Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

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Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Sustainability Appraisal

Representation ID: 26769

Received: 22/11/2019

Respondent: Childerditch Properties

Agent: Strutt & Parker LLP

Representation Summary:

Strongly support the proposed allocation at Childerditch Industrial Estate but seek clarification regarding transport item in the IDP (T17). We question the extent to which these new cycle ways could be delivered along the A127 corridor. Who would be responsible for delivery - the IDP confirms that this will be Essex County Council but we have not been party to discussions with BBC or ECC on how this new cycle way may be delivered in either physical and monetary terms. Further clarification is required on this prior to the submission.

Change suggested by respondent:

Further clarification is required on delivery of the cycle ways structure along the A127 in either physical and monetary terms. Further clarification is required on how funding will be apportioned to developers for these works as this may impact upon the viability and delivery of the employment allocation at Childerditch Industrial Estate. Welcome a discussion with Officers prior to the submission of the Plan and in this respect, we would be happy to enter into a Statement of Common Ground with BDC in the lead up to the Examination of the Plan, to confirm the deliverability of the proposed allocation.

Full text:

These representations have been prepared by Strutt & Parker on behalf of Childerditch Properties for Brentwood Borough Council's (BBC) Consultation on the Addendum of Focussed Changes (AFC) to the Regulation 19 Pre-Submission Local Plan (PSLP) and in particular, with regards to our client's land interest on the proposed allocation at Childerditch Industrial Estate (draft Policy E12).
Childerditch Properties request the right for Strutt & Parker or any other professional advisor acting on their behalf to provide further responses in Hearing Statements or at the relevant sessions of the Examination in Public following the submission of the PSLP.
Childerditch Properties are the sole owners of Childerditch Industrial Estate. Representations have previously been made on their behalf in respect of the site throughout the Plan making process, including at the Call for Sites stage, as part of the 2013 Preferred Options Consultation and, most recently, as part of the main PSLP Regulation 19 Consultation in March 2019.
Given that this is a focussed Consultation, this representation will focus on the documents published with the AFC and other points made within our previous representations are not repeated here.
Background
Whilst it is noted that this Consultation focusses on the redistribution of housing growth planned within the Borough, we are aware that the supporting Infrastructure Delivery Plan (IDP) was updated in October 2019 and published as part of the AFC, and therefore our comments focus on this document.
Within our representations to the Regulation 19 Consultation, we provided commentary on the IDP published by BBC for the Borough at that time. The IDP includes, at Figure 3.14 of Chapter 3, a sustainable transport plan for the Southern Growth Corridor affecting Childerditch Industrial Estate, which includes indicative locations for new cycle ways and a new bus route to connect Childerditch Industrial Estate, Brentwood Enterprise Park, Dunton Hills Garden Village and West Horndon Industrial Estate (to be redeveloped).
Comments
As set out within our previous representations, we support the principle of improving walking and cycling links within the land owned by our client, which extends to Little Warley Hall Lane. However, we would still question the extent to which these new cycle ways could be delivered along the A127 corridor, as this would require every land owner to be committed to this initiative.
We previously queried who would be responsible for delivering the cycle way infrastructure improvement and it has since been confirmed within the Part B Schedule of the IDP that this will be Essex County Council (ECC). However, we are concerned that we have not been party to discussions with BBC or ECC on how this new cycle way may be delivered in either physical and monetary terms. We consider that further clarification is required on this prior to the submission of the Plan.
The Part B Schedule of the IDP provides an indicative cost for delivering the cycle way improvements, which is noted as being £7,000,000 and states that the provisional funding sources will be from Section 106/CIL. What is not clear is what proportion of these costs would be secured from developers and how much would be funded by BBC and/or ECC. This requires further clarification to provide greater certainty on delivery. It should be noted that within Chapter 3 of the IDP, these cycle way improvements are given the reference T16, but within the Part B Schedule they are given the reference T17. These anomalies also exist for other items of infrastructure identified within the IDP.
In addition to the cycle way improvements, the IDP identifies additional infrastructure that is expected to be funded by developers (to what extent is unknown). This includes the creation of a new 'West Horndon Transport Interchange', new 'Bus Route Infrastructure' and 'West Horndon Public Realm Improvements'. Further clarification is required on how funding will be apportioned to developers for these works.
Our concern is that if our client is required to provide a disproportionate contribution toward these infrastructure works through a Section 106 Agreement, this may impact upon the viability and delivery of the employment allocation at Childerditch Industrial Estate. Not only does our submission at Regulation 19 relate to the provision of new employment units at the Estate, but also the redevelopment of the existing Estate. It is my client's intention to provide a more efficient and effective layout, which will create additional floor space for new employment opportunities, as demonstrated within the proposed masterplan copied at Appendix 1 of our representations to the PSLP. These works represent a significant investment and cost for our client. It will therefore be important to ensure that contributions to infrastructure improvements are reasonable, necessary and directly relate to the allocation to ensure our plans for the Estate can come forward. We would therefore welcome a discussion with Officers on this point prior to the submission of the Plan and in this respect, we would be happy to enter into a Statement of Common Ground with BDC in the lead up to the Examination of the Plan, to confirm the deliverability of the proposed allocation.
In conclusion, we continue to strongly support the proposed allocation at Childerditch Industrial Estate, as set out in our representations to the PSLP, and will continue to promote the Estate as the Plan progresses to Examination in Public, in consultation with BBC and key stakeholders. We will also seek to prepare a Statement of Common Ground with BBC to set out clarity on the proposed allocation, including agreed objectives for the site and delivery requirements, including matters relating to the provision of necessary infrastructure. In this respect and having regard to the infrastructure identified within the IDP for the Southern Growth Corridor, we seek greater certainty on how this will be delivered, in both physical and monetary terms. We have not been party to discussions with BBC or ECC on this and would therefore welcome a discussion with Officers on this point prior to the submission of the Plan. Should Officers wish to contact me to discuss these matters further, please do not hesitate to contact me on the details at the head of this letter.

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