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

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Object

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

POLICY BE13: SUSTAINABLE MEANS OF TRAVEL AND WALKABLE STREETS

Representation ID: 22376

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

Amendment required to seek distinction between new and existing development and terminology to correctly refer to 'passenger transport'.

Change suggested by respondent:

Amend Policy BE13 B. b. as follows -

'... good accessibility for passenger transport within sites and between sites and adjacent areas, and where appropriate improve areas where passenger transport, ...'

Full text:

3. Effective.

Amendment required to seek distinction between new and existing development and terminology to correctly refer to 'passenger transport'.

Object

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

POLICY BE14: SUSTAINABLE PASSENGER TRANSPORT

Representation ID: 22378

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

ECC's Development Management Policies February 2011 provide guidance on the development requirements for the provision of passenger transport. Reference should be made to the requirement to have consideration to these.

Change suggested by respondent:

Insert additional criteria to Policy BE14 after A. as follows -

Sustainable passenger transport provision should have consideration to the Essex County Council Development Management Policies, or successor.

Full text:

3. Effective.

ECC's Development Management Policies February 2011 provide guidance on the development requirements for the provision of passenger transport. Reference should be made to the requirement to have consideration to these.

Object

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

POLICY BE15: ELECTRIC AND LOW EMISSION VEHICLES

Representation ID: 22380

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

4. Consistent with National Policy.

As currently worded the policy only requires consideration of such infrastructure at major new developments. Points may be located at other locations. This is not consistent with the policy's supporting text or paragraph 110 of the NPPF.

Change suggested by respondent:

Replace Criteria A. of Policy BE15 with the following wording -

New dwellings and non-residential buildings shall provide convenient access to Electric Vehicle (EV) charging point infrastructure.

Full text:

4. Consistent with National Policy.

As currently worded the policy only requires consideration of such infrastructure at major new developments. Points may be located at other locations. This is not consistent with the policy's supporting text or paragraph 110 of the NPPF.

Object

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

POLICY BE16: MITIGATING THE TRANSPORT IMPACTS OF DEVELOPMENT

Representation ID: 22386

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

4. Consistent with National Policy.

The wording in Criteria A needs to be amended to ensure that the policy is positively prepared, and is consistent with paragraph 108 of the NPPF, particularly criterion c.

Change suggested by respondent:

Amend Policy BE16 A. as follows -

A. Developments should seek to ensure that any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety can be cost effectively mitigated to an acceptable degree.

Full text:

4. Consistent with National Policy.

The wording in Criteria A needs to be amended to ensure that the policy is positively prepared, and is consistent with paragraph 108 of the NPPF, particularly criterion c.

Object

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

POLICY BE17: PARKING STANDARDS

Representation ID: 22387

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

Amendment is requested to criteria A of the policy in order to reflect the current position in respect of parking policy.

Change suggested by respondent:

Amend Policy BE17 A. as follows -

'... Essex Parking Standards - Design and Good Practice (2009), or as amended....'

Full text:

3. Effective.

Amendment is requested to criteria A of the policy in order to reflect the current position in respect of parking policy.

Object

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

POLICY BE18: GREEN AND BLUE INFRASTRUCTURE

Representation ID: 22389

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

4. Consistent with National Policy.

Additional wording requested to ensure the policy considers connectivity for wildlife and people in line with paragraph 91 of the NPPF.

Change suggested by respondent:

Add the following wording at the end of B. b. -

'....and systems to improve connectivity for wildlife and people;'

Full text:

4. Consistent with National Policy.

Additional wording requested to ensure the policy considers connectivity for wildlife and people in line with paragraph 91 of the NPPF.

Object

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

6.25

Representation ID: 22391

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

ECC currently have 39 individuals in South of Essex who are waiting for Supported Living Scheme placements.In terms of housing,new potential builds for Supported Living could be beneficial to supply demand for this type of accommodation,and any specialist accommodation provision for people with disabilities and/or autism could meet the need of local population or individuals who would move to area.ECC are currently carrying out review of demand for adults with disabilities under Independent Living programme.

Request additional paragraph to be inserted after paragraph 6.25 to ensure that full range of specialist accommodation is considered in line with NPPF paragraph 61.

Change suggested by respondent:

Insert the following paragraph after paragraph 6.25 -

In terms of housing, new potential builds for Supported Living could be beneficial to supply demand for this type of accommodation, and any specialist accommodation provision for people with disabilities and /or autism could meet the need of the local population or individuals who would move to this area. The demand for adults with disabilities is considered under the Independent Living programme.

