Further to recent correspondences, please find below our comments on the Local Plan Potential Main Modifications.

As mentioned during the Local Plan Examination hearings on 27 and 28 July 2021, we would be content for the Plan to be adopted subject to an immediate review. On 27 July we stated that this would enable Brentwood Borough Council to prepare an up to date transport assessment covering impacts on the strategic road network (M25 and A12 outside London) that had in certain respects been hampered by the way existing evidence had been used guided by examination timescales.

As mentioned during the hearing of 28 July, should the Local Plan be adopted based upon existing incomplete evidence and mitigation for the M25 and A12 in Brentwood, National Highways (then Highways England) would still need to engage in the planning process to assess the impacts of each planning application coming forward and secure mitigation as necessary. This is because ordinarily when a Local Plan is adopted all required mitigation is identified for the Plan as a whole, negating the need for full and detailed assessment of subsequent planning applications covered by the full Plan as stated in DfT Circular 02/2013 Paragraph 21.

Bearing these points in mind and the current position of the proposed Local Plan our requirements moving forward are to assess each planning proposal on an individual basis under a situation of either no adopted Local Plan or an adopted Plan subject to immediate review. Mitigation requirements will be considered on an individual or if possible pooled basis depending upon the timing and location of individual applications. Any subsequent Local Plan (if an adopted Plan does not exist) or Local Plan review will then need to assess the impacts of all non-consented development at the time of submission and examination in public, including any non-consented development as part of an adopted Plan if applicable and suitable mitigation will be required for all non-consented development. We feel it important to make this point to clarify our position and avoid any uncertainty in future on the status of any Local Plan related development and the mitigation requirements of the M25 and A12 in Brentwood.

Therefore, our comments specific to the Schedule of Potential Main Modifications are as follows

Policy MG06: Local Plan Review
Paragraph D should be modified to state “a review of transport and highway issues to cater for all local plan growth including all growth without an existing planning permission up to the end of the review period in consultation with National Highways…”.

MM22 Strategic Policy BE08: Strategic Transport Infrastructure
Paragraph C should be modified to state “ improvements to the highway network as deemed necessary by transport evidence (either existing or through future transport assessments submitted as part of development planning applications) or as agreed by National Highways…”.

We hope you find these comments useful. We would be happy to discuss if you require clarification of further information.

Further to recent correspondences, please find below our comments on the Local Plan Potential Main Modifications.

As mentioned during the Local Plan Examination hearings on 27 and 28 July 2021, we would be content for the Plan to be adopted subject to an immediate review. On 27 July we stated that this would enable Brentwood Borough Council to prepare an up to date transport assessment covering impacts on the strategic road network (M25 and A12 outside London) that had in certain respects been hampered by the way existing evidence had been used guided by examination timescales.

As mentioned during the hearing of 28 July, should the Local Plan be adopted based upon existing incomplete evidence and mitigation for the M25 and A12 in Brentwood, National Highways (then Highways England) would still need to engage in the planning process to assess the impacts of each planning application coming forward and secure mitigation as necessary. This is because ordinarily when a Local Plan is adopted all required mitigation is identified for the Plan as a whole, negating the need for full and detailed assessment of subsequent planning applications covered by the full Plan as stated in DfT Circular 02/2013 Paragraph 21.

Bearing these points in mind and the current position of the proposed Local Plan our requirements moving forward are to assess each planning proposal on an individual basis under a situation of either no adopted Local Plan or an adopted Plan subject to immediate review. Mitigation requirements will be considered on an individual or if possible pooled basis depending upon the timing and location of individual applications. Any subsequent Local Plan (if an adopted Plan does not exist) or Local Plan review will then need to assess the impacts of all non-consented development at the time of submission and examination in public, including any non-consented development as part of an adopted Plan if applicable and suitable mitigation will be required for all non-consented development. We feel it important to make this point to clarify our position and avoid any uncertainty in future on the status of any Local Plan related development and the mitigation requirements of the M25 and A12 in Brentwood.

Therefore, our comments specific to the Schedule of Potential Main Modifications are as follows

Policy MG06: Local Plan Review
Paragraph D should be modified to state “a review of transport and highway issues to cater for all local plan growth including all growth without an existing planning permission up to the end of the review period in consultation with National Highways…”.

MM22 Strategic Policy BE08: Strategic Transport Infrastructure
Paragraph C should be modified to state “ improvements to the highway network as deemed necessary by transport evidence (either existing or through future transport assessments submitted as part of development planning applications) or as agreed by National Highways…”.

We hope you find these comments useful. We would be happy to discuss if you require clarification of further information.