The table included as this figure should therefore remove reference to Part of R03 - Land north of A1023 as a new employment allocation for 2ha.

These representations are submitted by Strutt & Parker on behalf of Countryside Properties (UK) Ltd in relation to the Brentwood Borough Council Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our clients land north of the A1023 (Chelmsford Road), Shenfield, which has been allocated as part of a wider allocation area under Policy R03 of the PSLP. A plan showing the site is provided as Appendix A to this representation. Countryside was founded in Essex 60 years ago by Alan Cherry and has since established a reputation for delivering high quality developments. With the ethos 'creating places people love', Countryside's achievements are exemplified through having won more Housing Design Awards than any other house builder. Countryside is a major development and place-maker, having secured planning permission and building out developments in varying scales: from smaller 30 dwelling schemes on the edge of village's through to large urban extensions of 3,500 new homes plus associated community facilities. Countryside has a proven track record of delivery. The company is headquartered in Brentwood and has a proud legacy of local sites such as Clements Park and the Square on Hart Street. The representations set out Countryside Properties position in relation to the allocation of the site as part of a wider strategic allocation 'R03' Land north of Shenfield and is an important contribution towards BBC's land supply for Brentwood's Draft Local Plan. The representations provide comments on the relevant policies relating to those interests in the Draft Plan. As the Council will be aware, representations have previously been made on behalf of the original landowner of the site, on the Preferred Options Consultation in October 2013 and the Strategic Growth Options Consultation February 2015, and the Regulation 18 Local Plan in March 2018. As a result of these representations and the discussions that have been held with officers at Brentwood Borough Council alongside the Local Plan process, the site has been allocated as part of a wider allocation proposed for strategic mixed-use development on land north and south of Chelmsford Road in Shenfield, between the A12 to the north west and the railway line to the south west. Previous representation have included supporting information relating to landscape visual and Green Belt impacts have demonstrated the low value of the site in this respect, which have respectively support its proposed allocation. This representation therefore builds on this and should be read in conjunction with this information provided previously. Countryside Properties overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to the elements of the Housing, Employment and Development Management Policies and the housing trajectory relating to the delivery of Policy R03 during the plan period. Where concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist the Council to make the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy. The site extends to a total area of 4.4ha, albeit the Council have previously defined the net developable area as 3.44ha. The site is located to the north of Chelmsford Road (A1023) and immediately south of the A12, directly south west of the A12/A1023/B1102 gyratory and westbound A12 slip road. The linear residential development of Chelmsford Road lies to the south of the site. The PSLP has recognised the sustainability of the site and enclosed character, as has been evidence through previous representations of the site, and have therefore proposed it for removal from the Green Belt and for its allocation to provide housing. We support this allocation but do however have some concerns over other policies in the PSLP that may have implications for the efficient and timely delivery of this site. Housing Needs: Paragraph 4.13 of the PSLP states that the Borough's housing requirement is 350 dwellings per annum. Paragraph 4.12 confirms that this figure is calculated using the Standard Method (as per the NPPF and respective Planning Practice Guidance(PPG)). We note that the PPG now confirms that the 2014-based subnational household projection should be used to calculate housing requirements using the Standard Method (Paragraph: 004 Reference ID: 2a-004-20190220). On this basis, the relevant subnational population projections indicate an average annual increase of 293.2 households in the Borough between 2019 and 2029. The latest (2017) ratio of median house price to median gross annual workplace-based earnings for the Borough published by the ONS is 11.23. Once the Standard Method is applied using these figures this results in a requirement of 452 dwellings per annum. The NPPF requires Local Plans to meet this need as a minimum, whilst also allowing sufficient flexibility to be able to respond to rapid change. At paragraph 4.16 the PSLP considers it appropriate to apply a 20% uplift to the identified housing target of 350 dwellings per annum, resulting in a proposed target of 456 dwellings per annum. The rationale for this buffer is unclear with separate references to the buffer advising that it allows for an additional housing land supply to maintained, but also that it serves to safeguard against any potential uplift to the standard methodology for calculating housing need, pending the outcome of the Government's 'Technical consultation on updates to national planning policy and guidance'. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility or Green Belt protection. Moreover, the figure does not allow provision for unmet need from neighbouring authorities in addition to the minimum requirement. At 4.18 the PSLP confirms the Council have not been able to identify a five-year housing land supply to deliver the annualised requirement. Further to this, at 4.19 the PSLP confirms that there is a high proportion of designated Green Belt within the Borough, making it extremely difficult to achieve a five-year supply due to the fact that sites on the edge of settlements, currently within the Green Belt are not available for development purposes until the adoption of the Plan. The Borough has a limited amount of previously developed land within its authority to provide for short term delivery, as such Green Belt release is required in order to meet the Authorities housing need and deliver within the short, medium and long term, as stated at paragraph 2.54 of the PSLP. The approach to amend the Green Belt boundaries is therefore supported. Despite the outcome of the technical consultation now having been confirmed, the proposed annual housing target of the PSLP only fractionally exceeds the minimum housing requirement derived from the Standard Method, and therefore does not provide any flexibility, Green Belt protection or unmet need from neighbouring authorities in addition to the minimum requirement. In respect of the above, whilst the current PSLP and associated housing allocations seek to go some way in delivering housing that will support the recognised needs of the Borough over the next 15 years, there is clearly a need to increase this provision. Whilst this could be helped through the identification of additional sites, ensuring the delivery and efficient use of the sites that are allocated for housing will also provide a degree of buffer. Further commentary and recommendations in this regard are provided later within this representation. Five-year Housing Land Supply and Housing Trajectory: The Council is required to demonstrate a five-year housing land supply at any point in the plan period (Paragraph: 038 Reference ID: 3-038-20180913). The NPPF (Paragraph 73) confirms that a 20% buffer