The Plan identifies a number of potential preferred allocation sites for employment development, each with their own characteristics and ability to deliver space for a variety of B Class uses. Further assessment could usefully be undertaken to understand more precisely what each of these sites, particularly at East Horndon Hall and DHGV could most usefully deliver. The plan currently envisages a 5.5ha site for dedicated employment uses at DHGV but correctly notes at paragraph 123 that "The exact range and type of employment development at Dunton Hills is still subject to detailed site master planning, but will need to be compatible with residential uses and of a human scale which is appropriate to a garden village." Preferred Allocation 187 on land south of East Horndon Hall is specifically allocated for employment purposes with the note "Self-contained employment site capable of being linked to DHGV proposals. This allows for increased development of new homes at Dunton Hills." Finally, on this point, the Employment Typology contained in the draft IDP identifies the 5.5 hectares of employment land at DHGV as potentially including land for B1a, B1b (Research and Development,), B1c, B2 and B8 uses.
In the Promoters view the precise scale, type and location of any employment land allocation at DHGV, whether with or without the development on land south of East Horndon Hall requires further assessment. Paragraph 5.13 of the Lichfield document states that the provision of future employment land should consider carefully how businesses use premises. The report concludes on this point that "These factors mean that the Council will need to plan for a flexible employment land supply."
The changing requirements for employers and the changing nature of employment with improved technology raises genuine opportunities for new settlements such as DHGV to deliver a different form of employment generation. Economies of scale and the potential to incorporate infrastructure including high speed broadband comprehensively and from the start of development affords the opportunity to consider efficient and sustainable home working, perhaps with shared meeting facilities within the village. The Promoters continue to investigate the potential for this form of technological innovation and intend to include appropriate references within subsequent applications for planning permission. In the meantime, though it is important that opportunities of this kind are captured in any allocation policy.
See additional documents

Employment Land - Need and Supply -

ECC acknowledges the ambition to develop new key strategic employment sites but this needs to be set within the wider context of Brentwood's Spatial Strategy, and any location needs to be consistent with the criteria to seek to ensure future developments are located in accessible locations reducing the need to travel. ECC therefore withholds support until the appropriate highway modelling has been undertaken, to assess both the site specific and cumulative impacts of such developments on the local, and wider, highway network.

ECC supports the proposed strategy of providing a range of employment and business development, through new employment (B use) land and existing employment sites, and their redevelopment where appropriate. However ECC considers uses should not be restricted to B use classes on allocated employment sites, other sectors, such as retail, hotel and leisure also need be provided for. Furthermore consideration should be given to the need for providing businesses with sufficient flexibility for them to function which reflects requirements for 'Grow-On Space'. ECC welcome the opportunity to engage with BBC in considering which interventions are the most appropriate and viable to ensure the Draft Plan provides flexible local employment space (such as flexible tenure) to meet the employment and economic needs of the Borough.

ECC welcomes and supports the ambition for economic growth in Brentwood Borough, seeking to deliver the upper range of employment land requirements, and notes the additional evidence base produced since the Draft Local Plan (2016) consultation, including the Economic Futures 2013-2033 (November 2017), and the Brentwood Economic Strategy (2017-2020).

As ECC advised under the Spatial Strategy section of this Appendix, concerns are raised over the allocation of 57% of the new employment land on one site, Brentwood Enterprise Park (BEP). The Economic Forecast Report also highlights concerns with regard to the considerable reliance on the BEP employment allocation. It is recommended that consideration be given to the phasing and deliverability of the site, to ensure a readily available supply of employment land across the short, medium and long term.

Furthermore ECC would draw attention to the 'red line' boundary for the Lower Thames Crossing major road scheme, which seeks to incorporate a significant part of the BEP employment allocation. Clarification is sought over the deliverability of the full allocation over the Plan period, particularly given the need for the site to come forward in the short, medium and long term.

