Support is also offered for the strategic objective (SO3) which seeks to sustain active communities through community and social infrastructure. This would accord with Government policy in paragraphs 91 and 92 of the NPPF and Sport England's 'Towards an Active Nation' strategy.

Should any part of the Brentwood Community Hospital site be declared as surplus to the operational healthcare requirements of the NHS in the future, then the site should be considered suitable and available for alternative use, and considered deliverable within the period 5- 10 years. These representations identify the sites potential for future development, in accordance with the realignment of the Green Belt so that this significant area of developed land is no longer included. It is evident, that the site does not make a positive contribution towards the purposes of the Green Belt set out in the NPPF. Accordingly, redevelopment of this site could provide a key contribution to Brentwood's housing need, which the Council have failed to justify, given the reliance on key strategic sites, and the lack of acknowledgement for unmet need arising from neighbouring authorities (Basildon and Havering). These representations therefore promote and identify parts of the Brentwood Community Hospital site as a suitable site to contribute towards these requirements. This site presents an excellent opportunity for a high quality residential redevelopment on previously developed Green Belt land. This could be achieved without compromising the character of the area as the development can act as an infill site to the existing residential development surrounding it, and without the need for significant infrastructure. Furthermore, the site is also available to accommodate further health related development should the CCG seek to expand their services in this location, including the possible expansion of the hospital to provide more comprehensive services for the community. However, the site's Green Belt designation would make it difficult for any planning application proposing additional built form to provide further healthcare services to be considered acceptable. The subject site is considered available, suitable and deliverable within the 5-10 year period of the plan.

These representations seek to comment specifically on Housing Requirements, Housing Allocations, and relevant evidence base documents identified and referred to in the draft Local Plan. In addition to this, these representations will also comment on specific parts of the Spatial Strategy and Strategic Objectives provided in the emerging plan. Housing Requirements This Consultation document outlines that the Council commit to delivering 7,752 new net additional dwellings over the Plan period 2016-2033 using a stepped trajectory that would see 310 dwellings per annum until 2022/2023, following by 584 dwellings per annum from 2023/24-2033. Overall, this represents an average of 456 dwellings per annum over the Plan period. The minimum housing need for Brentwood based on the standardised methodology is 452 dwellings per annum. In addition to the Council's minimum requirement, there are 3,508 dwellings that are unmet in Basildon and 5,650 dwellings that are unmet in Havering. Basildon and Havering both adjoin Brentwood, therefore the Council should consider contributing to their housing needs through outlining and planning for a higher housing target. The Council should also consider the arrival of Crossrail, which is set to unlock further demand for housing in the area. The Council's approach to a stepped trajectory is also not justified, and should look to deliver housing in the short term. Housing Allocations
The Council's Local Plan Consultation document identifies a number of residential allocations on Green Belt land located at the edge of the Brentwood Urban Area. Policy NE13 (Site Allocations in the Green Belt) states that sites allocated within the Green Belt will be expected to provide "significant community benefits", and will be de-allocated from the Green Belt to allow development to take place. This identifies that the release of Green Belt land in these areas is being pursued as part of their Spatial Strategy. Green Belt land is also proposed for release in a number of other settlements in the Borough. Of the Council's allocations, there are four Strategic Housing Allocations. The largest allocation is Dunton Hills Garden Village Strategic Allocation (Policy R01), which is allocated for a residential-led development to deliver around 2,700 homes, with a potential overall capacity of 4,000 beyond 2033. This allocation was also located within the Green Belt. The variable housing target outlined by the Council is substantially reliant on this Garden Village commencing delivery in 2023/24 (within the first five years of the Plan), and delivering at a rate of 100 homes per annum from thereon, reaching 300 homes per annum from 2026. Housing Allocation- Land off Crescent Drive: The land adjoining Brentwood Community Hospital to the east benefits from a draft allocation in the Local Plan consultation document. Although this site has similar characteristics to the Brentwood Community Hospital site, including being a previous NHS site, it is not designated as Green Belt. The allocation on site 186, Land at Crescent Drive, Shenfield, identifies that the 1.54ha site can provide for around 55 dwellings, anticipated to be delivered between 2021/2022 and 2023/2024. It will provide a mix of size and type of homes including affordable in accordance with the Council's policy requirements. This outlines the development potential of the area. Loss of Community Use Policy PC14 (Protecting and Enhancing Community Assets) states that existing community assets will be protected from inappropriate changes of use or redevelopment. Policy PC14 (e), states that development proposals that would result in a loss of community assets will be discouraged unless it can be demonstrated the following; i. There are realistic proposals for re-provision that continue to serve the needs of the neighbourhood and wider community; or ii. the loss is part of a wider public service transformation plan which requires investment in modern, fit for purpose infrastructure and facilities to meet future population needs or to sustain and improve services. To confirm, a property can only be released for disposal or alternative use by NHSPS once Commissioners have confirmed that it is no longer required for the delivery of NHS services. Furthermore, NHSPS estate code requires that any property to be disposed of is first listed on "e-PIMS", the central database of Government Central Civil Estate properties and land, which allows other public sector bodies to consider their use for it. The ability of the NHS to continually review the healthcare estate, optimise the use of land, and deliver health services from modern and fit for purpose facilities is crucial. Given that there is very careful oversight from NHS England and CCGs to ensure sufficient services are re-provided, and that the estate is fit-for-purpose, additional protection through planning policy should be unnecessary in relation to public healthcare facilities. Therefore, if all or part of the site is declared as surplus to the operational healthcare requirements of the NHS by health commissioners, this should be considered sufficient to satisfy Policy PC14 and any subsequent replacement policy. Furthermore, any marketing period (in addition to service re-provision) should not be required. Evidence Base Documents - Since the last consultation on the Brentwood Local Plan, the Council have published a suite of evidence base documents to inform the Regulation 19 Local Plan and to address the Council's main concerns. Evidence base documents of relevance consist of the following; * Green Belt Study (November 2018); and * Infrastructure Delivery Plan. Green Belt Study (2018) - The Council's Green Belt study (February 2018), identifies that around 89% of the Borough is designated as Green Belt; it then splits all the Green Belt in the district into various parcels which are assessed against a number of criteria including the NPPF's five Green Belt purposes. The land at Brentwood Community Hospital is entirely located within Parcel 55: East of Middleton Hall Lane. This Parcel spans over 26.1ha of land which is identified as being wholly / largely contained by large built up areas. In summary, the entire parcel is considered to be well-contained, but is located within a Critical