should be applied to the initial calculation for a five-year housing land supply requirement, in the event that the results of the Housing Delivery Test show that there has been significant under delivery of housing over the previous three years, to improve the prospect of achieving the planned supply. From November 2018 significant under delivery indicates that delivery was below 85% of the requirement for the Borough. The PPG (Paragraph: 037 Reference ID: 3-037-20180913) also confirms that the requirement for a 20% buffer also applies where a Local Planning Authority are seeking to confirm their five-year housing land supply through a recently adopted Local Plan. The results of the 2018 Housing Delivery Test confirmed that Brentwood have delivered just 50% of the housing requirement over the last three years and this is therefore well below the threshold for the 20% buffer requirement. The Borough's most recent reported five-year housing land supply (Five Year Housing Land Supply Statement as at 31 March 2018 (November 2018) ('HLSS') is 4.1 years. This is predicated on a requirement which, when considered in relation to the latest guidance, understates need; and a supply which, again when considered in relation to latest guidance, overstates supply. As such, the actual housing land supply is noticeably less. Looking at this in detail, the HLSS considers an annual need of 343 dwellings, resulting in a total requirement once the 20% has been applied of 2,058 dwellings. However, applying the latest guidance and the Standard Method, the Borough's housing requirement is 452 dwellings per annum. Applying the 20% buffer, this results in a five-year requirement of 2,712 dwellings. In terms of supply, the HLSS includes sites without detailed planning permission and without evidence such sites will be delivered within five years. As per the Glossary contained within Annex 2 of the NPPF, such sites cannot be considerable deliverable for the purposes of the five-year housing land supply. Table 1 of the HLSS suggests that at least 1,042 dwellings in the reported supply did not have planning permission. Once these are removed from the supply calculation, the five-year supply comprises 653 dwellings. It is unclear if and how many of the dwellings categorised as having extant planning permission are on major sites which only benefit from outline permission. Such sites would also have to be discounted. As such, the figure of 653 dwellings may overstate housing supply. A five-year supply of 653 dwellings compared to a requirement of 2,712 represents a 1.2-year housing land supply. This acute housing land supply shortage demonstrates the importance of allocating sites through the Local Plan which can delivery early in the plan period, and support the existing supply of housing. It also emphasises the need to avoid over-reliance on large strategic sites which inevitably take longer to deliver. The housing trajectory provided as Appendix 1 to the PSLP projects that it will enable completion of 2,305 dwellings between 2019/20 and 2023/24. Having regard to the Standard Method and the need to apply a 20% buffer to the housing requirement, the total five-year requirement for the Borough is 2,712 dwellings. Therefore, even before critical review of the supply, the PSLP will not provide a five-year supply of housing. Policy R03 - Land North of Shenfield: Policy R03 deals with land to the north of Shenfield, known as Officer's Meadow and surrounding land. The entire allocation area comprises an area of 58.2ha and it is intended that the area will provide around 825 new homes; land for a co-located primary school, early years and childcare nursery; residential care home; 5% self-build and custom build; and 2ha of land for employment purposes across a net developable area of 28.2ha. We are of the understanding that the majority of these primary facilities will be provided within the main portion of the allocated area, to the south/ south west of Chelmsford Road, which immediately adjoins the existing settlement boundary and will therefore be directly accessible and central to the strategic development as a whole. Countryside Properties land is also known as site 158, as assessed by the Council within Brentwood Borough Council's Housing and Economic Land Availability Assessment (2018). The site measures 4.4ha (gross area) and was considered by the Council to comprise a net area of 3.44ha and capable of delivering 100 dwellings. The site forms one of a number of sites that together form the Strategic Allocation under Policy R03, Land north of Shenfield. Employment Land Provision: Policy R03 refers to the provision of 2ha of employment land across the site allocation as a whole. However, it is noted that Figure 7.6 of the PSLP identifies a new employment land allocation of 2ha at land north of A1023 - the site the subject of this representation, and a more specific reference than that contained within the PSLP policy wording. We note the combined requirement for employment land set out in Figure 7.5 of the PSLP, which confirms that the maximum level of employment land expected to be required over the plan period is 45.96ha. This is a maximum, with the lower expectation falling to 33.76ha, dependent on the forecasting scenario use. Respectively, Figure 7.6 recognises a predicted total of 47.39ha of employment land to be delivered through the new Local Plan and this provision therefore currently exceeds even the highest level of forecasted need. We are aware that previous representations and the submission to the Regulation 18 Consultation in particular did consider the potential for the delivery of up to 2ha of employment uses on the site. Since this time however, Countryside Properties have now taken on the promotion of the site. This has been supported by an additional level of due diligence which, alongside further discussions with Brentwood Borough Council officers, have identified a need to discount an employment-led development on this site. Discussions with Brentwood Borough Council have confirmed that the site presents an opportunity to provide a key gateway into Shenfield and onto Brentwood in this location, our client is confident of the ability to deliver this either through exemplary residential and landscape-led design at the entrance to the site, or through a smaller provision of employment land which is respective of the current market and likely demand in this location, and not necessarily accommodating 2ha of land. Considering the employment uses referred to in Policy PC02, it has been agreed during discussions that an entirely B1 office frontage for the site would not be suited to this role, given that such a use would be unlikely to generate a visually prolific building or a flagship/feature. It would also generally be expected for offices to be located in a more urban and/or town centre location as opposed to this edge of settlement siting, and therefore doubt exists as to the likely interest in B1 premises in this location. B2 industrial or B8 storage uses would not be consistent with the desire for this location to act as a gateway to the area also, and also the implications that such a use could have on the A12 gyratory through the associated movements of HGVs and other vehicles. We are aware that there has been interest in the use of the site for other employment generating and commercial uses which would not fall under B-class uses and may be able to play a better role in the formation of a key gateway in this location. It is recognized however that the spatial requirements of such uses are again unlikely to meet a full 2ha of land. The proposed provision of employment uses on this site has not been justified and is not effective. The provision of 2ha on this site is not required