ECC acknowledges the significant contribution the BEP allocation would make to meeting the employment needs of the borough over the Plan period. However, its location, in close proximity to the M25 and A127, which is presently over capacity, provides primarily car based connections to service centres, and potential sources of employees. The location is not favourable to sustainable transport measures and at present there is limited evidence regarding any potential connectivity of the proposed development via sustainable transport measures. Additional clarification will be required regarding opportunities for such measures, and the output of any impact on the strategic junction, local road network, and potential mitigation requirements. The potential impact on the above would also depend on the mix of B1, B2 and B8 uses proposed on the site.

Hermes Investment Management support the new employment allocation on land at East Horndon Hall (paragraph 123)

ECC questions the inclusion of site 121 (Mellon House) in the calculations of existing allocated employment land given evidence which advises that this site has been sold to a residential developer. The site has Permitted Development approval for 70 flats and planning permission granted for an additional 5 penthouses.

ECC seeks clarification over the assumptions and considerations taken when determining the delivery forecast figures assigned to the employment sites, other than BEP.

ECC seek clarification on the balance to be achieved between providing residential development in the town centres, on sites currently providing car parking facilities, and the need to ensure local retail and leisure sector businesses continue to thrive and are provided with suitable facilities.

I used to work for BNY Mellon in Ingrave Road, until all staff were made redundant and the office closed in Dec 2016. As well as BNY Mellon leaving Brentwood, other firms (e.g. Equity Red Star) have also disappeared in recent years, taking many hundreds of jobs with them. One of the biggest gripes of BNY Mellon employees was the lack of affordable parking. Whilst I appreciate that people should try to use public transport where possible, this was simply not viable for many people who worked at BNY Mellon and having to pay up to £10 per day was too much for many staff. When existing and new sites are being evaluated for the creation of more jobs in the Borough, both public transport links and the need for sufficient parking need to be very carefully considered.

I am making comments on the plan and note the suggestion that Fords Warley and the Eagle and Child pub will both close as part of this plan. Clearly the closure of Fords is a massive blow to the area and I do hope they are relocating.
I note the plan for business premises. The problem in this area are that the requirements for business premises are not met by the current stock of properties available. As a small office style business which needs to be near to transport links the absence of suitable accommodation has caused us to relocate to South Quays. There appears to be a view that our of area business sites are the most useful. They are not for the current type of micro and SME that is being created.
My other concerns are about the road links and car parking as a consequence of these plans. I would urge the development first of a major multi story car parkin Brentwood before the other projects run. At present it is difficult to park and any change to the level of car parking to residents is likely to have a negative impact on the High Street and surrounding areas.
The Priests Lane development has real problems in terms of road usage. The minor roads that would be the linkage are already overused and are likely to be clogged. The impact on the limited car parking in Shenfield will also need to be considered. To maximise the value of Crossrail there is a need for a multi story car parking Shenfield which should probably be on one of the Railway existing car parks. This will allow Shenfield to be the successful transport hub it needs to be. However you will also be aware of the problems with the roads around the station and main street area and this must be addressed as part of the plan. I would suggest that the multi story be built and then the main street parking bays be removed altogether.
To get buy in from the local population to this I would suggest that in the first stage the car park should be free to local residents and that a residents voucher can be obtained. However out of town users will need to pay which will subsidise the project.

I refer to the current "Regulation 18" consultation on the Brentwood Draft Local Plan Site Allocations Development Plan Document (DPD) and set out below comments on behalf of Simons Developments Limited and R P Gaymer on the DPD in so far as it relates to their land interests at Ingatestone.

You will recall that we commented on the previous "Regulation 18" consultation in March 2016 with reference to 2.06 hectares of land to the east of Ingatestone By Pass fronting Roman Road. The broad thrust of those representations supported the removal of the site from the Green Belt and its proposed allocation for employment uses but sought a wider allocation to include for other employment generating uses outside of Class B of the Use Classes Order. Specifically the employment generating benefits of including retail uses (Classes A1 - A5) and residential care (Class C2) were noted alongside commentary as to how new convenience (food) retail floorspace would address an existing deficiency in local food shopping provision.

