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

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Object

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

5.13

Representation ID: 22288

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective

Request clarification footnote to footnote 5 to provide up to date information.

Change suggested by respondent:

Additional footnote should be added to 5 as follows -

United Kingdom Climate Projections 2018 (UKCP18) has started to consider revised risk associated with sea level change

Full text:

3. Effective

Request clarification footnote to footnote 5 to provide up to date information.

Object

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

POLICY BE08: SUSTAINABLE DRAINAGE

Representation ID: 22289

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective
4. Consistent with National Policy

In line with paragraph 156 of the NPPF, request additional wording added to end of A. to ensure requirements of Lead Local Flood Authority (LLFA) are met.

Change suggested by respondent:

Amend Policy BE08 A. as follows -

'... adverse impact on water quality. SuDS must be based on the criteria outlined in the Essex County Council SuDS Guide.

Full text:

3. Effective
4. Consistent with National Policy

In line with paragraph 156 of the NPPF, request additional wording added to end of A. to ensure requirements of Lead Local Flood Authority (LLFA) are met.

Object

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

5.68

Representation ID: 22290

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective

The Water Framework Directive (WFD) is a driver for the need for water quality improvements. However, the inclusion of this paragraph within the section relating to SuDS is confusing because ECC as LLFA do not use the criteria associated with water body status to assess pollution control delivered by SuDS.

Change suggested by respondent:

Delete paragraph 5.68.

Full text:

3. Effective

The Water Framework Directive (WFD) is a driver for the need for water quality improvements. However, the inclusion of this paragraph within the section relating to SuDS is confusing because ECC as LLFA do not use the criteria associated with water body status to assess pollution control delivered by SuDS.

Object

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

Transport and Connectivity

Representation ID: 22346

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Local Plan needs to be supported by transport modelling(site specific, local and cumulative impacts, infrastructure, and/or mitigation measures, costings and phasing).

ECC as Highway Authority and BBC need confidence, and assurance that identify transport mitigation measures (in site allocation policies and viability and IDP work).

BBC have own highway consultants, ECC to check outputs, confirm satisfaction, and ensure mitigation measures identified and accounted for.

BBC and ECC meetings with BBC's transport consultants (PBA) to progress outstanding work, set out in PBA note - 30-01-2019.

ECC as Highway Authority cannot, at this stage, endorse transport evidence (incomplete and not inform IDP.

Change suggested by respondent:

BBC need to complete the transport modelling, in order to clearly illustrate the site specific, local and cumulative impacts of the Local Plan growth, and identify any infrastructure and/or mitigation measures which would be required, together with costings and phasing.

BBC (together with ECC) need the confidence, and assurance that it can identify up-front the required developer funded transport mitigation measures, and that such mitigation measures are covered within the Local Plan site allocation policies and accounted for in both viability and IDP work.

Full text:

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

In line with paragraph 31 of the NPPF, a Local Plan needs to be supported by transport modelling that clearly illustrates the site specific, local and cumulative impacts of the Local Plan growth, and identifies any infrastructure and/or mitigation measures which would be required, together with costings and phasing.

ECC as Highway Authority (including BBC as the Local Planning Authority) need the confidence, and assurance that it can identify up-front the required developer funded transport mitigation measures, and that such mitigation measures are covered within the Local Plan site allocation policies and accounted for in both viability and IDP work.

It should be noted that as BBC have their own highway consultants, rather than ECC. This requires ECC as the Highway Authority to check outputs to confirm its satisfaction, and to ensure the mitigation measures are identified and accounted for.

Following the BBC's 2018 consultation, BBC and ECC have held meetings with BBC's transport consultants (PBA) to help progress the additional work needed to be undertaken to address the full range of issues previously raised.

BBC has published a note from PBA (dated 30th January 2019) as part of their evidence base for this consultation, which sets out the transport work that is still outstanding.

ECC confirms that these matters are being discussed and ECC will continue to work with BBC to address these matters. Once this work is completed and verified by ECC, BBC will need to publish a revised and consolidated transport assessment as part of the Plan's evidence base.

ECC as Highway Authority cannot, at this stage, endorse the transport evidence as it is incomplete, and this is required to inform the IDP which shows mitigation, costs and phasing.

Object

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

POLICY BE11: STRATEGIC TRANSPORT INFRASTRUCTURE

Representation ID: 22347

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

Criteria B. b. needs to make it clear who BBC will work with in relation to the matter. This would be consistent with the wording for criteria B. a.

Change suggested by respondent:

Amend Policy BE11 B. b. as follows -

'The Council will work with all relevant statutory bodies, stakeholders and passenger transport providers to consider .... .'

Full text:

3. Effective.

Criteria B. b. needs to make it clear who BBC will work with in relation to the matter. This would be consistent with the wording for criteria B. a.

Object

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

5.92

Representation ID: 22348

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

Request amendment to paragraph 5.92 to reflect current situation. Both stations have existing forecourts, the policy should be seeking to improve these.