to meet the Borough's identified employment need and conflicts with the deliverability of new homes on the site to meet the Council's housing need. As such, the provision of 2ha of land for employment purposes should be removed from the policy. In the interests of ensuring effective delivery, the Council should also consider the benefits of extending the provision of existing or larger proposed employment sites to account for flexibility that may be required on smaller allocations in response to market fluctuations and the viability of mixed use schemes. Countryside Properties are supportive of the land north of Chelmsford Road, Shenfield (ref.158) being identified as an opportunity to deliver a key gateway to Brentwood from the southbound A12. However, Countryside Properties consider the objective of a key gateway needs to be achieved through careful design in consultation with key stakeholders. In order to make Policy R03 effective, it is proposed that the wording in part (e) of the Policy is removed in its entirety, and for part A of Policy R03 to read: a) Amount and type of development; b) Provision for at least 825 new homes of mixed size and type, including affordable housing; c) Provision of land (circa 2.1 hectares) for a co-located primary school and early years and childcare nursery (Use Class D1); d) Provision for a residential care home (around 60 bed scheme as part of the overall allocation); e) Provision for 5% self-build and custom build across the entire allocation area. Whilst the site may have the potential to provide employment generating uses, a large scale provision of B-use class uses as required under Policies PC02 and PC03 is unlikely to be suitable for the site and the respective restrictive nature of this current wording. Countryside would however support the reintroduction of the wording presented to members which included: e) consideration for provision of appropriate new employment development on land north of Chelmsford Road. Figure 7.6 of the PSLP should be amended to reflect the proposed changes detailed above. The table included as this figure should therefore remove reference to Part of R03 - Land north of A1023 as a new employment allocation for 2ha. Unit Numbers: The wording of allocation policies such as Policy R03 should take the requirement for housing delivery flexibility into account, and therefore be worded to provide "at least 825 new homes", as opposed to "around 825 new homes". We consider that this would provide greater certainty on the number of homes to be delivered as part of each allocation for Brentwood Borough Council, and also allows for the delivery of additional units where appropriate opportunities may arise. For land north of A1023, a significant amount of feasibility work has been undertaken to establish any site constraints, and as a result of this, Countryside are confident in the ability for the site to provide at least 150 homes. We have concerns that the respective policy's current format may be interpreted to confirm the optimum use of the site, rather than a lower limit. In fact, the 100-unit figure has been produced by Brentwood Borough Council with far less rationale and technical justification than has been undertaken by Countryside Properties and may lessen the ability of this site and other policies with similar wording to support Brentwood's need for a buffer and flexibility in their housing land supply. Policy SP03 Health Impact Assessments: The Policy requires planning applications for developments of 50 or more to be dwellings, non-residential development of 1,000sqm or more or schemes for C2 class developments to be supported by HIAs. The HBF response to this policy is unsupportive and they consider the policy to be unsound as it is not consistent with national policy and is ineffective. We are in agreement with the HBF's response, dated 17th March 2019, in relation to the requirement for HIAs to be provided for 50 or more dwellings and consider the requirement to be unnecessary and an additional burden on applicants. Referring to the PPG we note that HIAs may be useful tools, however the PPG also expresses the importance of the local plan needing to consider the wider health issues in an area and ensuring the policies respond to these concerns. The guidance is provided below for completeness. Paragraph: 002 Reference ID: 53-002-20140306 confirms that provision of the required health infrastructure should be supported and taken into account at local and neighbourhood plan making, and when determining planning applications. Referring to National policy, paragraph 20 states that Strategic Policies should set out an overall strategy for the pattern, scale and quality of development, this includes infrastructure and community facilities. In order for the local plan to be consistent with national policy, the Local Plan should already consider the impact of development on the health and wellbeing of the communities and any identified infrastructure should be addressed in policy. Therefore, whilst Countryside support the important consideration of health and wellbeing of communities where development is in line with the policies contained within the development plan a HIA should not be necessary. The requirement for a HIA should only be triggered where there is a departure from the plan, enabling the Council to assess any impacts on the health and wellbeing of the community as a result of said proposals. Policy SP05 Construction Management: The Policy expects all major development schemes/developers to sign up to the Considerate Constructors Scheme, or equivalent. The scheme is a non-profit making, independent organisation which monitors construction sites signed up to the scheme, with the aim of managing and mitigating impacts arising from construction. This requirement is considered unjustified and inconsistent with national policy. Whilst we recognise the importance of managing the potential impacts on construction sites, we consider this policy to be unsound because it is unjustified and not consistent with national policy. We would suggest that consideration for the scheme is best dealt with through planning applications and development management without it being written into formal planning policy. We are not aware of any other adopted or emerging Local Plan which requires applicants and developers of major sites to enter into a specified construction management scheme and therefore question the reasonableness of this policy. The matter of construction management should be assessed on a case by case basis and should not be a matter for a strategic policy to prescribe. How a construction scheme is managed and mitigated should be an item for consideration by the decision taker and assessed on a case by case basis. The imposition of Policy SP05 requires all major developments to be signed up to the Considerate Constructors Scheme regardless of the site or proposal details. It is recommended that this policy is removed. Policy BE02 Sustainable Construction and Resource Efficiency: We consider the policy to be unsound as it is inconsistent with national policy. Part (f) of Policy BE02 requires the inclusion of renewable and decentralised energy as part of a new development, this is not consistent with national policy. Whilst Countryside recognise the importance of sustainable construction, a policy approach to such requirements does not allow for the appropriate flexibility in this regard, as recognised in the NPPF. Paragraph 153 of the NPPF states that local plans can expect development to meet such provisions, however the NPPF also states that they are only required to comply with such policies where it is either feasible or viable. To ensure consistency with national policy part (f) of Policy