BBC should seek to ensure the Local Plan is supported by the appropriate heritage evidence.

It is recommended that the policies are reworded positively, and that consideration be given to the potential to consolidate the policies.

2. Justified
3. Effective
4. Consistent with National Policy.

BBC should be satisfied that it has the appropriate evidence base, such as a Historic Environment Characterisation, to support its heritage strategies and the Local Plan policies.

Most of the policies are not phrased in a positive manner, contrary to paragraph 185 of the NPPF which requires plans to set out a positive strategy for the conservation and enjoyment of the historic environment.

There should be consideration given to amending the wording of the heritage policies in the Local Plan to be positive and support proposals which protect and enhance heritage assets, both designated or non-designated.

Further consideration should be given to the consolidation of the 5 policies, which currently address all the various heritage assets separately. The NPPF requires consideration of any heritage asset and its contribution made by its setting.

Amend footnote 7 to paragraph 6.120 to provide a link to the Essex Historic Environment Record http://www.heritagegateway.org.uk/gateway/

4. Consistent with National Policy.

The NPPF at paragraph 187 advises that LPA's should maintain or have access to a historic environment record, which should contain up-to-date evidence about the historic environment in their area.

Footnote 7 provides a link to the Historic England website to access the Historic Environment Records for Brentwood.

It is considered that a link to the Essex Historic Environment Record is more appropriate, which provides a list of heritage assets within the area and general character assessments.

Amend first sentence of paragraph 6.125 as follows -

'... local significance, or non-designated archaeological sites and deposits which ...'

4. Consistent with National Policy.

Heritage assets include all non-designated archaeological sites and deposits.

Clarity is sought on the deliverability and phasing of employment land allocations in order to meet requirements outlined in the Local Plan.

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

BBC needs to satisfy itself that the Local Plan has a clear economic strategy, with robust phasing and delivery mechanisms in place to ensure that the full employment requirements can be delivered over the whole Plan period, in line with paragraph 23 of the NPPF. This is important given 55% of BBC's employment land allocation in the Plan is proposed at the BEP. This site still has uncertainty over its access and how and when this will be delivered. Furthermore, BBC's evidence base (Economic Futures 2013-2033 Report 2018 prepared by consultants Litchfields) indicates that there is a need for this site to be delivered early in the Plan period, in order to accommodate local businesses that may be affected by employment land re-allocation proposed in the Plan.

Include the following paragraphs after paragraph 7.16 -

Facilitating the training and education of local people enables them to gain skills required to enter or remain part of the local workforce; and establishing and maintaining relationships between local businesses and local training and education providers ensures local facilities are provided to access professional and vocational training.

Larger scale developments in the Borough can support employment opportunities and increased skills levels by embedding both development and end-use phase obligations in the planning process. This would include requirements for the development of apprenticeship opportunities, educational outreach and social value.

Monetary contributions to support interventions will increase skills levels and/or employability skills supporting those hard to reach and furthest away from the job market.

3. Effective.

The Local Plan can play key role in supporting and facilitating local job creation and increasing local skills levels.ECC is currently working with EPOA on these proposals with the intention to include these in a refreshed Essex County Council Developers' Guide to Infrastructure Contributions. The Local Plan is currently silent on this matter. ECC would welcome the Borough's support to include such provisions in the Local Plan, in order to assist in ensuring that such matters are a consideration within the planning process.

Additional wording should be added to the 'new jobs' supporting text to Policy PC02.

Amend paragraph 7.22 b. to delete the word 'normally'.

4. Consistent with National Policy.

In paragraph 7.22 b. the use of the word 'normally' creates ambiguity as there is no definition of what constitutes 'normal' in this context. This could create opportunities for applicants to justify that their application represents a departure and that a full 24-month active marketing is not required to justify the lack of viability of the site for employment use. The word 'normally' should be deleted in line with paragraph 16 d) of the NPPF.

Clarity is sought on how to resolve any conflict between the policies.

3. Effective.

The wording in paragraph 7.24 somewhat contradicts other sustainable policies in Local Plan, particularly within the transport and connectivity section where the focus is on sustainable transport.

Clarity is sought on the deliverability and phasing of employment land allocations in order to meet requirements outlined in the Local Plan.

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

BBC needs to satisfy itself that the Local Plan has a clear economic strategy, with robust phasing and delivery mechanisms in place to ensure that the full employment requirements can be delivered over the whole Plan period, in line with paragraph 23 of the NPPF. This is important given 55% of BBC's employment land allocation in the Plan is proposed at the BEP. This site still has uncertainty over its access and how and when this will be delivered. Furthermore, BBC's evidence base (Economic Futures 2013-2033 Report 2018 prepared by consultants Litchfields) indicates that there is a need for this site to be delivered early in the Plan period, in order to accommodate local businesses that may be affected by employment land re-allocation proposed in the Plan.

Clarity is sought on the deliverability and phasing of employment land allocations in order to meet requirements outlined in the Local Plan.

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

BBC needs to satisfy itself that the Local Plan has a clear economic strategy, with robust phasing and delivery mechanisms in place to ensure that the full employment requirements can be delivered over the whole Plan period, in line with paragraph 23 of the NPPF. This is important given 55% of BBC's employment land allocation in the Plan is proposed at the BEP. This site still has uncertainty over its access and how and when this will be delivered. Furthermore, BBC's evidence base (Economic Futures 2013-2033 Report 2018 prepared by consultants Litchfields) indicates that there is a need for this site to be delivered early in the Plan period, in order to accommodate local businesses that may be affected by employment land re-allocation proposed in the Plan.

Clarity is sought on the deliverability and phasing of employment land allocations in order to meet requirements outlined in the Local Plan.

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

BBC needs to satisfy itself that the Local Plan has a clear economic strategy, with robust phasing and delivery mechanisms in place to ensure that the full employment requirements can be delivered over the whole Plan period, in line with paragraph 23 of the NPPF. This is important given 55% of BBC's employment land allocation in the Plan is proposed at the BEP. This site still has uncertainty over its access and how and when this will be delivered. Furthermore, BBC's evidence base (Economic Futures 2013-2033 Report 2018 prepared by consultants Litchfields) indicates that there is a need for this site to be delivered early in the Plan period, in order to accommodate local businesses that may be affected by employment land re-allocation proposed in the Plan.