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

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Object

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

7.30

Representation ID: 22409

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is acknowledged that paragraph 7.30 recognises the need to manage transition of current employment sites,which are to be redeveloped for residential purposes,through early delivery of strategic sites within A127 corridor.

BBC needs to be satisfied that their approach to dealing with proposals for employment land loss will not undermine supply of employment land(and sites) for the borough.Employment land loss to higher value land uses,particularly residential (or retail) use,might be anticipated if effective measures are not in place to manage this process.

Considered that without such measures,strategy may not support existing businesses or deliver the jobs required within Brentwood borough.

Change suggested by respondent:

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

Full text:

3. Effective.

It is acknowledged that paragraph 7.30 recognises the need to manage the transition of current employment sites, which are to be redeveloped for residential purposes, through the early delivery of strategic sites within the A127 corridor.

BBC needs to be satisfied that their approach to dealing with proposals for employment land loss will not undermine the supply of employment land (and sites) for the borough. Employment land loss to higher value land uses, particularly residential (or retail) use, might be anticipated if effective measures are not in place to manage this process.

It is considered that without such measures, the strategy may not support existing businesses or deliver the jobs required within Brentwood borough.

Object

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

POLICY PC09: BRENTWOOD TOWN CENTRE

Representation ID: 22410

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.

Linkages to Brentwood station should include all modes of sustainable transport, currently passenger transport is not included.

Change suggested by respondent:

Amend Policy PC09 Criterion I. b. as follows -

'...with priority given to passenger transport, pedestrian...'

Full text:

4. Consistent with National Policy.

Linkages to Brentwood station should include all modes of sustainable transport, currently passenger transport is not included.

Object

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

POLICY PC15: EDUCATION FACILITIES

Representation ID: 22411

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy PC15 F as currently proposed allows for provision of educational facilities in Green Belt to be looked upon favourably.

Chelmsford City Council's (CCC) Local Plan EIP Inspector's view that education and community use is inappropriate development in Green Belt generally accepted.
CCC suggested Main Modification (Examination Hearing Statement - Matter 9 - The Environment) to comply with NPPF (paragraphs 143 & 145), which deleted the criterion and amended the supporting text.

Recommend criterion F of Policy PC15 be deleted and supporting text is inserted/amended within Green Belt section of Local Plan.

Change suggested by respondent:

Delete criterion F of Policy PC15, and insert the following wording after paragraph 7.103 -

The Council acknowledges that due to the extent of the Green Belt in Brentwood there may be instances where new buildings related to community or educational uses may be proposed e.g. a new village hall, ancillary buildings related to an existing school. In accordance with the NPPF, these types of uses will be considered inappropriate development. However, the locational need for these types of uses will be given appropriate weight when considering whether there are very special circumstances that weigh in favour of the proposals.

Full text:

4. Consistent with National Policy.

Policy PC15 F as currently proposed allows for the provision of educational facilities in the Green Belt to be looked upon favourably.

During the EIP for Chelmsford City Council's (CCC) Local Plan the Inspector's view that education and community use is inappropriate development in the Green Belt was generally accepted. As a result CCC suggested Main Modification to comply with the NPPF (paragraphs 143 & 145). This is set out in the Examination Hearing Statement - Matter 9 - The Environment, as follow -

Proposed changes:
Delete criterion A. (iv) of Policy CO2.
Amend the text of paragraph 8.49 of the Reasoned Justification to:

The Council acknowledges that due to the extent of the Green Belt in Chelmsford
there may be instances where new buildings related to community or educational uses may be proposed e.g. a new village hall, new ancillary buildings related to an existing school. In accordance with the NPPF, these types of uses will be considered inappropriate development. However, the locational need for these types of uses will be given appropriate weight when considering whether there are very special circumstances that weigh in favour of the proposals.

It is recommended that criterion F of Policy PC15 be deleted and supporting text is inserted/amended within the Green Belt section of the Local Plan.

Object

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

7.94

Representation ID: 22412

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

2. Justified.

Request additional wording to be inserted to include childcare to paragraphs 7.94 to ensure that the full range of education provision is considered.

Change suggested by respondent:

Amend paragraph 7.94 to read as follows -

Education in this section relates to early years and childcare, primary....',

Full text:

2. Justified.

Request additional wording to be inserted to include childcare to paragraphs 7.94 to ensure that the full range of education provision is considered.

Object

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

7.97

Representation ID: 22413

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

2. Justified.

Request additional wording to be inserted to include childcare to paragraphs 7.97 to ensure that the full range of education provision is considered.

Change suggested by respondent:

Amend first sentence of paragraph 7.97 to read as follows -

'...early years and childcare and school place planning.

Full text:

2. Justified.

Request additional wording to be inserted to include childcare to paragraphs 7.97 to ensure that the full range of education provision is considered.

Object

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

7.101

Representation ID: 22414

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

2. Justified.

The supporting text to Policy PC 15 should also include reference to Post 16 education and skills to ensure the full range of education provision is considered.

Change suggested by respondent:

Insert additional paragraph after paragraph 7.102 to read as follows -

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 traveling into Havering.

Full text:

2. Justified.

The supporting text to Policy PC 15 should also include reference to Post 16 education and skills to ensure the full range of education provision is considered.

Object

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

8.5

Representation ID: 22415

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 consideration of connectivity for wildlife and people in line with paragraph 91 of the NPPF.

Change suggested by respondent:

Add the following wording to the end of paragraph 8.5 -

with a commitment to improving connectivity for wildlife and people e.g. Green and Blue Infrastructure and Open Space policies.

Full text:

4. Consistent with National Policy.

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

Object

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

8.11

Representation ID: 22416

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 consistency with paragraph 175 of the NPPF.

Change suggested by respondent:

Add an additional paragraph after paragraph 8.11 with the following words:

The borough also contains irreplaceable habitats such as ancient woodland, ancient and veteran trees and lowland fen. These habitats would be technically very difficult (or take a very significant time) to restore, recreate or replace once destroyed, taking into account their age, uniqueness, species diversity or rarity.

Full text:

4. Consistent with National Policy.

Additional wording requested to ensure consistency with paragraph 175 of the NPPF.

Object

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

POLICY NE01: PROTECTING AND ENHANCING THE NATURAL ENVIRONMENT

Representation ID: 22417

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 consistency with paragraph 175 of the NPPF.

Change suggested by respondent:

Change D. a. to read as follows:

'...ecological survey and assessment as....'

Full text:

4. Consistent with National Policy.

Additional wording requested to ensure consistency with paragraph 175 of the NPPF.

Object

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

8.19

Representation ID: 22418

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.

Where insufficient information is provided to demonstrate the impacts (including cumulatively) of development on wildlife then the Council should refuse applications and not use conditions to secure such information.

A Local Planning Authority needs certainty of impacts from development prior to the determination of planning applications.

Paragraph 8.19 should be amended to make this clear.

Change suggested by respondent:

Amend paragraph 8.19 to read as follows -
'...compensation measures and refuse planning applications. The...'

Full text:

4. Consistent with National Policy.

Where insufficient information is provided to demonstrate the impacts (including cumulatively) of development on wildlife then the Council should refuse applications and not use conditions to secure such information.

A Local Planning Authority needs certainty of impacts from development prior to the determination of planning applications.

Paragraph 8.19 should be amended to make this clear.

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