BE02 should be amended to reflect this position. Policy BE03 Carbon Reduction, Renewable Energy and Water Efficiency: It is Government policy to seek to deliver improvements to emissions from buildings through the building regulations regime. As such we do not consider it necessary to include the table at part (a) of this policy. Should a national zero carbon policy be introduced it will be achieved and applied through building regulations. We therefore echo those comments of the HBF's consultation response, dated 17th March 2019, and suggest that if the building regulations are updated then the Council should revisit the policy through a local plan review at that stage, but that such matters are dealt with through building regulations in the meantime to prevent unnecessary duplicate consideration of such matters through both planning and construction stages. Policy BE04 Establishing Low Carbon and Renewable Energy Infrastructure Network: It is acknowledged that the Government support the transition to a low carbon future in a changing climate, including support towards renewable and low carbon energy and associated infrastructure. Countryside support these intentions. Part (b) of Policy BE04 expects sites of over 500 dwellings, including where there are clusters of neighbouring sites that total over 500 units, shall incorporate decentralized energy infrastructure in line with a hierarchy however. We raise concerns in relation to the deliverability of part (b) of the policy in relation to sites within a cluster of 500 or more dwellings given that neighbouring sites will not necessary come forward by multiple landowners and developers at similar times. The coordinating and implementation of a heat network to serve smaller scale sites as separate applications but adjacent to other similar sized sites in the locality, is unreasonable and unjustified and could result in a delay in delivery of new homes, resulting in an ineffective local plan. It is recommended that the requirement for new development located where 'clusters' of neighbouring sites totals over 500 units should be removed from the policy in order to make the policy effective. Policy BE10 Connecting New Developments to Digital Infrastructure: It is Government policy to support the expansion of electronic communications networks. However, we would draw the Council's attention to the Written Ministerial Statement, 25th March 2015, which announced that local planning authorities preparing Local Plans, "should not set any additional standards or requirements relating to the construction, internal layout or performance of new dwellings." The Local Planning Authority are only allowed to adopt the three optional technical standards, in relation to construction, internal layout and performance, subject to evidenced need and viability. As such, the Council should not seek higher standards than Building Regulations, as already referred to in our response to Policy BE03. Therefore, Policy BE10 is considered unsound because it is unjustified and contrary to national policy. We are also unaware of National Policy requiring benches and bins to be connected to mobile digital infrastructure. As such the policy is unjustified and contrary to national policy. Countryside are committed to ensuring that all developments go as far as is practical to meet national intentions to ensure the quality, practicality and future-proofing of new housing developments. We have concerns however that by introducing a wealth of additional planning policies in these areas, there will be unnecessary duplication to building regulations, and potentially delays to planning applications which will in turn impact on the timely delivery of new homes. Summary: Countryside Properties generally support the plan, however alterations to the PSLP can enforce the soundness of the Plan, ensuring it has been positively prepared, justified and effective and consistent with national policy. The proposed allocation of land north of A1023 as part of the wider R03 strategic allocation within the PSLP is supported. Countryside do however raise concerns about the soundness of the Plan in relation to the approach taken to development management policies and timing of delivery of the site proposed for allocation. Policies mentioned above, appear to be based on an idealistic approach which does not account for different site constraints and flexibility in development management which would in turn help to protect the Council's supply of housing and robustness of the PSLP. The proposed amendments to the employment provision within Policy R03 will make the approach taken justified and effective. The proposed alterations will help to ensure that this policy is positively prepared and a justified approach for the site has taken into account the recognised constraints and the site is delivered in accordance with the expected delivery timescales, and that Brentwood can therefore meet housing needs as planned. The proposed amendments will also allow for flexibility over unit numbers in the event that the site can support the recognised need for a greater buffer and flexibility towards housing delivery over the Plan period. (Figure included in attached document).

Client respectfully requests that the Site is removed from the listed 'Existing Employment Allocations' under Draft Figure 7.6. We also note that no reference is made to the re-provision of the Council Depot which we understand is likely to be retained for employment purposes into the early years of the plan period (given its current operational status).

Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its ownership and commercial interests at Eagle Way, Warley, Brentwood (the 'Site') within the administrative area of Brentwood Borough Council ('BBC'). Accordingly, Iceni has been instructed by Ford to prepare and submit written representations to the BBC New Local Plan, Pre-submission Draft consultation (2019) (referred to herein as 'PSD'). On behalf of our Client, we welcome the opportunity to comment on PSD which was published for consultation on the 5th February 2019. This is the final stage of consultation on the new Local Plan, following which the plan will be submitted to the Planning Inspectorate for independent examination. We therefore note that this stage of consultation is inviting comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2018) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy. The PSD consultation follows two previous consultations on the Local Plan, including the Call for Sites in 2016 and Preferred Site Allocations ('PSA') consultation in 2018. As BBC Officers will be aware, Ford have continued to actively engage in the preparation of the local plan with BBC - having submitted representations to all previous stages of consultation; supporting the allocation of the Site for housing. In this regard, Ford's previous representations have demonstrated that the Site represents a highly suitable and available Site for such development early in the plan period (particularly given the recent announcement regarding a change in operational requirements moving forwards) which should be prioritised given its brownfield nature. Within the PSD consultation version of the new Local Plan, our Client is supportive of the principle of the Site's allocation for residential development under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness in the NPPF (2018) - which the PSD consultation is indeed specifically seeking comments on, our Client wishes to object to the designation of 2 hectares ('ha') of employment land on the southern portion of the Ford Site (RO4) as specifically referenced under Draft Figure 7.6 and Draft Policy PCO3 in addition to the provision of specialist accommodation and self-build housing - in the absence of sufficient, supporting evidence to justify this. At this stage, our Client therefore considers the emerging Local Plan to be unsound and unjustified in the absence of a robust strategy, which should be based on proportionate evidence contrary to the NPPF Paragraph 35 and the overarching objective of enabling the delivery of sustainable development. Our Client also wishes to raise comments on other aspects of the PSD and Draft policies (as detailed in Section 3 of this representation submission); respectfully requesting that this is reviewed by BBC ahead of its submission to the Planning Inspector for examination. We would also welcome
