Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
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Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Appendix 6: Glossary
Representation ID: 22264
Received: 19/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The text accompanying 'Heritage Asset' relates to infrastructure not a Heritage Asset.
Replace the existing text with the following -
A building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. Heritage assets include designated heritage assets and assets identified by the local planning authority (including local listing).
The text accompanying 'Heritage Asset' relates to infrastructure not a Heritage Asset.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Brentwood Local Plan 2016-2033
Representation ID: 22265
Received: 19/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
ECC supports preparation of BBC Local Plan.
Remain significant gaps in evidence base.
Support for Plan can only be provided following completed to ECC satisfaction:
a. appropriate transport evidence base to illustrate site specific, local and cumulative impact on local and strategic transport network, and to identify any infrastructure and/or mitigation measures required, together with costs and phasing;
b. up to date Infrastructure Delivery Plan (IDP) including infrastructure costs, phasing, delivery and viability (need to be agreed with ECC as primary infrastructure provider); and
c. clear references to evidence base within Plan to support spatial strategy, and Local Plan policies.
BBC need to complete the following:
a. An appropriate transport evidence base, to reflect ECC's role as Highway Authority, that clearly illustrates the site specific, local and cumulative impact on the local and strategic transport network, and to identify any infrastructure and/or mitigation measures which would be required, together with costs and phasing;
b. An up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability; and
c. Clear references to the evidence base within the Plan to support the spatial strategy, and the Local Plan policies.
In summary, while ECC supports the preparation of the BBC Local Plan in accordance with the Duty to Co-operate (DtC); and acknowledges the significant changes made since the Regulation 18 stages, to reflect many of ECC's representations, there remain significant gaps in the evidence base and support for the Plan can only be provided once the following has been completed to the satisfaction of ECC:
a. an appropriate transport evidence base, to reflect ECC's role as Highway Authority, that clearly illustrates the site specific, local and cumulative impact on the local and strategic transport network, and to identify any infrastructure and/or mitigation measures which would be required, together with costs and phasing;
b. an up to date Infrastructure Delivery Plan (IDP) that includes infrastructure costs, phasing, delivery and viability, which will need to be agreed with ECC as a primary infrastructure provider; and
c. clear references to the evidence base within the Plan to support the spatial strategy, and the Local Plan policies.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
1.21
Representation ID: 22266
Received: 19/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
3. Effective
Request amendment to paragraph 1.21 to ensure factual representation of the most up to date Regulations.
Amend paragraph 1.21 as follows -
replace '61' with '63'
replace '2010' with '2017'
3. Effective
Request amendment to paragraph 1.21 to ensure factual representation of the most up to date Regulations.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
1.22
Representation ID: 22267
Received: 18/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
3. Effective
4. Consistent with National Policy
The RAMS is not needed to assess the in-combination impacts - this is the role of HRA prepared by the LPA.
Mitigation is needed because these impacts cannot be ruled out and a strategic approach was advised by Natural England. This has now been produced (Jan 2019) and a SPD is in draft to secure per dwelling developer contributions.
Paragraph 1.22 should be amended to reflect this.
Amend paragraph 1.22 as follows -
'...(RAMS) has been identified for the internationally important designated wildlife sites on the Coast. A RAMS has been prepared (January 2019) to deliver strategic mitigation to avoid impacts on these sites from residential development within the evidenced Zone of Influence, with a view to subsequent adoption of a Supplementary Planning Document (SPD) by the Council to secure per dwelling developer contributions. Residential development that is likely to adversely affect the integrity of Habitats (European) Sites, is required to either contribute towards mitigation measures identified in the RAMS or, in exceptional circumstances, identify and deliver bespoke mitigation measures (in perpetuity) to ensure compliance with the Habitat Regulations. Mitigation is needed because these impacts, in combination with other plans and projects, cannot be ruled out and a strategic approach was advised by Natural England.