Change suggested by respondent:

Amend last sentence of paragraph 5.92 as follows -

'... with improved forecourt and pedestrian crossing facilities.

Full text:

3. Effective.

Request amendment to paragraph 5.92 to reflect current situation. Both stations have existing forecourts, the policy should be seeking to improve these.

Object

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

5.96

Representation ID: 22349

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

Additional wording requested to the end of paragraph 5.96 b. to ensure the proposed improvements can be appropriately funded.

Change suggested by respondent:

Insert additional sentence at end of paragraph 5.96 b. as follows -

Where appropriate contributions will therefore be sought from nearby developments.

Full text:

3. Effective.

Additional wording requested to the end of paragraph 5.96 b. to ensure the proposed improvements can be appropriately funded.

Object

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

5.102

Representation ID: 22350

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. 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.

Change suggested by respondent:

BBC should seek to clarify the status and progress of the 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.

Full text:

3. 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.

Object

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

5.102

Representation ID: 22351

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Recommended that reference made to A127 Task Force. Has representation from all South Essex authorities including BBC. Task Force will oversee public affairs interaction between Councils and Government to ensure route seen as strategic and potential candidate for re-trunking to bring about long-term improvement required for area of South Essex with over 600,000 residents. Planning and design work for any improvement of this scale require a short-term, medium and long term phasing. Whilst A127 is main focus ECC would be looking to work collaboratively with BBC and other councils in area on impact on A128 and M25 Junction 28 scheme.

Change suggested by respondent:

Insert additional point to paragraph 5.102 as follows -

iv. The A127 Task Force has representation from all South Essex authorities including BBC. This Task Force will oversee much of the public affairs interaction between the Councils and Government to ensure that the route is seen as strategic and as a potential candidate for re-trunking in order to bring about the long-term improvement required for an area of South Essex with over 600,000 residents. The planning and design work for any improvement of this scale will of necessity require a short-term, medium and long term phasing. Whilst the A127 is the main focus ECC would be looking to work collaboratively with BBC and other councils in the area on the impact on the A128 and the M25 Junction 28 scheme.

Full text:

3. Effective.

It is recommended that reference is made to the A127 Task Force. This has representation from all South Essex authorities including BBC. This Task Force will oversee much of the public affairs interaction between the Councils and Government to ensure that the route is seen as strategic and as a potential candidate for re-trunking in order to bring about the long-term improvement required for an area of South Essex with over 600,000 residents. The planning and design work for any improvement of this scale will of necessity require a short-term, medium and long term phasing. Whilst the A127 is the main focus ECC would be looking to work collaboratively with BBC and other councils in the area on the impact on the A128 and the M25 Junction 28 scheme.

Object

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

POLICY BE12: CAR-LIMITED DEVELOPMENT

Representation ID: 22374

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Principle of car limited development (CLD) policy is supported.

Policy references CLD being considered at Brentwood Town Centre,District Shopping Centres,railway stations,strategic employment sites.Unclear why locations separated or is intention to refer to locations individually?

Considered reasonable that CLD considered at 'District Shopping Centres'.

Unclear how CLD considered at Strategic Employment Allocations(inc. Brentwood Enterprise Park).Unclear how employees expected to travel via safe and direct walking and cycling routes given location(M25, J29) without significant improvements to sustainable transport network,including provision of new passenger transport services.

Criteria b and c repeats Policy BE13.

Unclear how methods identified in criteria d. would be implemented.

Change suggested by respondent:

It is recommended that the policy wording is amended to address the points raised in order to remove ambiguity and provide clarity for the decision maker in relevant planning applications.

Full text:

3. Effective
4. Consistent with National Policy

The principle of the policy to consider car limited development in appropriate locations is supported. NPPF, paragraph 102, seeks to promote opportunities for walking, cycling and public transport use, along with ensuring parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.

The policy makes reference to car limited development being considered at Brentwood Town Centre or District Shopping Centres, railway stations or strategic employment sites. As worded it is unclear why locations have been separated into the two alternatives, or in drafting the policy is the intention to refer to all these locations individually when considering car-limited development?

Paragraph 2.34 of the LP defines the 'District Shopping Centres' as being Shenfield Hutton Road, Ingatestone High Street, Warley Hill (Brentwood Station). It is considered reasonable that car limited development could be considered at these locations, as they are in close proximity to walking, cycling and passenger transport modes, including rail stations. However, they would need to consider other policies in the plan.

However, it is unclear how car limited development will be considered at Strategic Employment Allocations, of which only Brentwood Enterprise Park is thus defined. It is unclear how it would be expected that employees will be expected to travel via safe and direct walking and cycling routes given its location at M25, J29, without significant improvements to the sustainable transport network, including the provision of new passenger transport services.

However, criteria b and c, as worded, is repeated through Policy BE13 - Sustainable Means of Travel and Walkable Streets, which prioritises cycle and pedestrian movements and access to public transport.

It is unclear how the methods identified in criteria d. would be implemented.

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