Countryside Gap (CCG), operates as Functional Countryside (FC), and has a moderate relationship with a Historic Town. The Parcel is therefore identified as performing a moderate - high contribution towards the Green Belt's purposes. The Green Belt Stage 2 Review (February 2018) sub-divided a number of sites assessed in Part 1 for further detailed assessment. Parcel 55 had not been sub-divided in Part 2 for further assessment and thus there was no further assessment of the site against the Green Belt's purposes in this round of assessment. The Council's most recent Green Belt Study (November 2018), assesses the site under Site Assessment 186. To note, only the car parks to the western extent of the site fall within the Green Belt, therefore as such, the assessment only related to 25% of the site. The site was assessed as follows; * The car parks are strongly associated with surrounding buildings, albeit protruding in to the Green Belt. The site is assessed as Partly Contained (PC); * The site is small scale and contained within the town (e.g. infilling). The site is bounded by mature dense woodland to the west. Whilst development would mass housing on the site, there would be no appreciable reduction in the gap. The site is assessed as Separation Retained (SR); * The area of the site located within the Green Belt is car parks and woodland areas so therefore is assessed as being Mixed Functions within Countryside (MFC); * The site is assessed as having a limited relationship with the historic town (LRHT). Overall, the site was assessed as having low-moderate contribution to the Green Belt. The site was considered as a "partly developed site" due to the hardstanding car parks and was associated with the settlement boundary to the east. Infrastructure Delivery Plan - The Council's Infrastructure Delivery Plan (IDP) provides a schedule of infrastructure requirements to help support new development growth planned within the Brentwood Local Plan. Paragraph 10.6 outlines that Brentwood has a slightly higher proportion of over 65s compared to Essex county as a whole, although a 17% increase is expected between 2015 and 2025 equating to 2,600 more people. Given the foregoing, there is a clear need for a higher proportion of homes which are capable of accommodating people's changing needs. Paragraph 10.19 of the IDP also states that hospitals will need to be redesigned to treat the patients of the future. The site could be suitable for housing for older people as it is located in a sustainable location close to services, facilities and to transport links. The IDP also highlights that there is an ongoing programme to improve the utilisation of Brentwood Community Hospital, to reduce the void costs associated with the building and to make better use of the opportunity for providing a range of health and care services. Strategic Objectives - This sub-section provides a review of the Spatial Strategy, and the Strategic Objectives and how they are of relevance to the subject site. Chapter 2 (Borough of Villages), Figure 2.3 sets out the borough's settlement hierarchy categories, to identify their role for delivering sustainable growth. Figure 2.3 outlines Brentwood as a "large town", alongside Shenfield with 4 urban neighbourhoods, 2 large villages, 1 garden village, 6 rural villages, and 7 rural villages in sparse settings. Paragraph 2.11 of the Consultation document outlines that Brentwood is the borough's largest settlement and offers the most scope to develop in, in accordance with sustainable development objectives as set out in the NPPF. Chapter 3 of the consultation document outlines the Borough's Spatial Strategy and Strategic Objectives. The Council have highlighted four strategic objectives and how the policies align to help deliver these policies. These are the following; * SO1: Manage Growth Sustainably; * SO2: Deliver a Healthy and Resilient Built Environment; * SO3: Deliver Sustainable Communities with Diverse Economic & Social-cultural Opportunities for All; and * SO4: Deliver Beautiful, Biodiverse, Clean and a Functional Natural Environment. The subsequent chapters outline the policies that sit within each strategic objective. These representations specifically comment on both: Managing Sustainable Growth (SO1) and Sustainable Communities (SO3). SO1: Managing Sustainable Growth - The Council aim to direct development to the most sustainable locations, ensuring that the characteristics and patterns of the settlements are protected and enhanced. The redevelopment of the site would aid the Council in delivering most of these objectives and policies. Although currently designated as Green Belt, the brownfield nature of the site and its location within the existing built up area of Brentwood means it can significantly aid in intensification. The site is also easily accessible by existing public transport modes as outlined in the 'site context' section of these representations. The site is highly sustainable and helps contribute towards delivering the Strategic Objectives including having no unacceptable effect on visual amenity; having no unacceptable impact on health; and causes no unacceptable effects on adjoining sites. The intensification of this site would also increase the critical mass of customers/users of existing services and facilities. This can help to ensure the viability of existing services and amenities in the local area. The site could also be optimised for retention in its current use with the provision of additional built form to provide additional health services or an extension to the current facilities. SO3: Sustainable Communities - The Council aim to highlight opportunities which flexibly respond to the changing economic climate and employment sector trends making citizens feel economically empowered to enjoy and benefit from the necessary community/social infrastructure that sustains inclusive, informed, vibrant, active and cohesive communities. The potential for the provision of residential development at the site would help the Council to meet their identified and growing need for housing over the plan period. The sustainable location of the site in relation to the existing built form and settlement of Brentwood means that should the site ever become surplus to the requirements of the NHS, it would be a great location for residential development. The site is adjoined to the settlement, so therefore can help contribute towards creating a cohesive community. Furthermore, as outlined above, the site is also capable of accommodating further healthcare-related development, including the possible expansion of the hospital to provide better and more comprehensive services for the local community. The site is located in a sustainable location and is easily accessible by public transport, cycling and walking and could therefore make a good location for the expansion of the existing healthcare facilities should this be required by the CCG in the near future. Chapter 3 also outlines the Council's spatial development principles, stating that development