levels as a result of the policy approach following adoption of a South Essex Joint Strategic Plan.

Attachments:

Object

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

Transport and Connectivity

Representation ID: 23160

Received: 10/04/2019

Respondent: Thurrock Borough Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Whilst Thurrock Council supports in principle the overall aims of the sustainable transport Policies in the Brentwood Pre-Submission Local Plan (Regulation 19) it is concerned about the realism and practical deliverability of this approach. Generally, there seems to be insufficient information to support the change in travel behaviour that is needed to support the ambition and policies of the local plan. More information is needed in relation to sustainable travel initiatives, cost of implementation/operation (where relevant) and, importantly, how residents and commuters will be encouraged and empowered to use and embrace the suggested sustainable travel initiatives. It is unlikely that simply delivering more cycle routes, cycle parking provision, EV charging etc will result in the required increase in sustainable modes of travel, without some form of behavioural change provision. It is unclear how the suggested improvements to walking, cycling, public transport and EVs will deliver meaningful benefit if they are not supported by a package of behaviour change components which set out and support the need to use sustainable travel options.Despite the need for further clarification on the transport network impacts, there is an opportunity to work collaboratively on the plan to deliver sustainable transport measures that will benefit Thurrock. The Southern Growth Corridor includes measures as the West Horndon New Transport Interchange, a new multi-modal interchange at West Horndon Station that could also serve Northern Thurrock developments. Cycle routes on this part of the plan can also be connected with Thurrock's network.

Attachments:

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