I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.

I am writing in respect of Brentwood Borough's Local Plan Strategic Growth Options published for consultation on the 6 January 2015 on behalf of the Cabinet Member for Regeneration and Planning, Cllr Dr. Richard Moore. This consultation coincides with our joint consultation on the Dunton Garden Suburb. The following response by Basildon Borough Council however relates specifically to Brentwood Borough's Local Plan Strategic Growth Options.

General Observations

The Council is grateful for the opportunity to comment on the Local Plan Strategic Growth Options, but is unsure of the status of the document and how it will inform the next stage of the Local Plan process. The document focuses on the strategic growth options and specific sites only which suggests that it is a discussion paper which will inform the emerging draft Local Plan. It is also not clear what has informed its preparation, given the absence of key pieces of evidence and an audit trail.

Basildon Borough Council is deeply concerned as a neighbouring Local Planning Authority that the majority of the environmental evidence base, such as Green Infrastructure Study, Landscape Capacity Study, and Surface Water Management Plan are listed in the consultation document as being 'forthcoming'. Similarly the Highways Modelling and Crossrail Economic Impacts Study are also forthcoming which suggests that they have not informed the Strategic Growth Options. Furthermore, Brentwood Borough Council has not undertaken a Green Belt Review, be it partial or full, to inform any future release of Green Belt land as implied possible in the Strategic Growth Options consultation. Basildon Borough Council therefore considers that the Strategic Growth Options paper is premature of a clear appreciation and understanding of the baseline context in Brentwood Borough and the wider Essex area and it is difficult to see how the paper can meaningfully contribute to the debate on the most sustainable growth options available.

In preparing the draft Local Plan, Brentwood Borough Council may want to consider how the findings of all the forthcoming evidence impact on the suitability and deliverability of the growth options and sites identified in this consultation document and on any potential future joint working on the Dunton Garden Suburb proposal. One cannot assume that a site would be more suitable than another, or that one part of the Brentwood Borough could accommodate more growth than another, unless it can be supported by the plan's evidence; regardless of how popular or not a location is with Brentwood's communities. Therefore it is important that any future decisions on the spatial strategy and preferred sites have been informed by all of the evidence base commissioned and not just the Strategic Growth Options paper, even if this means Brentwood Borough Council has to revise and repeat its Strategic Growth Options exercise. To proceed in any other way risks the Local Plan being found unsound and consequently unadoptable.

Basildon Borough Council understands that the identification of sites within the consultation document does not mean these sites will necessarily be allocated in the future however; the Council is unsure just how the sites set out in Figure 8 and Appendix 1 have been identified. There are a number of sites within the list that are not included in the Council's latest Strategic Housing Land Availability Assessment (SHLAA) October 2011. The assessment of land availability is, according to the Government's Planning Practice Guidance (Ref ID: 3-001-20140306), an important step in the preparation of Local Plans and a requirement of the National Planning Policy Framework (NPPF). It ensures that all land is assessed together as part of plan preparation to identify which sites or strategic locations are the most suitable and deliverable for a particular use. Brentwood Borough Council should update its SHLAA by undertaking land availability assessments on all the sites listed in Appendix 1 to help inform the emerging draft Local Plan and review this on an annual basis. These assessments must review whether sites are suitable, available and achievable in both planning and viability terms, otherwise they cannot be relied upon to make up Brentwood's development land supply.

Basildon Borough Council is also unclear as to how the open spaces in Figure 15 have been determined and acknowledges that an area of open space is identified in the location of the Dunton Garden Suburb proposal, adjacent to the boundary of Basildon Borough. Whilst it is likely that the publication of the open space, green infrastructure and sports facilities studies will provide a more up-to-date context on this issue; its absence draws into question whether Dunton Garden Suburb as discussed as part of the Duty to Cooperate is feasible. Basildon Borough Council will continue working with Brentwood Borough Council on cross boundary strategic priorities as required by the Localism Act 2011 however shortcomings in the evidence base may affect what can be achieved.

Brentwood Borough Council should also identify and consider reasonable alternatives when developing the Local Plan's spatial strategy, growth options, specific sites and policies to ensure compliance with national policy and Strategic Environmental Assessment legislation. At examination the Council would need to show that the Local Plan has been prepared in accordance with the Duty to Cooperate, and other legal and procedural requirements, and that it complies with the test of soundness. As stipulated in paragraph 182 of the NPPF, for a Local Plan to be found "sound" it should have been positively prepared, be effective including the plan's deliverability, be consistent with national policy and be justified insofar as being the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence. It is not currently clear from the published evidence how Brentwood Borough Council can demonstrate this.

Question 1 and 2

It is unclear from the information provided why two of the growth areas have been divided in such a way, namely the A12 Corridor and the A127 Corridor. It is not clear why only West Horndon is considered to be the only settlement in the A127 Corridor. Ingrave, Herongate and Great Warley could have been included within the A127 Corridor due to their proximity to the A127 and the transport connections via the A128 and B186.

In the absence of a comprehensive set of evidence, in particular the highways modelling, landscape capacity study and land availability assessments, Basildon Borough Council considers the following statement in paragraph 2.19 to be based on assumptions, which are not supported by evidence and therefore undermine the Strategic Growth Options developed.

"Due to the different character and availability of suitable land the capacity for growth is potentially greater than elsewhere in the Borough. Although the A127 suffers from congestion problems it has more scope for improvements than the A12".

Furthermore is it not clear whether the planned infrastructure investment for the A12 by the Highways Agency and Essex County Council has been considered when comparing the capacity and scope for improvements of these two major highway corridors.

Question 3

Basildon Borough Council considers that it would have been more valuable for this consultation document to have identified and enabled discussion on the principles of growth, rather than considering specific housing sites options in the absence of a comprehensive set of evidence.

Question 4

Basildon Borough Council is concerned over the appropriateness of this question in light of the available evidence. The question makes certain assumptions about the capacity of the A127 Corridor to accommodate growth which is not supported by the plan's existing evidence base as the environmental and infrastructure constraints have not yet been identified. Little weight should be given to responses to this question as the question, as presented, is misleading.

Conclusion

Not withstanding the joint project of the Dunton Garden Suburb proposal that both Councils have been engaged with and presented for public consultation, as set out in the Memorandum of Understanding (November 2014), Basildon Borough Council's responsibilities as a local planning authority for Basildon Borough are not absolved.

Basildon Borough Council is continuing its Local Plan preparation and whilst Policy Areas for Development and Change (PADCs) have been identified there can be no absolute certainty that they will continue to the final version of the Local Plan. Basildon Borough Council's emerging Local Plan is being informed by a robust and credible, but proportionate evidence base and will only be submitted to the Secretary of State when the Council is confident that it has a sound plan, which will be tested by the Planning Inspectorate.

Basildon Borough Council is aware that whilst a comprehensive Green Belt Study has been undertaken for Basildon Borough to inform preferred development locations, no Green Belt Review has yet been undertaken for Brentwood Borough to inform Brentwood Borough Council's site selection and assess the suitability of the potential Green Belt development including the proposal at Dunton Garden Suburb.

Whilst Basildon Borough Council welcomes further engagement with Brentwood Borough to ensure that the points raised in this response are addressed and to continue working together on cross-boundary strategic priorities, it would need to be confident that the Dunton Garden Suburb is the most appropriate location for growth based on the evidence in order to make an informed decision on whether to progress the proposal further.