proposals in the borough will follow the following principles; 1. Urban Areas- Prioritise brownfield sites, making efficient use of land; 2. Brownfield Green Belt Land- Use of previously developed land in the Green Belt; 3. Strategic Sites- Use opportunities created by larger housing development; 4. Urban Extensions- deliver new homes in areas close to existing transport and local facilities; and 5. Windfall- an allowance for small scale development that will come forward in the future. The site is Brownfield Green Belt land (Tier 2) so therefore should be favoured for development over strategic sites and urban extensions. The Role and Extent of the Green Belt Policy NE9: Green Belt sets out that the Green Belt will continue to be preserved from inappropriate development so that "it continues to maintain its openness and serve its key functions". The redevelopment of this site would only seek for the removal of a small element of existing Green Belt land which is currently a mix of hardstanding car parking and woodland. This removal would enable efficient and maximum redevelopment of a brownfield site, without contradicting the purposes of the Green Belt. The NPPF states that Green Belt boundaries should only be amended in "exceptional circumstances". The Housing White Paper seeks to clarify this further and states that land which has been previously developed should be considered first. Accordingly, it is sites such as Brentwood Community Hospital which should be removed from the Green Belt. This is further outlined below, which highlights the sites suitability. a. Site Suitability The site is located adjoining the existing settlement and residential area of Shenfield, and a proportion of the site within the Green Belt is currently an existing hardstanding forming a car parking area. The site is located in close proximity to public transport connections which provides links to a variety of everyday services and amenities. As previously identified, the site is currently partially located (25% of the site) within the Green Belt. However, due to the existing built form within and surrounding the site, and as evidenced in the Green Belt Study, the site provides little or no contribution towards the purposes of the Green Belt. The Council undertook a Green Belt Study (November, 2018) which assessed various parcels of Green Belt land within the district. The site fell within Site Assessment 186, which concluded as having low-moderate contribution to the Green Belt. Although considered as having a low-moderate contribution to the Green Belt, a Green Belt assessment is provided below to outline the development potential of the land at Brentwood Community Hospital. The assessment is based on the Green Belt purposes identified in the NPPF. This assessment is to enable the Council to determine the importance of the site in Green Belt terms, and to demonstrate that the site does not meet the five purposes of the Green Belt, so therefore should be removed. 1. to check the unrestricted sprawl of large built-up areas - The site is bounded on three sides by the existing built form of Brentwood. The surrounding built form includes residential dwellings to the north and west, and a draft residential allocation to the east. - The built up area would not spread further than the site's boundary due to the presence of a significant area of woodland adjacent. 2. to prevent neighbouring towns merging into one another - The site falls between the settlements of Shenfield and Brentwood. Although the site falls between these two settlements, the built form of Shenfield and Brentwood already links through the existing built form on Shenfield Road and it is not this site that forms any gap rather the playing fields adjacent. - The site's built form also limits its purposes in restricting the two settlements from merging as it is clear that it is an existing built up area. 3. to assist in safeguarding the countryside from encroachment - The site is bounded to the north, east, and west by the existing built form of Brentwood. - The site is bounded to the south by existing woodland. - Due to the site not being located in the countryside, its contribution toward this aim is limited. 4. to preserve the setting and special character of historic towns - The site is not located within a historic town.5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land - The site is located within an existing settlement and promotes the intensification of an existing community facility which already has its own facilities, amenities, and day-to-day services, or, the site could equally be redeveloped for the provision of residential dwellings should the land become surplus to the NHS's requirements. b. Sustainability The golden thread running through the NPPF is a presumption in favour of sustainable development. This means that developments which accord with the Local Plan should be approved without delay. The three pillars of sustainability within the NPPF are identified as Social, Environmental, and Economic; the definitions of these terms and the ways the proposals at Brentwood Community Hospital conform to these pillars are identified below. Social The NPPF defines socially sustainable development as those which contribute toward supporting a strong, vibrant and healthy community by providing the supply of housing required to meet the needs of present and future generations, through a high quality built environment with accessible services and support of health, social and cultural wellbeing. The redevelopment of Brentwood Community Hospital would accord with the social pillar of sustainable development through the provision of an increased number of residential dwellings on a sustainably located site in order to help meet the Council's identified and growing need for housing. Should the Council fail to meet their identified housing target, there could be serious social instability caused including overcrowding of existing housing stock and undersupply of housing. In addition to this, the site could represent the opportunity for the delivery of affordable housing towards the Council's identified need, representing a further opportunity to deliver a socially sustainable development. Environmental The NPPF defines environmentally sustainable development as development which contributes to protecting and enhancing the natural, built and historic environment through improving biodiversity, using natural resources prudently, and minimising waste and pollution. A scheme at Brentwood Community Hospital could provide sustainably located residential dwellings within walking distance of existing services and amenities, reducing the need for future residents to travel long distances and reducing pollution and the use of finite resources. Alternatively, should the CCG seek to expand their existing facilities on site, the intensification of the existing healthcare services could help to ensure the healthcare facilities continue to be provided in a sustainable location. Economic The NPPF defines economically sustainable development as development which contributes toward building a strong, responsive, and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation. A residential scheme at Brentwood Community Hospital would accord with this pillar through the introduction of an increased number of residents into an existing urban area. These new residents will help to secure the economic viability and vitality of the existing local businesses and services through an increased customer base. The redevelopment of the site would also ensure that a higher provision of land is available for a land use which is identified as being highly demanded at this point in time ensuring that a sufficient supply of land is available in a sustainably located site.