discussing this submission in further detail with officers at the earliest possible convenience. In accordance with the requirements of the PSD consultation, and in order to inform this submission, the following documents have been submitted on behalf of our Client: * BBC completed Consultation Form; and * Written representations statement (this report which should be read in tandem with the above). This representation is submitted in line with the consultation deadline of 19th March 2019. The Site Location and Surroundings: The Site comprises 8.51 hectares (21.03 acres) of land located within Warley, forming the southern
edge of the Brentwood settlement boundary. This is a primary location for housing growth within both the adopted and PSD version of the emerging Local Plan - recognising its urbanised location within an existing settlement boundary. The Site is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway. The Site was originally developed for military purposes before being occupied by Ford as their European headquarters in the 1950s. Whilst the head office function has since been relocated to Cologne, Germany, the Site has remained in use by Ford as a central office for its UK services. However, Ford have recently announced that the Site will not continue to have an operational function as offices for the company moving forwards (due to a change in operational requirements). As such, it now represents a pivotal strategic opportunity within the PSD as a highly deliverable and available Site for new housing. Eagle Way runs east-west through the Site, dividing it into two parcels of land, as outlined below: * 'The northern parcel' - 1.37 hectares (3.39 acres) of land to the north of Eagle Way, currently utilised for staff car parking. A bus station is located on The Drive which runs along the western boundary, with Eagle Way running along the southern boundary of the northern parcel. To the north there is BBC owned land which is currently being utilised as additional car parking by Ford (on a lease agreement), as well as the highways depot and auto garage known as 'Council Depot.' 'The southern parcel' - 7.14 hectares (17.64 acres) of land to the south of Eagle Way where the main office building is located. The 6-7 storey office building has a NIA of 43,664 sq.m (470,000 sq.ft.), together with an ancillary data centre building, car parking and landscaping. Notably, the southern parcel includes an area of Green Belt Land along the eastern edge (comprising the Warley Gap) which is not proposed for any development within the PSD. The southern parcel is bounded by woodland, Clive Road to the west, Eagle Way to the north and woodland to the east. The area surrounding Site is predominantly characterised by residential uses, in addition to Marillac nursing home (to the east) and a local centre comprising retail and commercial uses to the west. Existing Planning Policy - Designations: In terms of adopted planning policy, the Site is currently subject to employment land use designations as defined by the BBC Replacement Local Plan (2005). Land to the north of Eagle Way is designated for 'general employment', and the land to the south of Eagle Way is designated as 'office'. A small portion of the southern parcel of the Site also falls within the Green Belt, along its eastern edge - which is not proposed for any form of development within the emerging PSD. In terms of heritage, there are Grade II listed buildings located outside of the site to the west including: The Royal Essex Regiment and Royal Anglian Regiment Headquarters building and Chapel. Site Ownership: Ford is the freehold owner of the Site. Ford also occupy an additional area to the north, which is currently owned by BBC and leased to Ford as car parking (comprising part of Draft allocation RO5 within the PSD). A plan highlighting the ownership boundary is included at Appendix A1. Formal Response to PSD Consultation: The following provides a formal consultation response on behalf of our Client to the PSD consultation. Specifically, this representation relates to the 'soundness' of the PSD - commenting on individual Draft policies within the consultation document on this basis (in accordance with the PSD Consultation Form Section B). Draft Policy R04 and R05: Ford Headquarters and Council Depot: Ford notes that the current PSD includes the Warley Site as a 'Strategic Housing Allocation' with the Council Depot, Warley under Draft policy allocation RO4 and RO5 - Ford Headquarters and Council Depot, which are collectively allocated for residential development for around 473 new homes anticipated to be delivered between 2024/25 and 2032/33 (within years 9-17 of the plan period). Notably, the Draft allocation also states that 'development proposals should consider the following': * The provision of a 60-bed residential care home as part of the overall allocation; * Provision for 5% self-build and custom build across the entire allocation; and * Provision of 2ha of land for employment purposes (specifically allocated on land south of Eagle Way with reference to Figure 7.2). Supporting Appendix 2 (Site Allocations) provides two separate plans for allocation RO4 ('land south of Eagle Way'; comprising the main Ford office building) and RO5 ('land north of Eagle Way; comprising the additional car parking area for Ford and the Council Depot) setting out that the sites have a collective site area of 9.4ha - of which 8ha is considered developable: * RO4 (south of Eagle Way) - 5.34ha of which 4.5ha developable. * RO5 (north of Eagle Way) - 4.06ha of which 3.5ha developable. Ford wishes to voice support in principle for the Draft allocation in the PSD for future residential development - including up to 350 new dwellings on the Ford owned land (as per our Clients previous representations to the PSA consultation and as demonstrated as deliverable within the 'Garden in the Woods' conceptual masterplan; as prepared by Iceni Design). This is highlighted with specific regards to the Site's situation within the Brentwood / Urban Area settlement boundary; comprising of previously developed brownfield land whereby the NPPF (2018) and PSD (2019) acknowledges that housing growth should be directed as a matter of priority in promoting sustainable development (providing a sound policy basis under the test of soundness within the NPPF). The need for BBC to identify additional land for housing is also required in order to address cross-boundary pressures such as London's future housing growth, which has been exemplified within relevant London Plan EiP hearing sessions. In this context, the Mayor of London has confirmed that local planning authorities within the wider south east, where the housing market is influenced by that of London should be working collaboratively with the GLA to significantly boost the supply of housing and ensure that Local Plans meet full objectively assessed needs. The arrival of Crossrail at Brentwood and Shenfield further exemplifies this requirement. This will undoubtedly bring even greater connections to central London, inevitably resulting in