Amend Policy R04 and R05 B. c. as follows -

provide well-connected internal road layouts which allow for good accessibility including for passenger transport;

3. Effective.
4. Consistent with National Policy.

Criterion B. c. of Policy R04 and R05 should therefore include reference to passenger transport (see comments to Policy R02 - Land at West Horndon Industrial Estate).

Amend Policy R04 and R05 as follows to separate into two criteria -

d. integrate existing community facilities within new development;

e. provision for new multi-functional green infrastructure including public open space;

3. Effective.

Policy R04 and R05 B. d. covers 2 separate matters (community facilities and open space) and should be split into two criteria.

Remove the caveat "where appropriate". This is unnecessary and ambiguous, creating a loophole for developers to do nothing.

g. protect and enhance the Local Wildlife Sites (Barrack
Wood/Donkey Lane Plantation) and deliver a measurable net gain in biodiversity.

The policy wording is ambiguous and lacks a commitment to deliver a net gain in biodiversity.

Dear Sir/Madam,
Thank you for consulting Thames Water on the above document. Thames Water is the statutory sewerage undertaker for part of the Borough and is hence a "specific consultation body" in accordance with the Town & Country Planning (Local Development) Regulations 2012.
Planning Policies
Thames Water support the proposed policies within the Pre-submission Local Plan. Notwithstanding this it is suggested that minor modifications are made to the text within Policies SP01 and SP04 in order to ensure that the policies are effective in relation to ensuring development is delivered alongside any necessary sewerage infrastructure reinforcement works required to support it. The proposed modifications are set out in the attached response forms. In relation to Policy NE02 the requirement for engagement with sewerage providers is welcomed. To assist with promoting early engagement it would be beneficial if a link to Thames Waters pre-application service could be provided on the Councils website. Details regarding Thames Waters pre-application service can be found at: www.thameswater.co.uk/preplanning

Site Specific Comments
We have undertaken a high level review of the proposed site allocations within the Thames Water catchment and have appended comments in relation to wastewater infrastructure issues for these sites in table below.
R04 & R05 - Ford Headquarters and Council Depot, Warley: The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and
how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application. R06 - Land off Nags Head Lane, Brentwood The wastewater network capacity in this area may be unable to support the demand
anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application.
R07 - Sow & Grow Nursery, Ongar Road, Pilgrims Hatch
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ
R08 - Land adjacent to Camel, Mascalls Lane, Warley
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ. We do not envisage network infrastructure concerns regarding wastewater infrastructure capability in relation to this site on a basis that it won't be any surface water connection into a public foul sewer system. Connection of surface water into a public foul sewer system reduces sewer capacity and has the potential to cause flooding to existing customers. Drainage hierarchy to be followed in addressing surface water.
R09 - Land west of Warley Hill, Pastoral Way, Warley
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ
Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R10 - Brentwood railway station car park St James Road, Brentwood
The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be submitted with the planning application. A significant assets run beneath the site. We would seek protection of these assets and may require several wayleaves /easements. Drainage hierarchy to be followed in addressing surface water. As this is brown field site, we expect significant reduction in surface water runoff.
R11 - Westbury Road Car Park, Westbury Road, Brentwood
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Drainage hierarchy to be followed in addressing surface water. As this is a
brown field site, we expect significant reduction in surface water runoff.
R12 - Land at Hunter House, Western Road, Brentwood (Reviewed Jan18)
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing. Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Surface water to be addressed according to the Drainage hierarchy. This being a brownfield site we expect a significant reduction in surface water runoff.
R13 Chatham Way/Crown Street Car Park, Brentwood (Reviewed Jan18)
On the information available to date we do not envisage infrastructure concerns regarding wastewater network or wastewater treatment infrastructure capability in relation to this site/s. It is recommended that the Developer and the Local Planning Authority liaise with Thames Water at the earliest opportunity to advise of the developments phasing.Please contact Thames Water Development Planning, either by email Devcon.team@thameswater.co.uk tel: 02035779998 or in writing Thames Water Utilities Ltd, Maple Lodge STW, Denham Way, Rickmansworth, Hertfordshire, WD3 9SQ Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R14 - WILLIAM HUNTER WAY, CAR
PARK SITE, BRENTWOOD
The wastewater network capacity in this area may be unable to support the demand anticipated from this development. Local upgrades to the existing drainage infrastructure may be required to ensure sufficient capacity is brought forward ahead
of the development. Where there is a potential wastewater network capacity constraint, the developer should liaise with Thames Water to determine whether a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered is required. The detailed drainage strategy should be
submitted with the planning application. Drainage hierarchy to be followed in addressing surface water. As this is a brown field site, we expect significant reduction in surface water runoff.
R15 - Wates Way Industrial Estate,
Ongar Road, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding water supply network or water
treatment infrastructure capacity in relation
to this site/s. It is recommended that the
Developer and the Local Planning Authority
liaise with Thames Water at the earliest
opportunity to advise of the developments
phasing. Please contact Thames Water
Development Planning, either by email
Devcon.team@thameswater.co.uk tel:
02035779998 or in writing Thames Water
Utilities Ltd, Maple Lodge STW, Denham
Way, Rickmansworth, Hertfordshire, WD3
9SQ
Drainage hierarchy to be followed in
addressing surface water. As this is a
brown field site, we expect significant
reduction in surface water runoff.
R16 & R17- Land off Doddinghurst Road, either side of A12, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater network or
wastewater treatment infrastructure
capability in relation to this site/s. It is
recommended that the Developer and the
Local Planning Authority liaise with Thames
Water at the earliest opportunity to advise of
the developments phasing. Please contact
Thames Water Development Planning,
either by email
Devcon.team@thameswater.co.uk tel:
02035779998 or in writing Thames Water
Utilities Ltd, Maple Lodge STW, Denham
Way, Rickmansworth, Hertfordshire, WD3
9SQ
R19- Land At Priests Lane, Brentwood
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Please note that the above comments
relate to the sewerage network within the
Thames Water supply area only. It is
recommended that Anglian Water are also
consulted for their comments in relation to
this development proposal. Drainage
hierarchy to be followed in addressing
surface water.
R23 - Brizes Corner Field, Blackmore
Road, Kelvedon Hatch
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Drainage hierarchy to be followed in
addressing surface water. Please note that
the above comments relate to the sewerage
network within the Thames Water supply
area only. It is recommended that Anglian
Water are also consulted for their
comments in relation to this development
proposal.
R24 - Land off Stocks Lane, Kelvedon Hatch
On the information available to date we do
not envisage infrastructure concerns
regarding wastewater infrastructure
capability in relation to this site.
Drainage hierarchy to be followed in
addressing surface water. Please note that
the above comments relate to the sewerage
network within the Thames Water supply
area only. It is recommended that Anglian
Water are also consulted for their
comments in relation to this development
proposal.

