Draft Local Plan
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Draft Local Plan
Sustainability Appraisal
Representation ID: 14382
Received: 14/04/2016
Respondent: Thurrock Borough Council
It is suggested that some of the scoring for the options in the SA has been based on assumptions that may not be correct or realistic and should be reconsidered.
* It is unclear that the options and sites have been comprehensively appraised in terms of access and sustainable transport.
* It is uncertain whether the benefits of improved accessibility brought about by Crossrail and longer term the A12 widening are taken into account.
* It is consider the housing appraisal skews the findings towards meeting the OAN but undermines the location of the housing.
* It is not considered that Housing along the A127 corridor would meet housing needs (p34) in Brentwood/Shenfield as well as housing located along A12.
* It is not considered that a new strategic settlement at Dunton Hills would be a self -sustaining community.
The scoring of the development options in relation to community and well-being tends to overstate the benefits for new strategic developments in the south without evidence being provided. Conversely the SA under-states the ability of existing locations to gain improved and additional capacity in infrastructure.
See attached and summary below:
Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.