an increase in people living in the local area. This places further pressure on land for residential development, with the Site at Warley providing a key brownfield opportunity for much needed new housing. However, and as per our Clients previous formal response to the PSA consultation in May 2017, Ford request that the Draft allocation is revised to reflect the Ford owned land being available and deliverable earlier in the plan period - notably, 1-5 years versus the 9-17 years currently referenced within the PSD under the collective allocation with the Council Depot. This will help to deliver a significant degree of Brentwood's housing requirement in the short term (in line with the key objective of the NPPF with regards to boosting the supply of housing without delay). In this regard, it is assumed that the collective allocation has been put forward later in BBC's housing trajectory - to reflect the timescales anticipated for the Council owned Depot to be relocated. On this basis, our Client contends that the Ford owned land should be treated separately, with the Draft allocation revised to reflect the earlier timescales for housing delivery (which has indeed been evidenced to BBC through Ford's original Call for Sites submission in addition to ongoing, open dialogue with officers following Ford's announcement regarding the rationalisation of the business and subsequent vacation of the Site later this year). In this context, we wish to emphasise that the Ford Warley Site is a highly deliverable and available site for housing development, with realistic prospects that this will be delivered within the early phases of the plan period. Conversely, the Depot site is currently unavailable with an existing occupier, whereby we understand that BBC as the landowner have made no decisions regarding the site in terms of alternative provision. The approach to separating the sites within the Plan, will ensure that the early delivery of the Ford land for much needed housing is not unduly jeopardised (in accordance with the HELAA 2018, which indicated that new housing in the Borough would be brought forward on brownfield sites within the early years of the Plan). Please also see detailed comments made to Draft Policy SP02. Ford also wishes to object to the retention of 2ha of employment floorspace specifically at the land south of Eagle Way (i.e. the main Ford site; as referenced in Draft Figure 7.2 and Appendix 2) - in the absence of robust evidence to justify this, in tandem with acknowledging that the Site is no longer suitable for such uses (with the Ford site arguably being bespoke and an anomaly within the Borough; whereby the site's location would not be an attractive location for modern commercial investment). It is also apparent that BBC actually have a surplus of employment supply over the plan period, including at other more suitable sites across the Borough, whereby there is no logical or sound reasoning for the retention of 2ha of employment floorspace at the main Ford site (please also see comments made under Draft Policy PC03 'Employment Allocations' for full details / response on this matter). In a similar context, Ford also wishes to challenge the inclusion of a 60-bed care home and 5% custom build housing across the wider RO4 and RO5 Draft allocation - in the absence of any sound justification for this (contrary to the NPPF with regards to the requirement for planning policies to be underpinned by proportionate evidence) (please also see comments made under Draft Policy HP01 'Housing Mix' and HP04 'Specialist Accommodation' for full details / response on this matter). Whilst Ford welcomes the update to the PSD with regards to the correct site areas for Draft allocations RO4 and RO5 (under Appendix 2), as per our Client's comments to the PSA consultation (enclosed at Appendix A3 for reference), Ford wish to highlight that it is not possible to feasibility accommodate the amount of development currently included across the collective allocation - in the form which the market demands, whereby the provision of a care home and 2ha of employment floorspace significantly reduces the net developable area and ability to deliver up to 350 news homes on the Ford owned land (taking account of open space and infrastructure requirements; as demonstrated within the Garden in the Woods Conceptual Masterplan). This would result in a potential dwelling density that is wholly inappropriate for this type of location and would not respond at all well to the market demand for a housing-led development. As such, and for the reasons specifically raised under Draft Policy PCO3 and HP04 Ford wishes to object to the inclusion of these additional land uses in the interests of ensuring that the Site can be maximised for much needed housing development. To insist on retaining these alternative uses would significantly impact upon the ability and rate at which new housing could be delivered on this site, which would work against other objectives and policies in the Plan which are seeking early years delivery of housing on PDL. Draft Policy SP01: Sustainable Development: Ford wishes to voice support for the stated positive approach to the presumption in favour of sustainable development under Draft Policy SP01, in line with the NPPF (2018). In this regard, it is noted that the purpose of the planning system is to act positively to contribute to the achievement of this overarching objective. Draft Policy SP01 also provides a commitment from BBC to always work 'proactively with applicants to find solutions which mean that proposals for sustainable development can be approved wherever appropriate, and to secure development that improves the economic, social and environmental conditions in the area.' Again, this is welcomed by our Client and is considered a sound approach to plan and decision making (in accordance with NPPF Paragraph 12) which we would strongly urge BBC to ensure is underpinned by all other aspects of the new Local Plan in order for it to be sound. Spatial Development Strategy - Draft Paragraph 3.23: Ford wishes to voice support for the spatial strategy set out within the PSD, under Draft Paragraph 3.23, which seeks to prioritise brownfield sites wherever suitable, making efficient use of land in urban areas. In this regard, Ford wishes to highlight the suitability of the land at Eagle Way for residential development in supporting this endeavour - which is located within the established urban neighbourhood of Warley (recognised as being the priority settlement for housing growth). As such, the delivery of housing at the Ford site should be viewed as a vital, and priority opportunity for BBC in recognising that the Borough is heavily constrained by Green Belt (which makes up 89% of the Borough area), whereby this has made it challenging for BBC to fully meet its development needs. Our Client therefore contends that this approach is sound but should be consistently reflected in other aspects of the Plan (including the Draft allocation for the Ford site as discussed at Paragraph 3.2 of these representations). Draft Policy SP02: Managing Growth - The Government has introduced a new standardised methodology for calculating local housing need in line with the NPPF (2018). This is based on 2014 household projections published by the ONS. The NPPF (2018) places a much greater emphasis on seeking to meet objectively assessed needs than previous national policy - recognising that there are several significant negative socio-economic consequences that result from a failure to meet housing needs. This includes reducing access to housing, increasing inequality and housing market instability. One of the most significant impacts of a lack of housing supply is to reduce affordability, thereby increasing