Castle Point Local Plan Statement of Common Ground with Brentwood

Castle Point Local Plan

Statement of Common Ground with Brentwood Borough Council

21 December 2020

Castle Point Local Plan 1 Statement of Common Ground with Brentwood Borough Council

1.1 This Statement of Common Ground identifies areas of agreement between Brentwood Borough Council (BBC) and Castle Point Borough Council (CPBC) in relation to BBC’s representations on the CPBC Local Plan Sustainability Appraisal (SA), Pre-Submission Habitat Regulations Assessment and Pre-Submission Local Plan.

1.2 This Statement identifies the issues raised by BBC in their representations and outcomes from meetings where these issues were discussed. It also highlights areas of joint working between the two authorities.

1.3 BBC submitted representations 213 – 219 in the Regulation 19 consultation, these can be found in Appendix 1.

1.4 BBC and CPBC had a meeting on 25 November 2020 to discuss the representations made by BBC to the CPBC Pre-Submission Local Plan, as well as an update on the local plan process for both parties.

2 Pre-Submission Sustainability Appraisal

2.1 BBC raised no issues with the Local Plan Sustainability Appraisal (SA) and considers the SA submission document and its accompanying addendum report are comprehensive documents which are supported.

3 Pre-Submission Habitats Regulations Assessment

3.1 BBC raised no issues with the Pre-Submission Local Plan Habitats Regulations Assessment (HRA) and considers the HRA submission document and its update are comprehensive documents which are supported.

4 Essex coast Recreational disturbance Avoidance and Mitigation Strategy (RAMS)

4.1 Both parties along with nine other Essex authorities signed a Memorandum of Understanding in late 2017 to work across authority boundaries to deliver a strategy to mitigate the recreational impacts of development and the additional recreational impact across the Essex coastline.

4.2 Work has continued since 2017 on the RAMS and both parties have since adopted the agreed strategy and Supplementary Planning Document.

5 Association of South Essex Local Authorities (ASELA)

5.1 In 2018 ASELA was formed with five South Essex local authorities, including CPBC and Essex County Council. In 2018 BBC joined ASELA and in June 2018 the South Essex Joint Strategic Plan Statement of Common Ground (SCG) was published. The SCG sets out the commitment to joint working and the continuing and ongoing arrangements for delivery of a Joint Plan addressing cross boundary strategic matters. 5.2 The SCG sets out how the spatial strategy work-stream will be implemented through a new local planning ‘portfolio’ to include a Joint Strategic Plan (JSP). The Joint Strategic Plan is to be designed to set out how growth and development will take place across the sub-region and the positive effect it will have on the economy, together with a coherent framework for delivery of the right scale and type of infrastructure to support growth.

5.3 The JSP will seek to implement the programme and priorities set out by ASELA in its Growth and Recovery Prospectus published in July 2020. That identifies 10 interrelated workstreams including strategic infrastructure priorities, economic recovery and growth, digital connectivity, tackling climate change and accelerating housing growth. The JSP is a project that supports all 10 of the programmes.

5.4 Both parties are committed to continue the work of ASELA and delivering the JSP.

6 Pre-Submission Local Plan

6.1 BBC broadly support the Pre-Submission Local Plan in its approach to policies. The sub-headings below outline the key points raised by BBC below:

• Housing • Employment • Town centres • Healthy and safe communities • Duty to co-operate

7 Housing

Relevant representations: 214 and 215

7.1 BBC raised concerns over the reliability within the housing trajectory on extant planning permissions and the Brownfield Register, their representation (214) highlighted that these sources made up 50% of the borough’s housing needs. Since the representation CPBC have clarified that extant planning permissions and the Brownfield Register is robust. Since the consultation CPBC have updated the housing trajectory and is satisfied the figures are robust. Details of this can be found under modification M9.11 below.