Full text:

3. Effective
4. Consistent with National Policy
ECC currently have 39 individuals in the South of Essex who are waiting for Supported Living Scheme placements. In terms of housing, new potential builds for Supported Living could be beneficial to supply demand for this type of accommodation, and any specialist accommodation provision for people with disabilities and /or autism could meet the need of the local population or individuals who would move to this area. ECC are currently carrying out a review of the demand for adults with disabilities under the Independent Living programme.

Request additional paragraph to be inserted after paragraph 6.25 to ensure that the full range of specialist accommodation is considered in line with paragraph 61 of the NPPF.

Object

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

6.50

Representation ID: 22393

Received: 19/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

The Essex Design Guide 2018 is an Essex Planning Officers' Association document, it was not prepared by Essex County Council. Paragraph 6.50 needs to be amended to ensure factual representation of the Essex Design Guide.

Change suggested by respondent:

Delete 'prepared by Essex County Council' from first sentence of paragraph 6.50.

Full text:

3. Effective.

The Essex Design Guide 2018 is an Essex Planning Officers' Association document, it was not prepared by Essex County Council. Paragraph 6.50 needs to be amended to ensure factual representation of the Essex Design Guide.

Object

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

POLICY HP10: SUB-DIVISION OF PITCHES OR PLOTS

Representation ID: 22394

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criteria A. c. of Policy HP10 seeks to restrict sub-division of Gypsy & Traveller sites to no more than 10 pitches per site.

Chelmsford City Council's Local Plan EIP Inspector questioned restriction.Post hearing advice-National planning policy for traveller sites requires criteria based policies should be fair and effective.

Inspector advises available evidence does not adequately demonstrate why sites should be restricted, and policy contains other criteria to consider impact and scale. Inspector recommended criterion not justified and should be deleted.

BBC should provide appropriate evidence in respect of this matter. If no supporting evidence, then recommended criterion is deleted.

Change suggested by respondent:

Consideration should be given to the Chelmsford Inspector's letter and if there is no appropriate evidence for BBC then delete criterion A. c. from Policy HP10.

Full text:

2. Justified.

Criteria A. c. of Policy HP10 seeks to restrict the sub-division of Gypsy & Traveller sites to no more than 10 pitches per site.

During the EIP of Chelmsford City Council's Local Plan the Inspector questioned this restriction.

The post hearing advice from the Inspector (8th February 2019) advises that National planning policy for traveller sites requires that criteria based policies should be fair and effective in facilitating the traditional and nomadic life of travellers while respecting the interests of the settled community.

The Inspector advises that the available evidence does not adequately demonstrate why sites should be restricted to 10 pitches or plots, and that furthermore, the policy contains other criteria against which impact and scale of any proposals could be considered. The Inspector is therefore recommended that this criterion is not justified and should be deleted.

In line with the Inspectors comments BBC should provide the appropriate evidence with the Local Plan in respect of this matter. If there is no supporting evidence, then it recommended that this criterion is deleted.

Object

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

POLICY HP11: PROPOSALS FOR GYPSIES, TRAVELLERS AND TRAVELLING SHOWPEOPLE ON WINDFALL SITES

Representation ID: 22395

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Criteria A. i. of Policy HP11 seeks to restrict the capacity of Gypsy & Traveller sites to no more than 10 pitches per site.

Chelmsford City Council's Local Plan EIP Inspector questioned restriction.Post hearing advice-National planning policy for traveller sites requires criteria based policies should be fair and effective.

Inspector advises available evidence does not adequately demonstrate why sites should be restricted, and policy contains other criteria to consider impact and scale. Inspector recommended criterion not justified and should be deleted.

BBC should provide appropriate evidence in respect of this matter. If no supporting evidence, then recommended criterion is deleted.

Change suggested by respondent:

Consideration should be given to the Chelmsford Inspector's letter and if there is no appropriate evidence for BBC then delete criterion A. i. from Policy HP11.

Full text:

2. Justified.

Criteria A. i. of Policy HP11 seeks to restrict the capacity of Gypsy & Traveller sites to no more than 10 pitches per site.

During the EIP of Chelmsford City Council's Local Plan the Inspector questioned this restriction.

The post hearing advice from the Inspector (8th February 2019) advises that National planning policy for traveller sites requires that criteria based policies should be fair and effective in facilitating the traditional and nomadic life of travellers while respecting the interests of the settled community.

The Inspector advises that the available evidence does not adequately demonstrate why sites should be restricted to 10 pitches or plots, and that furthermore, the policy contains other criteria against which impact and scale of any proposals could be considered. The Inspector is therefore recommended that this criterion is not justified and should be deleted.

In line with the Inspectors comments BBC should provide the appropriate evidence with the Local Plan in respect of this matter. If there is no supporting evidence, then it recommended that this criterion is deleted.

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