Brentwood Pre-Submission Local Plan (Regulation 19) Ingatestone - Land adjacent to A12 slip road - Policy E08. Representations on behalf of Simons Developments Limited and RP Gaymer. I refer to the above and set out below further comments on the emerging land allocation policy (E08). These comments should be read in the context of our representations at the Regulation 18 consultation stages in respect of the Draft Local Plan in March 2016 and the Preferred Site Allocations in March 2018. In order to assist discussions with the local planning authority a detailed Statement of Delivery was prepared and submitted in December 2016 which provided supporting analysis on highways, flood risk and drainage, noise, ecology, landscape and visual impact; and heritage. The purpose of the statement was demonstrate that there was no technical constraint that would prevent the site from coming forward for development. Moreover, Simons Developments Limited (SDL) have an option to purchase the site from R P Gaymer and have actively promoted its redevelopment since early 2016. Not only have SDL engaged in the local plan preparation process they have also sought advice on occupier demand from Bidwell (Commercial Agents) and that advice has been shared with the local planning authority at a series of meeting for the purpose of informing the evolution of the draft land allocation policy for this site. Importantly, Bidwells have highlighted that market interest in the site is evident across a range of sectors beyond traditional B class employment uses all of which will nevertheless generate a significant number of new jobs. Against the background of the above, SDL fully support the proposed removal of the site from the Green Belt and its allocation by Policy E08 as "2.06 ha of employment land (principally use classes B1, B2, B8 and any associated employment generating sui generis uses)" alongside recognition in the reasoned justification at paragraph 9.226 that "the primary purpose of the allocation is to deliver jobs for the area and so consideration will be given to other uses that enable job opportunities, taking account of market needs". The flexibility provided for in paragraph 9.226 is consistent with the fact that the emerging Plan recognises the importance of providing a wide range of employment opportunities. Strategic Objective SO3 - Deliver sustainable communities with diverse economic and social cultural opportunities for all - identifies the need for "opportunities which flexibly respond to the changing economic climate and employment sector trends". Moreover, Policy PC01 - Cultivating a strong and competitive economy - acknowledges the need to "improve access to a range of employment opportunities for the borough's residents". The flexibility is also consistent with Bidwells assessment of market demand for the site which spans a range of sectors and uses beyond traditional B class employment uses. Accordingly, the broad intent of Policy E08 is consistent with the strategic objectives of the emerging Plan. The intended flexibility also recognises that identifying market demand for employment land (in use classes B1, B2, and B8) over the plan period to 2033 is not a precise science. Indeed Chapter 7 of the draft Local Plan - Prosperous Communities - notes a forecast requirement at Figure 7.5 (Employment Land Need) for between 33.76 hectares and 45.96 hectares up to 2033. By comparison the Plan seeks to allocate 47.39 hectares in order to provide a choice of sites in a range of sizes and locations. The point here is that the flexibility for sites to come forward for "other uses that enable job opportunities, taking account of market needs" is balanced by a total employment land allocation in excess of the upper end of the forecast range over the Plan period. Notwithstanding SDL"s support of the broad intent of Policy E08 it is noted that the policy wording has changed from that presented to the Council in November 2018 which is attached to these representations for completeness. The change shifts the flexibility and support for "other uses that enable job opportunities, taking account of market needs" from the wording of the Policy itself to the reasoned justification. The National Planning Practice Guidance is explicit that "the local plan should make it clear what is intended to happen over the life of the plan, where and when this will occur and how it will be delivered" (Reference ID 12-002-20140306). As drafted Policy E08 is not sufficiently clear and the support for flexibility in terms of acceptable uses should therefore be reinstated under the "Development Principles" part of the Policy. Assuming that the flexibility in respect of acceptable land uses is reinstated under the "Development Principles" part of the policy a further useful addition to the drafting would be to make it clear that the other employment generating uses referred to are uses outside of Class B. The suggested drafting for this addition is underlined as follows "other uses *outside of Class B* that enable job opportunities, taking account of market needs". The requested changes are wholly consistent with the statement at paragraph 9.226 that "primary purpose of the policy is to deliver jobs for the local area" and should therefore be acceptable. For the reason set out above SDL do not consider that the Plan passes the test of soundness set out at Paragraph 35 of National Planning Policy Framework because Policy E08 is not "effective" nor is it "consistent with national policy". Paragraph 36 of the Framework notes that the test of soundness "will be applied to non strategic policies (such as Policy E08) in a proportionate way, taking into account the extent to which they are consistent with relevant strategic policies for the area". In this respect the strategic policies of the Plan are clear about the importance of ensuring a range of employment opportunities and that should be clearly reflected in Policy E08. This above is easily rectified by a non material change to the drafting of Policy E08 prior to submission of the Plan for examination. I hope that the above comments are helpful and will be pleased to discuss further with the objective of agreeing revised wording that would allow SDL to withdraw its objection.

These representations have been prepared by Strutt & Parker on behalf of Childerditch Properties for Brentwood Borough Council's (BBC) Regulation 19 Pre-Submission Consultation Local Plan (PSLP) and in particular, with regards to our client's land interest on the proposed allocation Childerditch Industrial Estate. Childerditch Properties request the right for Strutt & Parker or any other professional advisor acting on their behalf to provide further responses in Hearing Statements or at the relevant sessions of the Examination in Public following the submission of the PSLP. Childerditch Properties are the sole owners of Childerditch Industrial Estate. Representations have previously been made on their behalf in respect of the site throughout the Plan making process, including at the Call for Sites stage, as part of the 2013 Preferred Options Consultation and, most recently, as part of the 2018 Draft Local Plan Regulation 18 Consultation. At present, the Estate provides some 35 units and between 700 and 800 people are employed here. All of these units are occupied and our clients continue to receive enquiries for occupation. The Estate therefore currently plays an important role in providing a significant source of the Borough's employment land and the provision of jobs. The proposed allocations provided for in the PSLP would build on the success of the Estate by creating new employment land. Located two miles from Brentwood on the A127, the Estate is ideally placed to offer future employment opportunities in a highly sustainable location with excellent transport links. Childerditch Industrial Estate is an 'island' site within the surrounding countryside, comprising a range of B1, B2 and B8 employment uses and storage yards. The proposed allocation at Childerditch Industrial Estate is referred within Policy E12 of the PSLP. The proposed allocation of additional