Insert the following paragraph at the end of the Education and Schools section (paras 2.49-2.51) -

All of the secondary schools within Brentwood have 6th form provision, learner's wishing to study vocational subjects either travel to South Essex College (Thurrock/Basildon), Chelmsford College, with a further cohort travelling into Havering.

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 paragraph at the end of the Education and Schools section (paras 2.49-2.51), and before paragraph 7.103 -

In respect of Special Education Needs (SEN) children present with many different types of need and it is not possible to provide for every need within each District. Each special school is regarded as a regional centre of excellence for their type of need i.e. autism, severe learning difficulties etc and children attend from a wider geographical area. Some children in Brentwood with special needs travel to special schools in other areas of the County.

Endeavour School is a special school for children aged 5 years to 16 years with moderate learning difficulties and complex needs and is the only special school in Brentwood. ECC commissions places for local children with an Education Health and Care Plan at this school.

ECC has developed specially resourced provision for children with speech and language difficulties within West Horndon Primary School in Brentwood to meet the needs of a small number of children with specific speech and language difficulties who are able to access the national curriculum with specialist support.

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 paragraph at the end of the Education and Schools section (paras 2.49-2.51), and before paragraph 7.103 -

In respect of Special Education Needs (SEN) children present with many different types of need and it is not possible to provide for every need within each District. Each special school is regarded as a regional centre of excellence for their type of need i.e. autism, severe learning difficulties etc and children attend from a wider geographical area. Some children in Brentwood with special needs travel to special schools in other areas of the County.

Endeavour School is a special school for children aged 5 years to 16 years with moderate learning difficulties and complex needs and is the only special school in Brentwood. ECC commissions places for local children with an Education Health and Care Plan at this school.

ECC has developed specially resourced provision for children with speech and language difficulties within West Horndon Primary School in Brentwood to meet the needs of a small number of children with specific speech and language difficulties who are able to access the national curriculum with specialist support.

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.

BBC should include within paragraph 3.6 information from its evidence base that identifies the cross-boundary issues, where they are located, and how the Plan seeks to address these.

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

In accordance with paragraphs 21 and 27 of the NPPF, the plan should include information from its evidence base that identifies the cross-boundary issues, where they are located, and how the Plan seeks to address these. ECC would expect to see this in the section covering spatial challenges and opportunities in the Spatial Strategy chapter of the Local Plan.

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.

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.

Amend S04 as follows:

SO4: Deliver Beautiful, Biodiverse, Clean and a Functional Natural Environment,
Where resources are carefully managed to avoid adverse impact and provide net gains for biodiversity; and where our natural heritage is protected, and ecosystem services are restored, enhanced and integrated back into the built environment through multi-functional green and blue infrastructure and opportunities are pursued for securing measurable net gains for biodiversity.

4. Consistent with National Policy

To ensure that the Objective is in line with Paragraph 174 b) of the NPPF.

Delete reference to Green Wedge on the diagram and in its key.

2. Justified

Reference to Green Wedges on the Key Diagram is confusing in this context. There is no policy within the Local Plan providing such a designation, and it is unclear what their role and/or function are.

There does not appear to be any evidence to demonstrate that these areas require a separate designation, or why they have been specifically identified. Furthermore, these areas are within the open countryside and are covered by Green Belt.

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.

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.

Amend Policy SP04 B. b. as follows -

b. on-site construction of new provision;
c. off-site capacity improvement works;

Amend Policy SP04 F. as follows -

F. Exceptions to this Policy will only be considered whereby:
a.it is proven that the benefits of the development proceeding without full mitigation outweigh the collective harm;
b. a fully transparent open book Viability Assessment has proven that the full mitigation cannot be afforded, allowing only the minimum level of developer profit and land owner receipt necessary for the development to proceed. The viability assessment may be subject to an independent scrutiny by appointed experts;
c. a full and thorough investigation has been undertaken to find innovative solutions to issues and all possible steps have been taken to minimise the residual level of unmitigated impacts; and ...'

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

Attention is drawn to the ECC Full Council Motion in October 2014, reaffirmed in July 2017, which states that 'Essex County Council will not support Local (Development) Plans unless adequate resources are identified from developers, local councils and/or Government grants to ensure that sufficient infrastructure, including roads, schools, medical facilities, parking, sewerage and drainage, is provided in a timely manner and in a way that balances the needs to promote economic growth and provide housing for residents whilst protecting their quality of life'.

The Policy should be amended to clarify and strengthen intent in order to effectively secure and deliver the necessary infrastructure and contributions so that ECC's role as an infrastructure provider is not jeopardised. This is in line with paragraphs 20 and 34 of the NPPF.

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.

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.