Following meetings to discuss the above representations we submitted a detailed Statement of Delivery in late 2016 which was supported by highways, flood risk and drainage, noise, ecology, landscape and visual impact, and heritage analysis. On the basis that Statement has not been submitted thus far as part of any formal consultation it is attached to Email 2 of these representations for completeness.

In so far as the current Preferred Site Allocations DPD is concerned I set out below a number of observations:

1. We welcome the additional housing proposed at Ingatestone which equates to 218 new dwellings over the plan period.

2. The additional residential development will exacerbate the existing deficiency in local food shopping provision. As previously identified Ingatestone - by reference to the Brentwood Retail and Commercial Leisure Study (BR&CLS) 2014 - attracts only a small percentage of available convenience goods expenditure from the local area. Specifically, the Co-Op attracts only 8.2% and the Budgens 9.9% of that expenditure. This is very low and represents an unsustainable pattern of food shopping with a significant number of linked trips to large format out of centre food stores further afield.

3. Figure 23 of the Preferred Site Allocations DPD identifies an employment land requirement of between 33.76 hectares and 45.96 hectares and an allocation of 47.39 hectares. Whilst that is a surplus of +0.43 hectares against the upper requirement allowing for pipeline change of use it is a surplus of +12.63 hectares against the lower requirement. Accordingly there is clear scope for flexibility and a wider mix of uses on the proposed allocation at Ingatestone.

4. Whilst it is appreciated that this current "Regulation 18" consultation is effectively a rerun of of that undertaken in March 2016 save for the introduction of additional housing and employment sites the local planning authority has missed an opportunity to incorporate greater flexibility at this early stage of the plan making process.

5. Against the background of the numbered points above we would welcome a further dialogue with the local planning authority prior to "Regulation 19" consultation in order to ensure that the emerging Preferred Site Allocations DPD contains a policy framework which is sufficiently flexible to deliver a mixed use scheme along the lines of that proposed at Section 5 of the Statement of Delivery. That scheme would deliver 134-192 new jobs. That being significantly higher than a scheme of Class B uses only.

6. It is understood that the local planning authority is in the process of updating its evidence base in respect of retail planning matters and we would welcome the opportunity to engage with officers and their appointed consultants regarding the case to underpin further retail floorspace in Ingatestone.

In addition to the above Simons Developments Limited and R P Gaymer propose a further allocation in Ingatestone as per summary discussions with Officers in late 2017. That site is the "Island Site" as identified on the plan attached to Email 3. The site comprises 1.22 hectares of land effectively circled by Roman Road to the west of the A12. It is suggested that the site be allocated for Class B uses.

During our initial discussions with you further information on access and landscape impact was requested and that has now been completed. That analysis concludes that:

1. The site can be safely accessed. See Highways Technical Note prepared by Connect Consultants attached to Email 4.

2. The site can be developed without adverse landscape and visual impact. See Landscape Briefing Note prepared by Aspect Landscape Planning attached to Email 5. That notes that the sites proximity to the A12 and the existing urban edge combined with topography and vegetation provide an opportunity for development with only glimpses views from transient receptors moving along road corridors within the context of the urban edge.

Based on the above there is a clear opportunity for the allocation of further land for employment uses at Ingatestone should the local planning authority remain concerned about the ability to meet its upper requirement.

Whilst we do not consider it essential in order to justify a broader mix of uses on the primary site (land fronting Roman Road) the "Island Site" could sensibly be allocated or safeguarded for employment uses to come forward during the plan period as and when required in response to market demand.

In so far as the primary site is concerned we would welcome the opportunity to agree a draft allocation policy for "Regulation 19" consultation and based on our experience nationwide that would ideally specify the uses identified in the Statement of Delivery or recognise the benefits and acceptability of other employment generating uses subject to compliance with other policies in the plan. The former would clearly provide greater certainty and is in our view appropriate given the deficiency in local food shopping provision particularly.

I trust that the above and attachments on Emails 2, 3, 4, and 5 are of assistance and look forward to discussing further in due course.

If you could confirm safe receipt of these emails that would be appreciated.

Best regards

See attached.