employment land, in combination with the existing Park, will provide a developable area of approximately 20.6 hectares of employment land. Accompanying these representations is a proposed masterplan prepared by CMP Architects which, whilst indicative at this stage, demonstrates how the Estate can be more efficiently and effectively developed. This document is copied to these representations at Appendix 1. An updated Access Appraisal prepared by Journey Transport Planning is also submitted with these representations and is copied at Appendix 2. Within this document, consideration is given to the existing Estate and proposed allocations, and the cumulative traffic impacts arising from other developments in the A127 corridor. The Appraisal also considers the access from Childerditch Hall Drive onto the A127, to confirm that the proposed allocation of the site is deliverable in the context of the existing and proposed allocations referred to above. Childerditch Industrial Estate is located just to the north of the A127, approximately halfway between Junction 29 of the M25 to the west, and the junction of the A127 and A128 to the east. Other sites proposed for allocation within the PSLP also found along this section of the A127 include Brentwood Enterprise Park (Policy E11) and Land at Codham Hall Farm (Policy E10), which are located to the south and north of the A127 respectively. Given the stage of the PSLP, these representations focus on the soundness of the Plan, in accordance with paragraph 35 of the National Planning Policy Framework (NPPF). Paragraph 35 confirms that Plans are sound if they are positively prepared, justified, effective, and consistent with national policy. The PSLP is supported by an evidence base that includes a number of technical studies. These representations give regard to both the Pre-Submission Document and these studies. The following section of these representations provide comment on draft policies, with particular regard to Policy E12, and other supporting text relevant to the proposed allocation at Childerditch Industrial Estate. Our client's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations. Where concerns are raised in respect of PSLP or its evidence base, specific changes will be noted to assist Brentwood Borough Council in ensuring that the Plan is sound. Regulation 19 Consultation Pre-Submission Document Section 3: Spatial Strategy - Vision and Strategic Objectives: The PSLP sets out the overarching aims of the Spatial Strategy, which includes an emphasis on 'Transit-orientated Growth'. This identifies two key transit corridors, including the 'Southern Brentwood Growth Corridor'. The PSLP focuses growth on land within the Borough's transport corridors, with strategic allocations along the A127 corridor for employment, which is justified given the aims and objectives of the Plan. The Council's strategy to direct development growth to the Borough's transport corridors is supported and has potential to provide for employment growth in locations where there is strong market demand, and to minimise environmental impacts on the wider Borough. The proposed allocation at Childerditch Industrial Estate will assist in meeting this objective, by bringing forward new business and employment opportunities along the A127 corridor. It will help support the planned residential growth within Borough. The Plan has been positively prepared in this respect. The Strategic Objectives identified within Section 3 of the PSLP are supported. Economic prosperity forms a key part of the objectives. In order to be considered sound, it is important the Plan is consistent with national policy, which seeks to enable the delivery of sustainable development. Strategic Objective SO1 seeks to direct development to the most sustainable locations and this links to the proposed allocation at Childerditch Industrial Estate. Strategic Objective SO3 supports opportunities that respond to the changing economic climate. Childerditch Industrial Estate is a traditional industrial estate that has developed over many years, as illustrated in the indicative proposed masterplan prepared by CMP Architects. It provides a mixture of B1, B2 and B8 uses across the site. The Estate will offer opportunities for a range of businesses seeking new premises within a highly sustainable location, which the A127 corridor offers through the proposed allocations. The indicative proposed masterplan sets out how the proposed allocation would allow for the redevelopment of the Estate and how this could come forward through a series of phased developments. This will be able to offer a number of units of varying sizes that would be suitable to a range of businesses, responding to the economic climate. The work undertaken by CMP Architects demonstrates how the Estate can be more efficiently and effectively developed, by providing a modern range of units for B1, B2 and B8 uses and associated infrastructure. Figure 3.1: Key Diagram: Figure 3.1 provides a visual aid in support of the Spatial Strategy. It identifies Junction 29 of the M25 as a key location for 'Employment-led development' (Brentwood Enterprise Park) and Childerditch Industrial Estate as a location for new 'Employment land', in addition to the strategic housing-led development at Dunton Hills and the redevelopment of West Horndon. A focus on employment growth along the A127 corridor will reduce the need for additional employment sites in less sustainable locations elsewhere in the Borough. This approach is fully supported and recognizes the importance of this location for new employment opportunities. This approach is justified and demonstrates that the Plan is consistent with national policy in this respect. Section 5: Resilient Built Environment: Policy BE11: Strategic Transport Infrastructure: We support part C of Policy BE11, which states that the Council will continue to work with the Highway Authority, statutory bodies and key stakeholders to deliver improvements to the ensure highway infrastructure capacity is maintained. Any future planning applications to be submitted in respect of new development at Childerditch Industrial Estate will be accompanied by the relevant transport studies. Paragraph 5.105: Paragraph 5.105 states that, within the South Brentwood Growth Corridor, there is a recognition that provision of sustainable transport in this area is poor. Since the Draft Local Plan Regulation 18 Consultation, the Council has published an Infrastructure Delivery Plan (IDP) for the Borough. This includes, at Figure 3.14 of Chapter 3, a sustainable transport plan for the Southern Growth Corridor, which includes indicative locations for new cycle ways and a new bus route to connect Childerditch Industrial Estate, Brentwood Enterprise Park, Dunton Hills Garden Village and West Horndon Industrial Estate (to be redeveloped). We support the principle of improving walking and cycling links within the land owned by our client, which extends to Little Warley Hall Lane. However, we would question the extent to which these new cycle ways could be delivered along the A127 corridor, as this would require every land owner to be committed to this initiative and an identification of funding. It is also not clear within the IDP who would be responsible for delivering this infrastructure improvement i.e. would this be the responsibility of Essex County Council, Brentwood Borough Council or landowners. This point needs to be clarified. In respect of the new bus route loop that is shown within the IDP at Childerditch Industrial Estate, whilst our client broadly supports the principle of a bus service at the Estate, they consider that the circulatory route shown within the IDP is too prescriptive and misleading, and at this stage, a broad arrow would be sufficient within the IDP. Details of how the Estate could be served can be dealt with as part of the iterative masterplan process. If a bus service from the A127 were to drop off/pick up were to be brought forward, our client could support this if the bus were to stop outside the Estate, turn and move back down Childerditch Hall Drive. Section 7: Prosperous Communities: