brentwood.gov.uk

The failure of the Local Authority to produce an updated Proposals Map means that the Plan is not sound. The lack of completion of the Green Belt Evidence Base means that the subject site has not been properly assessed. Also, in accordance with the February 2019 NPPF, there should be revisions to the Green Belt Policy, Criteria A g Limited Infilling addition to add the words - "Not cause substantial harm to the openness of the green belt where the development would re-use previously developed land and contribute to meeting an identified affordable housing need within the area of the Local Planning Authority". Also further, the Criteria for replacement or substantial re-building of permanently occupied dwellings are too limiting. Any reference to 30% above original habitable floor space should be deleted and the wording of the Policy more in accordance with the NPPF and relate solely to disproportionate increases.

This representation is in relation to Policy PC03 and Employment Land Allocations and the Proposals Map in relation to the Green Belt. McColls Headquarters Site, Ongar Road, has been identified as Site 321 as an existing employment site in the Green Belt. It is all previously developed land and reference is made to the Site Area as 1.6 hectares. As a site in the Green Belt, it should rank along other sites that have been brought forward existing employment sites not previously allocated and new land allocations. The Emerging Plan has identified such sites as being released from the Green Belt. Our key concern is the fact that no Proposals Map yet exists. It is assumed that as all these sites make an important contribution to the strategy for delivering economic growth, that the previously developed land of McColls will be shown as an employment site excluded from the Green Belt. It is a site that is adjacent to the primary road network coming into Brentwood and has availability to public transport facilities, including bus services. It sits opposite a Primary School and adjoins other built form. The Green Belt Study which should underpin and inform all potential Green Belt releases has not yet been completed, with working drafts only currently being available in respect of Part 1 & 2 Assessments. The subject site is intensively developed with over 5,000 sqm of floor space. The more modern office buildings are now over 60 years old and in need of substantial refurbishment or redevelopment. There is the opportunity to provide new development and make better use of the previously developed land. Until such time as the Proposals Map is released and it is clarified as to how this site is treated, we would maintain an objection. The site has within it a number of non-designated heritage assets which would benefit from some form of residential development and the site provides an opportunity for some mixed use.