This representation is submitted by Phase 2 Planning Ltd on behalf of the Police, Fire and Crime Commissioner for Essex (PFCC) in response to the consultation on the Pre-Submission Local Plan February 2019. This response represents both the Essex Police and Fire Service as part of their joint emergency services collaboration.

The additional population generated by development within Brentwood's Borough will place an increased demand on the level of policing and fire and rescue services for the area. This representation is therefore concerned with ensuring that policies in the Local Plan are sound in respect of infrastructure planning and mechanisms to secure new infrastructure or contributions towards both services. This submission is a holding response, which the PFCC office wishes to expand upon further during dialogue with Brentwood Borough Council in the remaining stages of its Local Plan preparation.

To maintain current levels of policing, developer contributions towards the provision of capital infrastructure will be required as Essex Police do not have capacity and funding ability to respond to growth caused by additional housing.

In respect of fire services, adequate access for fire fighting vehicles and equipment from the public highway must be available and may require additional works on or off site, particularly in very large developments. Works may also be needed to fulfil the Fire Authority's duty to ensure the provision of an adequate supply of water for firefighting.

Requirements for the provision of fire hydrants affixed to water mains and to carry out other works necessary to ensure adequate supplies of water, in terms of both volume and pressure, may be sought either as planning conditions or possibly through a planning obligation.

In addition, contributions may be sought via a planning obligation towards the provision of a new police and/or fire stations or the extension of an existing station so as to enable the fire authority to meet the nationally prescribed standards of police and fire cover for the area.

The PFCC is seeking to work collaboratively with Brentwood Borough Council to ensure that impacts on the existing Police and Fire operational services and infrastructure and its future requirements is planned for within this Local Plan rather than being dealt with in a reactionary ad-hoc manner through the determination of planning applications. It is essential to have sound policy basis in place for future determination of planning applications.

In light of the foregoing we support the intention of Policy SP04 (Development Contributions), which sets out the Council's strategy to secure new infrastructure or contributions towards new or expanded facilities.

Policy SP04 outlines at point E, (or 5 in the online version), that for the purposes of this policy the widest reasonable definition of infrastructure and infrastructure providers will be applied. This wide definition is supported by the PFCC and consistent with the Governments view of infrastructure as expressed in the Planning Policy Guidance (PPG), which supports a flexible view on the infrastructure types suitable for CIL funding for example.

A wide and flexible interpretation of infrastructure as envisaged by Policy SP04 should therefore extend to include addressing impacts on Essex Police and Fire operational and set up costs associated with its services and not just built infrastructure provision, however for the sake of clarification this should be made explicit within the wording of the policy, its supporting text and supporting glossary definitions.

We would refer the Council to the adoption of Mid Sussex District Council Local Plan and SPDs which plans for Police and Fire infrastructure requirements recognising within its policies and SPDs and makes clear that infrastructure extends to include:
* Staff;
* Premises;
* Vehicles; and
* Other infrastructure.

We would encourage the Council to follow in the footsteps of Mid Sussex District Council and work collaboratively with the PFCC office to ensure a comprehensive approach to infrastructure provision is secured through this Local Plan.

Policy SP04 or its supporting text should also be modified to make clear that further guidance on the application of Policy SP04 will be included within a Supplementary Planning Document, which will set out the likely scope and scale of planning obligations applicable to different types of development and outlines the Council's general approach to securing them.

These changes are required for soundness. We wish to appear at the oral part of the Examination in Public.