This section of the PSLP confirms Brentwood Borough Council's Economic Strategy, which includes a number of Economic Aims and Strategic Priorities. These will help facilitate sustainable development, which is required to ensure that the Plan is sound. Paragraph 7.1 of the Plan recognises the importance of the Borough as being a high-quality environment within close proximity to London. The economic aims include the desire to encourage high value, diverse, employment uses that will provide a significant number of skilled and high-quality jobs; and to encourage the better utilisation, upgrading and redevelopment of existing land and buildings. These aims are supported and are reflected in the indicative proposed masterplan accompanying these representations. Childerditch Industrial Estate has a unique employment offer, insofar as it comprises a range of B1, B2 and B8 employment uses and storage yards. The proposed allocation provides the opportunity to build on the success of the Estate, by creating additional employment opportunities with a range of businesses. The proposed allocations will also enable the upgrading of the existing units on site through increased investment. The accompanying indicative proposed masterplan prepared by CMP Architects sets out how the redevelopment of the Estate could come forward through a series of phased developments. The development of The Range North (previously identified as site 112D in the Regulation 18 Consultation) as a first phase will assist with the provision of funding to begin the process of upgrading the existing units and infrastructure at the Estate, and provide for the ability for reinvestment to develop the proposed southern extension (previously identified as site 112E in the Regulation 18 Consultation). This redevelopment would ensure compliance with the Economic Aims of the PSLP. In addition to the Economic Aims, the PSLP sets out a number of Strategic Priorities. Of these, Strategic Policies P1 and P6 are strongly supported. P1 seeks to support business development and growth. P6 seeks to promote Brentwood Borough as a place to visit and invest, thereby encouraging the visitor economy. Childerditch Industrial Estate would assist in meeting those objectives. Policy PC02: Job Growth and Employment Land In determining the employment land allocations necessary to ensure that an adequate number of jobs can be provided, it is important that the Plan is sufficiently flexible to adapt to rapid change (as required by Paragraph 11 of the NPPF), and that it does so in a manner that ensures that the boundary of the Green Belt will not need to be reviewed before the end of the Plan period (Paragraph 136 of the NPPF refers). As set out within Paragraph 2.54 of the PSLP, 89% of the Borough lies within the Metropolitan Green Belt. There is not sufficient land outside of the Green Belt for the Council to deliver the requisite level of housing and employment land. It is therefore necessary and justified to amend the boundary of the Green Belt as part of the Local Plan process. Paragraph 8.84 of the PSLP refers to the need to release land from the Green Belt in order to achieve the Council's growth strategy. This release has been carefully balanced to ensure that sustainable development can be achieved, whilst ensuring that the longer-term purpose, integrity and benefit of the Green Belt remains intact. We support the Council's approach insofar as our client's land interests are concerned and it is important to ensure that any changes to the Green Belt endure beyond the Plan period, having regard to its intended permanence, as required by Paragraph 136 of the NPPF. The PSLP is informed by an evidence base, including an assessment of the Functional Economic Market Area (FEMA) and the Brentwood Economic Futures 2013-2033 Report. The PSLP suggests a range of growth within the Borough, where at Paragraph 7.19(iv), it is stated that a range from 33.76 hectares to 45.96 hectares will be required. This includes land lost at existing allocations (i.e. at West Horndon). Childerditch Industrial Estate will therefore make a significant and important contribution towards the required land. It is well suited for businesses that may need to relocate as a result of sites that will come out of employment use to provide for housing. It is therefore considered the approach to Policy PC02 is justified in providing for 47.39 hectares of new employment land in excess of the higher forecasts; offering support for existing employment sites and the appropriate redevelopment of sites, to be able to adapt to rapid change and to remove the need for the Green Belt to be reviewed during the Plan period. The PSLP sets out the proposed allocation at Childerditch Industrial Estate can come forward over the next 1 to 10 years. The indicative proposed masterplan prepared by CMP Architects provides an illustrative approach as to how the proposed allocation could come forward in conjunction with the redevelopment of the existing Park. The land is available now and there are no overriding constraints to delivery. The Plan would be justified and effective in this respect. The Brentwood Economic Futures (2013-2033) Final Report sets out 4 scenarios for quantifying the potential requirement for jobs in order to support the growth of the Plan Period. The Report provides indicative job capacity figures, which have been based on assumptions, in terms of both site capacity and B1a/b, B1c/B2, and B8 split. (Refer to table in attached copy of full representation). In respect of Childerditch Industrial Estate however, the Report has not taken into account that the existing Park can be redeveloped in a more efficient and effective manner to provide more job growth, as provided for in these representations. Overall, the proposed allocation will enable the upgrading of the existing units on the site through increased investment. Policy PC03: Employment Land Allocations: Policy PC03 sets out a number of considerations that are intended to relate to existing and proposed employment sites identified in Figure 7.6 of the PSLP. This includes Childerditch Industrial Estate. However, the PSLP also includes a specific policy that relates to Childerditch Industrial Estate (Policy E12, which will be addressed later in these representations). Paragraph 7.23 of the PSLP states that due to the difficulties of accommodating the quantum of employment land within other parts of the Borough, the opportunity has been taken to capitalise on the strategic connections of the South Brentwood Growth Corridor by extending employment land around Childerditch Industrial Estate. This approach is considered to be justified and consistent with national policy, as the proposed allocation seeks to make efficient use of an existing, highly sustainable employment site. Proposed Modification: It is considered that greater clarification should be added to Paragraph 7.23, Part b. ii. on where Policy PC03 applies, as Policy E12 covers the entirety of Childerditch Industrial Estate. It should be added that the proposed allocation at Childerditch Industrial Estate allows for the redevelopment of the existing Estate and new development on the extended areas, which will provide a location for employment generating sui generis uses, as provided for by Policy E12. Policy PC05: Employment Development Criteria: Policy PC05 does not specify whether it applies to existing and/or new employment land. The policy simply refers to development for employment uses. The wording of Policy PC05 is therefore ambiguous and is more restrictive than the site specific policy for Childerditch Industrial Estate (Policy E12). For example, Policy E12 requires provision to be made for improved walking and cycling links within the surrounding area. Policy PC05 on the other hand states that employment uses will be encouraged provided that the proposal is accessible by public transport. At present, there are no public transport connections directly available to Childerditch Industrial Estate, and whilst this may change in the future, there is no guarantee of if and when this will happen. On this basis, we object to Policy