the number of concealed households and increasing the proportion of income required to rent. It is noted that the current PSD (Draft Policy SP02) makes provision for 7,752 new residential dwellings (net) to be built in the Borough over the plan period 2016-2033 at an annual rate of 310 dwellings per year to 2022/23, followed by 584 dwellings per year from 2023/24-2033. This approach adopts a stepped trajectory; resulting in the backloading of housing delivery beyond 2023 which we understand is in part due to a high proportion of Draft designated GB edge of settlement sites not being available for development until later in the plan period. Whilst our Client supports BBC's ascertain to direct housing growth to allocated sites in highly accessible locations along the transit/growth corridor (including the Ford Site) (as referenced under Draft Policy SP02 B), our Client considers that the starting point for examination of the Plan should be that a straight, rather than stepped trajectory should be used - to avert a significant, historic under-delivery of housing to persist (acknowledging that BBC are continuing to under-supply against its housing requirement until at least 2022/3). Whilst we do not consider that the principle of a stepped trajectory is justified, if this is accepted, we consider that a higher annual rate of housing delivery over the five-year period to 2023 should be tested. Iceni note that the current requirement for 310 dpa would fall below even the projected level of household growth. Indeed, the SHMA (2018) sets out that BBC has an uncapped need of 365 homes per year, reduced to 350 once a 40% cap is applied. The SHMA has pragmatically advised that BBC still needs to plan for at least 380 dpa as a minimum. Accordingly, we believe that BBC should take a rational position on this and plan for a higher annual housing target leading up to 2023 to ensure that a robust strategy is adopted (in line with the test of soundness). Notwithstanding, Ford encourages BBC to review the OAN figure as the Local Plan progresses towards examination to ensure that the housing target is adequately reflected. Housing Trajectory: In light of comments raised above (in addition to our Client's comments to Draft Policy RO4 and RO5), we contend that the housing trajectory referenced within Appendix 1 of the PSD should be reviewed and adjusted to recognise that the Ford Warley site (both the northern and southern parcel) can be delivered earlier in the plan period (1-5 years versus the 9-17 years as currently drafted), irrespective and in isolation of the Council Depot - which our Client has indeed raised in both previous rounds of consultation on the local plan (including the Call for Sites and PSA). Indeed, and as BBC officers are aware, Ford will be vacating the Warley Site in 2019, with Conceptual masterplanning already undertaken and submitted to BBC; demonstrating the deliverability and suitability of the Site for a significant quantum of residential development on the Site (please refer to 'Garden in the Woods' Conceptual Masterplan at Appendix A2; as submitted to BBC in May 2017 as part of the Call for Sites consultation). Further to ongoing dialogue with BBC, our Client also understands that the timescales for bringing forward the Council Depot for housing (which is still operational) are currently unknown at this stage, whereby the early delivery of the Ford site for housing should not be precluded on this basis. As such, our Client contends that the PSD as currently drafted, is contrary to the Governments ambitions to deliver 300,000 new homes by the mid-2020s nationally - ignoring the availability and deliverability of a significant proportion of housing at the Ford site, early in the plan period in providing for much needed housing for the Borough as soon as possible, at a sustainable brownfield location. In this regard, it is considered that the PSD is unsound on this basis and should be revised prior to being submitted for examination by BBC. Draft Policy SP06: Effective Delivery of Development: Our Client notes that Draft Policy SP06 is designed to ensure that a collaborative and participatory approach is taken when working up proposals. Ford are broadly supportive of this policy position, understanding the importance of comprehensive masterplanning to inform strategic site delivery. However, our Client wishes to note that such exercises should not inhibit the ability of individually owned sites to come forward for development. This is specifically referenced with regards to the Council Depot currently being included under the wider allocation for the Ford site, which we understand is not anticipated to be available for redevelopment until later in the plan period. As such, whilst Ford welcomes open and collaborative discussions regarding the wider allocation, and indeed the masterplan works to date have shown how future connections could be made to the Depot site; in tandem with how development could be proposed so as not to prejudice the development of either site, the early delivery of housing on the Ford owned land should not be prejudiced by delays in the decision-making process with regards to the Depot (see also comments under Draft Policy RO4 and RO5). It is considered that this would go against the premise of the overarching objective of the emerging Local Plan and the NPPF (2018) Paragraph 59 in terms of the delivery of sustainable development and ensuring the supply of homes without unnecessary delay. Draft Policy HP01 Housing Mix (varied types and tenures): Ford supports the intentions of Draft Policy HP01 in seeking to ensure that residential development proposals deliver housing in a way that contributes to the rebalancing of the housing stock; ensuring it reflects the recognised needs of existing and future communities. This includes providing a mix of dwelling types, sizes and tenures, relevant to the context of each site. Self-Build and Specialist Accommodation Threshold: Notwithstanding the above, our Client notes that the threshold for requiring a minimum of 5% self-build homes (which can include custom housebuilding and provision for specialist accommodation; see comments also made to Draft Policy HP04) is set at 500 or more dwellings. However, this threshold does not appear to have been applied to Draft allocations RO4 and RO5, which includes a requirement for both custom build housing and specialist accommodation across the wider allocation, despite having a total housing yield of 473 units across the Draft allocation - i.e. under the 500-unit threshold. Accordingly, our Client urges BBC to review this and requests that Draft allocation RO4 and RO5 is revised to remove this requirement based on the threshold set under Draft Policy HP01. At present, it is considered that there is a lack of evidence to justify this policy position, rendering the PSD unsound on this basis. Draft Policy HP03 - Residential Density: Ford welcomes Draft Policy HP03, which aims to ensure efficient use of the boroughs land whilst promoting a design-led approach to density which ensures schemes are sympathetic to local character and context. The supporting text states efficient land use is essential in a borough like Brentwood where land is scarce and enables new homes to be provided without encroaching on the countryside. This stresses the importance of delivering new housing on previously developed sites. Draft Policy HP05 - Affordable Housing: We fully appreciate that there is a significant need for affordable housing in Brentwood Borough, with 35% affordable applied to major residential schemes. Ford are aware that this level of affordable housing will likely be applied as part of any future planning application for the site, however this will be subject to