Comment

Representation ID: 5421

Received: 16/02/2015

Respondent: Thurrock Borough Council

Thurrock Council supports in principle the approach taken by Brentwood Council to accommodate the objectively assessed need within Brentwood's boundary, whilst recognising this is an ambitious growth agenda.

However, Thurrock Council is concerned that Brentwood Council should further review the strategic development locations issues (see response set out below and in response to Dunton Garden Suburb) and evidence base including a revised Objectively Assessed Need. It is considered the local plan will require further revision and consultation with an ongoing duty to cooperate with adjoining local authorities.

Comment

Representation ID: 5426

Received: 16/02/2015

Respondent: Thurrock Borough Council

Brentwood council needs to ensure that the local plan strategy and policies are evidenced on sound economic and housing technical studies based on robust methodologies for identifying objectively assessed need.

Thurrock remains very concerned that considerable elements of the evidence base have not been made available during the consultation process even though some of these studies were identified as forthcoming at the Preferred Options stage and despite comments made by respondents regarding this issue at this previous stage of consultation.

It is considered the draft Brentwood Local Plan remains part based on assumptions that are not clearly evidenced or available for respondents to make full and informed comments to this current consultation. The OAN report was only published very late in the consultation period. Furthermore assumptions and assertions are made in the Interim SA report without the full baseline of supporting evidence available (see other comments) This is a major error in approach and in the consultation and Duty to cooperate process. The draft local Plan and evidence when available should be subject to further consultation prior to the submission stage of the plan.

Comment

Representation ID: 5427

Received: 16/02/2015

Respondent: Thurrock Borough Council

Relevant infrastructure requirements associated with each of the proposed broad growth areas should be identified and any environmental constraints and impacts of development taken into consideration.

Comment

Representation ID: 5428

Received: 16/02/2015

Respondent: Thurrock Borough Council

Some of Brentwood Borough Council's Technical Evidence will need to be updated. The current SHMA and Economic Futures reports are based on EPOA Phase 6 study, which in turn is based on 2010 Sub-National Population Projections and 2011 interim population and household projections.

The NPPF and the Planning Policy Guidance place great weight on using up to date population and household projections. The 2012 population and household projections will be more robust than existing projections.

The current OAN may be an under or overestimate when compared to scenarios based on 2012 projections. Thurrock does not consider that numbers based on the EPOA phase 6 study constitute OAN. It is noted that the OAN report says it must be updated.

Brentwood Council needs to make sure their OAN meets the requirements of the NPPF, Planning Practice Guidance and best practice guidance (recently written by PAS). Any Draft Plan by the Council must be based on new OAN figures. It is unclear how Brentwood council will take account of new dwellings provision for households identified by DCLG/ONS projections into the OAN.

The SHMA and Economic futures will also need to be updated to reflect the new OAN, especially if it is significantly different to the current OAN figure.

Comment

Representation ID: 5429

Received: 16/02/2015

Respondent: Thurrock Borough Council

The 5,500 dwellings figure stated in the consultation document may be higher, as it will also need to include any shortfall and needs to provide for whole plan period from anticipated adoption. Therefore the 5,500 stated could actually be higher than this figure.

Comment

Representation ID: 5434

Received: 16/02/2015

Respondent: Thurrock Borough Council

Government guidance states that SHMA areas are unlikely to reflect borough boundaries. Whilst Thurrock is is not part of the same SHMA area it is considered the evidence provided for self containment of the Brentwood HMA is questionable as it relies on data from a limited period of house moved in the sub-region which may distort the level of self-containment. Also population migration and household data demonstrate significant flow into Brentwood over short and longer periods from London. It is considered the SHMA market area should be reviewed to assess its robustness and spatial geography. The SHMA is also based on the now out of data 2007 SHMA guidance.

Comment

Representation ID: 5463

Received: 16/02/2015

Respondent: Thurrock Borough Council

The NPPF makes provision for change of Green Belt boundaries. Brentwood Borough Council have not provided compelling evidence as to why they should not undertake a Green Belt Review. The 2013 and 2015 consultations both demonstrate Brentwood Borough Council cannot meet full OAN on brownfield. This constitutes exceptional circumstances for Brentwood to undertake a Green Belt Review. Both documents contain proposals for strategic Green Belt releases without a formal consistent Green Belt Review having been undertaken. The current consultation document fails to consider more strategic and consistent approach to assessing options for Green Belt release and boundary changes. Instead it relies purely on sites submitted by developers. Brentwood Borough Council should undertake a Green Belt Review as part of spatial options testing, which is subject to further public consultation before proceding to submission stage.

Comment

Representation ID: 5464

Received: 16/02/2015

Respondent: Thurrock Borough Council

Thurrock Council has no objection to the 3 proposed areas. Any spatial strategy that emerges is likely to include development options from the three areas, representing a further variation from the previous strategy. It is challengeable therefore as to whether the previous spatial options represent the best or only options to accommodate the levels of development proposed.

Thurrock Council considers that the most appropriate spatial strategy would be a variation of the previous preferred options strategy (Option 2 on page 11) with growth including Green Belt release concentrated in the A12 Brentwood/Shenfield corridor but with some limited potential for Green Belt release at West Horndon.

Comment

Representation ID: 5465

Received: 16/02/2015

Respondent: Thurrock Borough Council

North of the Borough (A):It is recognised that potential development options are limited in the broad area by its rural character and nature. Settlement expansion is constrained by limited transport and community infrastructure resulting in less sustainable forms of development.

However as stated in paragraph 3.14 of the document the potential offered by limited infill on brownfield sites should be investigated. Furthermore the capacity and re-use of previously developed land in the Green Belt for housing should be considered where appropriate and taking account of environmental and physical constraints. Sites should be appraised through the SHLAA and a criteria based policy included in the Local Plan should set out the circumstances and conditions when previously developed land can be redeveloped for housing.

Comment

Representation ID: 5466

Received: 16/02/2015

Respondent: Thurrock Borough Council

A12 Corridor (B): Thurrock Council considers there is further significant potential to provide housing and other development in the A12 Corridor Broad Area including the potential for urban edge expansion of settlements. Thurrock Council does not wish to focus on site specific proposals but suggests some broad locations and key issues.
It is recognised that the western end of the A12 Broad Location is subject to a number of environmental constraints in addition to being within the Green Belt and is likely to have limited potential for development. It is considered due to the size and extent of the Green Belt in these locations that a limited number of urban expansions are less likely to have a significant harm to the openness of the Green Belt than locations in other broad areas.