PC05 in its current form as it would not allow for an effective Plan. Proposed Modification to Policy PC05: It is suggested that Policy PC05, Part A. a. be amended to state that proposals provide opportunities to be accessible by public transport, walking and cycling. At Childerditch Industrial Estate, opportunities are limited to provide public transport; however, in bringing forward proposals for the site, this issue can be reviewed with Brentwood Borough Council and Essex County Council. Section 8: Natural Environment Policy NE9: Green Belt: Policy NE9 is supported. The Council has recognised the need to release some land from the Green Belt in order to meet its housing and employment needs. However, the land that will remain within the Green Belt should be protected throughout the Plan period and Policy NE9 achieves this, in accordance with the NPPF. Policy NE13: Site Allocations in the Green Belt: It is considered that Policy NE13 should be removed from the PSLP. The criteria of the policy can be included other policies, such as the site specific policy for Childerditch Industrial Estate (Policy E12), and it is therefore not considered necessary to have a standalone policy duplicating these points. Furthermore, it is queried why the policy refers to the benefits of housing sites only and no other land uses. Section 9: Site Allocations Policy E12: Childerditch Industrial Estate: Policy E12 is supported. We consider that it is justified, effective, consistent with national policy and necessary for the reasons set out elsewhere in these representations. Policy E12 proposes to allocate land that has previously been promoted at the Range North (site 112D) and the land to the south (site 112E), in addition to the existing Childerditch Industrial Estate, to provide a total developable area of 20.64 hectares across the entire Estate. The release of these sites from the Green Belt is justified and will ensure that the Plan has been positively prepared. At present, Childerditch Industrial Estate offers some 35 units. As part of the work supporting these representations, CMP Architects have undertaken an analysis of the Estate to identify how the existing Park could be regenerated for existing occupiers, redeveloped in areas to maximise efficiency, and expanded for future employment growth demand. The proposed masterplan at Appendix 1 provided for indicative purposes to support these representations, demonstrates the deliverability of the site over a period of time. The proposed allocations will extend the size of the Estate and as a whole, it is considered that it has the potential to accommodate around 50 units following redevelopment. The development of The Range North (site 112D) as a first phase will assist with the provision of funding to begin the process of upgrading the existing units and infrastructure at the Estate, which will ultimately lead to the development of the southern extension. This infrastructure will include an improved primary route through the core of the site and a number of secondary routes stemming from this to provide access to the different areas of the site. In addition to the work undertaken by CMP Architects, an Access Appraisal is submitted with these representations. The Appraisal at Appendix 2 confirms that the proposed allocation is deliverable in the context of the existing and proposed highway infrastructure, and will not have a significant impact on the efficiency or safety of the local transport network. The Appraisal also confirms that cumulatively, the allocation can be accommodated with other employment allocations along the A127 corridor, including those at Brentwood Enterprise Park and Codham Hall Farm. The PSLP, at Appendix 2, confirms a delivery forecast of 1 to 10 years. Following the adoption of the Local Plan and confirmation that the proposed allocations at Childerditch Industrial Estate are removed from the Green Belt, a planning application supported by a package of technical information will be submitted to Brentwood Borough Council for the first phase of development at The Range North. Further applications will then follow for the subsequent phases. It is very much expected that development will commence on site within the first few years of the Plan period, given the known demand as referred to at Paragraph 1.4 of these representations. We are in agreement that the entirety of the proposed allocations will be delivered within the 10 year period, which will ensure that the Plan is effective. Our clients purchased the site in 1983 and have a long term investment in the site and a desire to deliver the proposed allocations and enhancements to the existing site, as shown in the indicative proposed masterplan. In respect of Part B, criterion b) of Policy E12, we support the principle of improving walking and cycling links within the land owned by our client, which extends to Little Warley Hall Lane. However, we object to Part B, criterion c) of Policy E12, as it is not considered to be necessary. The Access Appraisal copied at Appendix 2 does not identify a need to improve the junction where the A127 meets Childerditch Hall Drive. The Access Appraisal confirms that the additional traffic created by the proposed allocation will not have an impact on the A127 junction because due to the length of the access from the A127, vehicles will not be delayed on entry. On exit from Childerditch Hall Drive onto the A127, any queuing will be held on site and therefore the increase in vehicles will not have an impact on the A127. Proposed Amendment to Policy E12: In light of the comments set out in the above paragraph, Part B, criterion b) should be removed from Policy E12. Sustainability Appraisal: A Sustainability Appraisal (SA), published in January 2019, has been produced by AECOM on behalf of Brentwood Borough Council in support of the PSLP. The SA forms only one part of the evidence base underlining the PSLP. The evidence base also includes documents such as the Brentwood Economic Futures 2013-2033 Report, Green Belt Study and Transport Assessment. In allocating additional land at Childerditch Industrial Estate, Brentwood Borough Council has taken a balanced judgement on the site constraints and the need to provide to create additional employment opportunities within the Borough. The SA is currently focused on a spatial approach to the assessment of each criterion, using the distance between the site and various factors to judge the extent to which it either achieves certain objectives or not. However, it is considered that the SA fails to fully consider the nature of each proposal or the likelihood in practice of effects in sustainability terms, where a 'broad brush' approach has instead been taken to sites regardless of their intended use. For example, in respect of distance to a GP Practice, the proposed employment allocations at Childerditch Industrial Estate have been scored in the same manner as a residential allocation. However, it is considered to be less important for an employment site to be located within close proximity to a GP practice than a residential site, given the nature of the uses. Therefore, Childerditch Industrial Estate should be considered against a different set of criteria more relevant to the proposed employment allocation. Provided below is an extract from the SA showing the scoring for the proposed allocations at Childerditch Industrial Estate. The proposed allocation includes Sites 112A, 112D and 112E. Site 112A relates to the existing allocation at the Estate. Site 112D relates to the proposed allocation at The Range North, and site 112E relates to the proposed southern extension allocation. (Refer to table in attached representation). On review of the appraisal of Childerditch Industrial Estate, the site has not scored particularly well in relation to the criteria that has data available. However, it is considered that the SA, or at least the sustainability criteria, could be too sensitive when it comes to assessing sites against the criteria. The fact that no site performed 'particularly well' against any of the criteria suggests that the scope of the assessment makes many