3. Effective
4. Consistent with National Policy
The RAMS is not needed to assess the in-combination impacts - this is the role of HRA prepared by the LPA.
Mitigation is needed because these impacts cannot be ruled out and a strategic approach was advised by Natural England. This has now been produced (Jan 2019) and a SPD is in draft to secure per dwelling developer contributions.
Paragraph 1.22 should be amended to reflect this.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
1.27
Representation ID: 22268
Received: 19/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
3. Effective
Request amendments to paragraph 1.27 to ensure factual representation of the adopted Essex Minerals Local Plan 2014.
Add the following wording to the end of paragraph 1.27 -
The aim of minerals safeguarding is to ensure that mineral resources are not needlessly sterilised by non-mineral development by ensuring their prior extraction, where this is viable, before the non-mineral development is implemented.
3. Effective
Request amendments to paragraph 1.27 to ensure factual representation of the adopted Essex Minerals Local Plan 2014.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
1.32
Representation ID: 22269
Received: 19/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
3. Effective
Request amendments to paragraph 1.32 to ensure factual representation of the adopted Essex and Southend-on-Sea Waste Local Plan 2017.
Amend paragraph 1.32 to read:
'... the Waste Local Plan does identify a number of Areas of Search across the county where the Waste Planning Authority may support development outside of allocated waste sites. These Areas of Search are all existing industrial estates, and any waste use proposed on these estates will be required to be in keeping with existing development. The Waste Local Plan seeks to focus any new proposals for waste management facilities, which support local housing and economic growth, within these Areas of Search before other locations are considered. Two such Areas of Search have been designated in Brentwood ...'
3. Effective
Request amendments to paragraph 1.32 to ensure factual representation of the adopted Essex and Southend-on-Sea Waste Local Plan 2017.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
1.34
Representation ID: 22270
Received: 19/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
3. Effective
Request amendments to paragraph 1.34 to ensure factual representation of the adopted Essex and Southend-on-Sea Waste Local Plan 2017.
Add the following wording to the end of first sentence of Paragraph 1.34 -
..., extending to 400m in the case of Water Recycling Centres.
3. Effective
Request amendments to paragraph 1.34 to ensure factual representation of the adopted Essex and Southend-on-Sea Waste Local Plan 2017.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
2.8
Representation ID: 22271
Received: 18/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
2. Justified.
BBC will need to be satisfied that the proposed Settlement Hierarchy is supported by the appropriate evidence base.
BBC should include appropriate reference to the evidence base on this matter in the supporting text.
2. Justified.
BBC will need to be satisfied that the proposed Settlement Hierarchy is supported by the appropriate evidence base.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
2.13
Representation ID: 22272
Received: 18/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
2. Justified
Clarification is sought on the infrastructure constraints of Ingatestone, given this paragraph states that Ingatestone has relatively good accessibility to public transport, has a rail station and a secondary school.
BBC should make the appropriate reference to the evidence base covering this point.
2. Justified
Clarification is sought on the infrastructure constraints of Ingatestone, given this paragraph states that Ingatestone has relatively good accessibility to public transport, has a rail station and a secondary school.
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Education and Schools
Representation ID: 22273
Received: 18/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
2. Justified.
Request additional paragraphs to be inserted at the end of this section to ensure that the full range of education provision is considered.
Insert the following two paragraphs after paragraph 2.51 -
Essex County Council has a statutory duty under the Childcare Act 2006 to ensure there are sufficient and accessible high quality early years and childcare provision. In September 2017, the Government also introduced the Extended Funding Entitlement, providing an additional 15 hours free childcare for 3-4 year olds who meet certain criteria.
In general Brentwood has a diverse range of Early Years and Childcare provision to a high quality, however data suggests a large majority of areas are reaching maximum capacity and with the introduction of the Extended Funding Entitlement, childcare choices are limited and new provision will be needed with the additional developments planned.
2. Justified.
Request additional paragraphs to be inserted at the end of this section to ensure that the full range of education provision is considered.