Modification Table Modification Proposed No. M9.11 Table Policy Site Completions Extant Years Total 9.1 permission 2018- 2023- 2028- 2023 2028 2033 HO9 Land west 0 0 1000 460 290 850 of Benfleet 500 350 HO10 Land 0 22 24 0 101 0 101 between Felstead Road and Catherine Road HO11 Land off 0 0 5 25 0 30 Glyders HO12 Site of the 0 0 20 19 0 39 former WRVS Hall, Richmond Avenue HO13 Land east of 0 0 100 290 65 455 Rayleigh 15 359 81 Road HO14 Land at 0 0 0 173 0 173 Brook Farm HO15 Land south 0 0 0 55 0 55 of Scrub Lane HO16 Land at Oak 0 0 0 65 0 65 Tree Farm HO17 Hadleigh 0 0 0 52 0 52 Island HO18 Land north 0 0 30 0 0 0 30 30 of Grasmere Road and Borrowdale Road HO19 Land at 0 0 10 145 0 155 Glebelands HO20 The Chase 0 10 0 320 20 340 HO21 Land 0 0 0 0 60 60 fronting Rayleigh Road HO22 Land at 0 0 0 0 12 12 Thames Loose Leaf HO23 Land east of 0 0 0 262 38 300 Canvey Road HO24 Land west 0 57 0 19 177 196 of Canvey 76 120 Road HO25 Land at 90 146 0 0 210 300 510 Thorney 225 375 74 674 Bay Caravan Park (gross of projected losses) HO26 Land at The 0 0 0 0 100 100 Point HO27 Walsingham 0 0 16 16 0 32 House HO28 Land at 0 0 40 0 20 0 40 Admiral 20 Jellicoe HO29 Land south 0 0 10 0 12 0 10 24 of Haron 12 Close HO30 Land at 0 0 14 0 0 14 Haystack car park HO31 Land at 0 0 25 0 25 0 50 Kings Park 50 HO32 244-258 0 0 0 0 50 50 London Road Total from strategic 90 146 89 91 370 3,719 allocations 337 2,237 1,112 3,897 2,625 935 Completions 2018 – 2020 (Net) 200 0 0 200 271 271 Extant planning permissions at 1 April 2020 (Net) 605 0 0 605 602 602 Policy compliant sites 29 78 186 293 12 77 275 Brownfield Land Register 125 63 15 203 67 67 50 184 Windfall 80 110 110 300 60 300 300 660 Gross total 1,409 2,488 1,423 5,320 1,349 3,069 1,471 5,889 Projected Losses on Strategic Allocations (incl -162 -277 -83 -522 Thorney Bay etc) Net total 1,187 2,792 1,388 5,367 Replacement dwellings on strategic allocations -36 Net Total 5,284

Proposed New Text – Red Underlined Proposed Deleted Text – Struck Through

7.2 Both parties are satisfied that the approach to the housing trajectory is sufficient.

7.3 BBC and CPBC both agree that the level of affordable housing as set out in policy HO4 is proportionate. Since the consultation a further viability assessment has been undertaken and supports policy HO4.

7.4 In light of the updated evidence work CPBC have proposed modifications M9.18, M9.19 and M9.20, as highlighted below. Both parties are satisfied with the proposed modifications.

Modification Paragraph Modification Proposed No. / Policy No. M9.18 Policy 1. All proposals for housing development, and mixed-use proposals HO4 Part that include an element of housing, resulting in 11 10 or more net 1 additional homes will be required to make the following level of provision of affordable housing:

a. Up to 40% for development sites on the mainland (Benfleet, Hadleigh and Thundersley)

b. On Canvey Island: i. 15% for all developments of less than 100 dwellings which include flats;

ii. 25% for all developments of less than 100 dwellings which does not include flats; and

iii. Up to 40% for all developments of 100 dwellings or more.

M9.19 Policy 3. The targets set out in Part 1a above represent the target for all HO4 Part development of 11 10 or more units. In exceptional circumstances 3 where this is evidence that a development is unviable at those levels, including below 40%, it will be the responsibility of the development to make the case to the satisfaction of the Council.

M9.20 Policy 1. The Council will seek no less than 50% of all new affordable housing HO4 Part as affordable or social rented to be affordable housing for rent, with 4 the remainder and 50% as intermediate housing affordable home ownership products, as defined in the NPPF. The Council will seek nomination rights in the Section 106 Agreement. Proposed New Text – Red Underlined Proposed Deleted Text – Struck Through