sites appear unsustainable, with limited opportunity to score 'green' in many of the objectives. The NPPF, at paragraph 81, states that the Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Paragraph 16 of the NPPF states that Local Plans must be prepared with the objective of contributing to the achievement of sustainable development. Paragraph 17 further adds that Local Plans should include strategic policies to deliver the homes and jobs needed in the area. Childerditch Industrial Estate is within a highly sustainable location, with excellent transport links in the form of the A127 and M25, which is a significant benefit to the occupiers of the site. The Estate is a successful employment site and the PSLP process provides a pragmatic response to the opportunity to build upon this success with further land being allocated. Indeed, as outlined above, the Council's own Spatial Strategy includes an emphasis on 'Transit-orientated Growth', which provides for new development along two key transit corridors in the Borough, including the Southern Brentwood Growth Corridor. It is noted that sites 112A, 112D and 112E are presently scored 'amber' (performs poorly) under the Green Belt criterion. We do not consider that this aspect has been considered in sufficient detail by the SA given the particular circumstances of the site and existing uses. Childerditch Industrial Estate is visually contained by the surrounding agricultural land. We note that within the Green Belt Study Part II: Green Belt Parcel Definition and Review Document updated in November 2018, Green Belt Parcel 20, which the Childerditch Industrial Estate is excluded from, has been scored as making a moderate contribution to Green Belt purposes. As the existing site (112A) is excluded from the Green Belt, it is considered that this site should instead be considered to have 'no issue' in the SA assessment. There would be no loss of Green Belt land that would otherwise meet established purposes. The Green Belt Study recognises that the primary land use within the Parcel is arable farmland, but that the secondary land use is an industrial estate (Childerditch) set within the Parcel. The Estate is an 'island site' excluded from this Green Belt Parcel. The Study considers that views across the Parcel are limited, where field boundaries with dense hedgerows reduce visibility. Whilst the Study considers that undulating fields facilitate some views from the north, it is considered that views of Childerditch Industrial Estate will be limited from the north. The northern portion of the site is constrained by its topography, with some significant level changes and mature landscaping screening the existing buildings within the Estate. The northern most section of the Estate is only used as open storage and is also screened by existing woodland. These areas of the Estate form part of the existing allocation in any instance. The work undertaken by CMP Architects has given consideration to wider views of the Estate. The proposed allocations at sites 112D and 112E are currently located within the Green Belt. However, as part of the Council's review of the Local Plan, the opportunity exists to review Green Belt boundaries, in accordance with paragraphs 138 and 139 of the NPPF. At paragraph 138 of the NPPF for example, it states that, when drawing up or reviewing Green Belt boundaries, local planning authorities should take account of the need to promote sustainable patterns of development. As part of the new Local Plan, the fringes of the existing Childerditch Industrial Estate can be released to provide a necessary and important contribution to employment land within the Borough within a highly sustainable location. Furthermore, it is considered that the areas proposed for allocation, adjacent to an existing employment site, are sequentially more appropriate than other sites in the Borough that currently have no employment use. This supports the Council's growth strategy, which requires land to be released from the Green Belt, and is therefore justified. The release of land has therefore been carefully considered taking all factors into account, to ensure that sustainable development can be achieved, whilst ensuring that the longer-term purpose, integrity and benefit of the Green Belt remains intact. The Childerditch Industrial Estate sites have additionally been scored 'amber' with regard to effect on agricultural land, with the methodology stating that any site in land classified as Grade 3 will be 'amber' and Grade 2 will be 'red'. While the assessment notes that the dataset used is of poor resolution, the assessment has failed to adequately consider the existing nature of the sites (with particular regard to site 112D), as well as differentiate between Grades 3a and 3b. We would consider that the criteria should be amended to be more in line with the aims of Government policy, and that the sites be assessed on the basis of whether their use for employment purposes would lead to the loss of the best of the best and most versatile land. Furthermore, if the locally defined employment requirement is to be met, building on agricultural land is necessary. The fact that no site performed 'particularly well' (scoring 'dark green') in any of the criteria, also suggests that the scope of the assessment was not sensitive to acknowledge the competing objectives of national and local policy, particularly that in the Green Belt, to meet needs for employment and other development. Ultimately, it is important to note that the SA, at paragraph 9.6.6 states that "... there is a strategic opportunity to develop the A127 corridor as an employment growth corridor, capitalising on connections to key economic centres in the region (including Tilbury Port, Southend Airport and those in Greater London). All sites will have good or excellent access onto the strategic highway network". Furthermore, at paragraph 9.6.7, it is stated that "... With regards to site specific policy, the policies for the four employment should support timely and effective delivery". We support this view and will continue to take a proactive approach regarding promotion of and extension to Childerditch Industrial Estate through to the adoption of the new Local Plan, including attending the relevant Hearing Sessions at the Examination in Public. Summary: The PSLP confirms that the Spatial Strategy substantially focuses on 'Transit-orientated growth', including the Southern Brentwood Growth Corridor, with strategic allocations along the A127 corridor for employment, which is supported. The proposed allocation at Childerditch Industrial Estate is a recognition of the role that the Estate has in providing employment for the Borough. The proposed allocation would assist in meeting Brentwood Borough Council's identified need, to provide employment land required to assist meeting the Strategic Objectives of the PSLP Plan for the Plan period. The Estate is ideally located along the A127 to provide excellent transport links for the businesses operating at the Estate, and this is reflected in the full occupation rate of the existing units. There is a strong market for additional units in this location. The proposed allocations at The Range North and the southern extension will provide additional land to build on the success of the existing Estate. This submission demonstrates how the Estate can be more efficiently and effectively developed, by providing a modern range of units for B1, B2 and B8 uses and associated infrastructure. In conclusion, we strongly support the proposed allocation at Childerditch Industrial Estate, as set out in the PSLP, and will continue to promote the Estate as the Plan progresses to Examination in Public, in consultation with Brentwood Borough Council and key stakeholders. We consider that the Plan is generally sound; however, we do object to two policies in their current form. These are Policies PC05 and E12, as set out at paragraphs 2.23 - 2.25 and 2.34 - 2.35 of these representations. However, within these representations, we have also set out suggested amendments to these policies that we consider would make the plan sound.