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Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report October 2019 SA of the Brentwood Local Plan REVISION SCHEDULE Rev Date Details Prepared by Reviewed by Approved by 1 October SA Report presented to Extraordinary Mark Fessey Steve Smith Steve Smith 2018 Council Associate Technical Director Technical Director Chris McNulty, 2 January SA Report published alongside the Pre- Senior consultant 2019 submission Plan 3 October Partial update to the SA Report 2019 published alongside an ‘“Addendum of Focussed Changes to the Pre- Submission Local Plan (Regulation 19)” Limitations This document has been prepared by AECOM Infrastructure & Environment UK Limited (“AECOM”) in accordance with its contract with Brentwood Borough Council (the “Client”) and in accordance with generally accepted consultancy principles and the established budget. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. AECOM shall have no liability to any third party that makes use of or relies upon this document. AECOM Infrastructure & Environment UK Limited 2 Leman Street, London E1 8FA Telephone: 020 7061 7000 A note on this partial update This partial update to the SA Report is made available as part of the consultation on “Focused Changes”. The only updates made within this report, relative to the SA Report as previously published in January 2019, are within Section 9 of the report, which presents an appraisal of the Pre-submission Plan. Specifically, at the end of each of the thematic sub-sections within Section 9 a new discussion is added under the heading “Implications of the Focussed Changes”, which gives consideration to: • the Focussed Changes, which are relatively narrow in scope, involving a decrease in the number of homes assigned to four allocated sites1 and a consequential 70 homes increase in the number of homes assigned to Site R01 Dunton Hills Garden Village Strategic Allocation; and • updates to the evidence-base since January 2019, including the new higher Local Housing Need (LHN) figure for Brentwood Borough, which is 454 dwellings per annum (dpa). The decision was taken to leave other Parts/Sections of the report unchanged,2 including Part 1, which importantly explains the process of exploring ‘reasonable alternatives’. Latest understanding – including in respect of housing capacity at the five sites that are a focus of Focussed Changes, and also in respect of LHN – did not lead to a need to reconsider the reasonable alternatives. 1 Site R18 Land off Crescent Drive, Shenfield (20 homes); Site R19 Land at Priests Lane, Shenfield (30 homes); Site R25 Land North of Woollard Way, Blackmore (10 homes); and Site R26 Land North of Orchard Piece, Blackmore (10 homes); 2 The opportunity was also taken to correct a small number of typographical errors, and also to change references to ‘the Proposed Submission Plan’ to ‘the Pre-submission Plan’, with a view to ensuring consistent terminology. SA REPORT i SA of the Brentwood Local Plan TABLE OF CONTENTS INTRODUCTION ................................................................................................................................................ 1 1 INTRODUCTION ...................................................................................................................................... 2 2 WHAT IS THE PLAN SEEKING TO ACHIEVE? ..................................................................................... 4 3 WHAT’S THE SCOPE OF THE SA? ....................................................................................................... 6 PART 1: WHAT HAS PLAN-MAKING / SA INVOLVED UP TO THIS POINT? ............................................... 8 4 INTRODUCTION (TO PART 1) ................................................................................................................ 9 5 SELECTING THE REASONABLE ALTERNATIVES ............................................................................ 11 6 APPRAISAL OF THE REASONABLE ALTERNATIVES ...................................................................... 41 7 DEVELOPING THE PREFERRED APPROACH ................................................................................... 43 PART 2: WHAT ARE SA FINDINGS AT THIS CURRENT STAGE?.............................................................. 45 8 INTRODUCTION (TO PART 2) .............................................................................................................. 46 9 APPRAISAL OF PRE-SUBMISSION PLAN ......................................................................................... 49 PART 3: WHAT HAPPENS NEXT? ................................................................................................................. 79 10 INTRODUCTION (TO PART 3) .............................................................................................................. 80 11 PLAN FINALISATION ............................................................................................................................ 80 12 MONITORING ........................................................................................................................................ 80 APPENDIX I - REGULATORY REQUIREMENTS ........................................................................................... 81 APPENDIX II - CONTEXT AND BASELINE REVIEW .................................................................................... 85 APPENDIX III - SITE OPTIONS APPRAISAL ................................................................................................. 97 APPENDIX IV - BRENTWOOD/SHENFIELD OMISSION SITES.................................................................. 116 APPENDIX V - VILLAGE OMISSION SITES................................................................................................. 121 APPENDIX VI - SPATIAL STRATEGY ALTERNATIVES APPRAISAL ....................................................... 125 SA REPORT ii SA of the Brentwood Local Plan INTRODUCTION SA REPORT 1 INTRODUCTION SA of the Brentwood Local Plan 1 INTRODUCTION 1.1 Background 1.1.1 AECOM is commissioned to undertake Sustainability Appraisal (SA) in support of the emerging Brentwood Local Plan. 1.1.2 Once in place, the Local Plan will establish a spatial strategy for growth and change in the Borough over the next 15 years, allocate sites to deliver the strategy and establish the policies against which planning applications will be determined. Figure 1.1 shows the plan area. 1.1.3 SA is a mechanism for considering and communicating the likely effects of an emerging plan, and alternatives, with a view to avoiding and mitigating adverse effects and maximising the positives. SA of Local Plans is a legal requirement.1 1.2 SA explained 1.2.1 It is a requirement that SA is undertaken in-line with the procedures prescribed by the Environmental Assessment of Plans and Programmes Regulations 2004, which were prepared in order to transpose into national law the EU Strategic Environmental Assessment (SEA) Directive. 2 1.2.2 In-line with the Regulations, a report (known as the SA Report) must be published for consultation alongside the draft plan that essentially ‘identifies, describes and evaluates’ the likely significant effects of implementing ‘the plan, and reasonable alternatives’.3 The report must then be taken into account, alongside consultation responses, when finalising the plan. 1.2.3 More specifically, the SA Report must answer the following three questions: 1. What has Plan-making / SA involved up to this point? – including with regards to the consideration of 'reasonable alternatives’. 2. What are the SA findings at this stage? – i.e. in relation to the draft plan. 3. What happens next? – including in respect of monitoring. 1.3 This SA Report 1.3.1 This report is the Brentwood Local Plan SA Report. It is published alongside the final draft (‘proposed submission’) plan in-line with Regulation 19 of the Local Planning Regulations. 1.3.2 Questions 1 - 3 are answered in turn, in order to provide the required information.4 Before answering Question 1, two initial questions are answered in order to further set the scene: i) What is the plan trying to achieve? ii) What is the scope of the SA? 1 Since provision was made through the Planning and Compulsory Purchase Act 2004 it has been understood that local planning authorities must carry out a process of Sustainability Appraisal alongside plan-making. The centrality of SA to Local Plan-making is emphasised in the National Planning Policy Framework (NPPF, 2018). The Town and Country Planning (Local Planning) (England) Regulations 2012 require that an SA Report is published for consultation alongside the ‘Proposed Submission’ plan document 2 Procedurally SA and SEA are one and the same, with no legislation or guidance to suggest that SA process should differ from the prescribed SEA process. SA and SEA differ only in terms of substantive focus. SA has an equal focus on all three ‘pillars’ of sustainable development, whilst SEA involves a degree of focus on the environmental pillar. SA therefore ‘incorporates’ SEA. 3 Regulation 12(2) of the Environmental Assessment of Plans and Programmes Regulations 2004. 4 See Appendix I for further explanation of the regulatory basis for answering certain questions within the SA Report, and a ‘checklist’ explaining more precisely the regulatory basis for presenting certain information. SA REPORT 2 INTRODUCTION SA of the Brentwood Local Plan Figure 1.1: Brentwood