scheme viability. BBC have recognised this approach, outlining that they will consider this where robust viability evidence demonstrates that the full amount of affordable housing cannot be delivered. This approach is welcomed by our Client and is considered to form a sound basis for negotiating affordable housing on a site-by-site basis (in line with NPPF Paragraph 62). Draft Policy PC03 - Employment Allocations: Ford notes that Draft Figure 7.6 and Appendix 2 of the PSD includes Part of allocation RO4 - 'Ford offices Eagle Way' (southern parcel of the Ford owned land) as an Existing Employment Site, whereby 2ha of land is proposed to be retained for employment purposes. However, there is no further evidence and/or explanation provided for this designation, which our Client indeed questioned and requested within our previous representations to the PSA consultation. Further, Draft Figure 7.5 'Employment Land Need' of the PSD outlines an employment land requirement of between 33.76ha and 45.96ha (taking account of four growth scenarios referenced under Draft Figure 7.4; as derived from the supporting Economic Future Report ['EFR'] January 2018). The EFR states that there is a pipeline supply of employment space in the Borough totalling 111.3ha. This includes 47.4ha of new employment allocations, 41.0ha of existing employment allocations, and 22.9 ha of existing employment sites previously unallocated. When subtracting the employment land requirements from BBC's new employment land supply there is a surplus in the range of between 21.4 ha and 33.7 ha (which is indeed recognised by BBC under Draft Paragraph 7.20 'exceeding requirements'). As such, it is highlighted that with the new employment allocations alone, BBC appear to have more than supply of employment land to meet its overall forecast needs over the plan period - questioning the requirement to retain 2ha of employment floorspace at the Ford site (whereby there appears to be very limited, or indeed no market demand for such space with no real planning basis for the 2ha figure referenced). Accordingly, it is anticipated that the new supply through the 'Proposed Allocations' should sufficiently compensate for the full release of the Ford site for residential with the Draft allocation for the Site revised accordingly including the removal for the requirement for 2ha of employment land. Ford also wishes to emphasise that the existing offices at Eagle Way were designed specifically for Ford and are bespoke for the operational and commercial requirements of Ford. It is therefore very unlikely that the Site could continue to support large-scale, modern employment uses of such a scale. It is also considered that the distance from Brentwood and Shenfield town centres and train stations would not be an attractive location for commercial investment - acknowledging that typically businesses requiring commercial properties of this size today, would pursue sites within close proximity of strategic infrastructure, trunk roads and more extensive local facilities and services. As such, and in light of current national policy parameters which specifically seek to promote sustainable forms of development, Ford wishes to object to the retention of employment uses at the Site - acknowledging that such a use is not considered an appropriate, or viable use of the Site in the future (contrary to the NPPF 2018). Ford further acknowledges that whilst there will be a requirement for commercial space in the Borough, land for residential development is critical in order to relieve any additional pressures on the Borough's Green Belt - with the Site representing an ideal opportunity for maximising residential development (including much needed family accommodation) which should be recognised under the Draft site allocation versus being restricted. In light of the above, and in the absence of robust evidence, Ford wishes to object to the provision of any level of employment use at the Site - rendering the PSD, Draft Policy PC03 and allocation RO4 and RO5 unsound on these grounds. Our Client therefore respectfully requests that the Site is removed from the listed 'Existing Employment Allocations' under Draft Figure 7.6. We also note that no reference is made to the re-provision of the Council Depot which we understand is likely to be retained for employment purposes into the early years of the plan period (given its current operational status). Draft Policy HP04 - Specialist Accommodation: Ford acknowledges that BBC are encouraging proposals to contribute to the delivery of Specialist Accommodation and are broadly supporting of Draft Policy HP04 in terms of providing such facilities where there is a 'demonstratable established local community need'. Ford recognises that the SHMA Part 2 (2016) identifies that there is likely to be an additional need for 494 specialist units over the next 20 years, including 466 units as sheltered housing and 28 extra-care units (albeit no distinction is made between them within the Draft policy wording, with no further assessment having been undertaken in recent years with regards to local requirements). Whilst Ford is supportive of BBC seeking to accommodate such facilities across the Borough, we note that there is currently a lack of evidence (including a detailed assessment of local community need) to fully justify accommodating such a use under Draft allocation RO4 and RO5, alongside residential. Indeed, we understand that that this requirement has only been included in response to a likely strategic-need for age friendly housing, but with no local analysis and/or basis to support this. Accordingly, and similarly to Ford's comments regarding the retention of employment uses at the Site, Ford wishes to highlight that due to the Site's location on the edge of Warley, it is considered that the Site does not represent the most suitable location for specialist care accommodation, with no analysis having been undertaken by BBC to demonstrate how the site is best placed to serve older people and their specialist needs. This goes to the heart of the NPPF (2018) test of soundness, in terms of the requirement for policies within local plans to be based on proportionate evidence. Further, Ford's commercial advisors CBRE have undertaken a recent analysis of local demand and supply within the surrounding Site area (Pulse Report) whereby this has identified that there is an oversupply of bed spaces across a variety of care spectrums (including a c.200 bed space oversupply within a 5-mile radius and c.1,000 within a 3 mile radius) - signifying a lack of need within the local area; whereby the Draft allocation would likely result in an un-viable future use (contrary to the parameters of sustainable development set out within the NPPF). As such, we would strongly urge BBC to revise the Draft allocation for the Site accordingly - recognising that it is most suitable for residential use only. Summary: On behalf of Ford, thank you for providing the opportunity to comment on the BBC PSD consultation document. As noted above, Ford is broadly supportive of the Draft allocation of its Site for housing, subject to further discussions with BBC Officers regarding the proposed additional land uses and development capacity - with sufficient evidence requested to justify the former, prior to the Local Plan being submitted for examination (to ensure that it is sound and legally compliant, in accordance with the NPPF 2018). We trust that the enclosed is clear, but please do not hesitate to contact Andrew Gale or Lucy Howes should you require any additional information. We would welcome discussing these representations with BBC at the earliest possible opportunity and to be kept informed of progress to the next stages of local plan preparation.