POLICY SP04
In relation to wastewater infrastructure it will be essential that new development is aligned with any
necessary upgrades required to ensure that the development would not overload the existing
sewerage network. Thames Water therefore support the content of Policy NE2 parts D and E and
encourage developers proposing developments to engage with them at an early stage to discuss the
wastewater infrastructure requirements for development.
The proposed policy ensures that the Local Plan is consistent with Paragraphs 20 and 41 of the NPPF.
Alongside the proposed amended text for Policy SP04, the policy will help ensure the effective
delivery of any sewerage network reinforcement works necessary to support development.

POLICY SP04
In relation to wastewater infrastructure it will be essential that new development is aligned with any
necessary upgrades required to ensure that the development would not overload the existing
sewerage network.
Thames Water support the policy in principle. However, it should be noted that new sewerage
infrastructure is delivered by the sewerage undertaker and funded through the infrastructure charge
for new developments connecting to the sewerage network. It is not therefore possible for any
necessary upgrades to be secured through CIL or S106 contributions. In order to ensure that any
necessary sewerage infrastructure reinforcement works required to support a development are
delivered ahead of the occupation of development it may be necessary for planning conditions to be
used to ensure that a development or phase of development is not occupied until the required
upgrade has been delivered. To help ensure this Policy SP04 should make reference to the use of
planning conditions as a mechanism to ensure the delivery of infrastructure alongside S106
agreements and CIL.

To address the above concern Part B of Policy SP04 could be amended to incorporate the following
wording:
"c. off-site capacity improvement works (secured through appropriate planning conditions or
agreements)"
The proposed change would ensure that planning conditions can be used to secure infrastructure
improvements necessary to support development alongside S106 agreements and CIL thereby
ensuring that the policy is effective and the Local Plan is sound.

POLICY SP01:
Thames Water support the aim of Policy SP01 (D) in relation to ensuring development does not result
in unacceptable impacts on amenity. However, as worded the policy would only be effective in
ensuring that development itself has no unacceptable impact on amenity. Consideration is also
required to be given to whether the location of proposed development is appropriate taking into
account existing sources of noise, odour and vibration to ensure that the amenity of future occupiers
of development will not be adversely affected by such issues. Where development would be affected
by an existing source of noise, odour or vibration development should only be allowed where it is
demonstrated that suitable mitigation measures can be put in place and it has been demonstrated
how these will be delivered. This would be required in order to ensure that the policy is consistent
with Paragraph 182 of the NPPF 2019.
To address the above concern it is considered that Part D(e) of Policy SP01 could be revised to read as
follows:
"e. has no unacceptable effect on health, the environment or amenity due to the release of pollutants
(such as light, noise pollution, vibration, odour, smoke, ash, dust and grit) to land, water or air, and
where the amenity of future occupiers would not be adversely impacted by existing sources of such
pollutants unless suitable mitigation measures are proposed and secured;"
The additional wording would ensure that development is not located where the amenity of future
residents would be affected by existing sources of polluntants unless suitable mitigation is provided.
This would ensure that the policy is effective and consistent with the NPPF and therefore sound.

1.0 Introduction
1.0.1 Thank you for consulting the Basildon & Brentwood Clinical Commissioning Group (CCG) and the Mid and South Essex Sustainability and Transformation Partnership (STP) on the above emerging Local Development Plan (LP) Document.
1.1 In reviewing the context, content and recommendations of the LP Document and its current phase of progression, the following comments are with regard to the Healthcare provision on behalf of the STP
2.0 Existing Healthcare Position in the Emerging Plan Area
2.1 The LP Document covers the administrative area of Brentwood.
2.2 Currently, within the administrative area, healthcare provision incorporates a total of 9 GP Practices, 13 pharmacists, 9 dental surgeries, 10 Opticians, 2 community clinics and 2 community hospitals.
2.3 These are the healthcare services available that this Local Plan must take into account in formulating future strategies.

The Brentwood Bus and Rail Users' Association represents the interests of users of public transport in the Brentwood district.
Its aims and objectives are fourfold:
* To make representations on behalf of Brentwood's bus and rail users on the local services that are currently available and to campaign for new services to be .
* To campaign for more investment in local bus and rail services.
* To have regular dialogue with the local transport providers and Essex County Council.
* To work with other organisations and individuals to improve and develop local bus and rail services in our area.
In pursuit of these aims and objectives it wishes to comment on the implications of the Local Development Plan as amended by the Extraordinary Council Meeting on 8th November 2018.
The Plan will clearly have far-reaching implications for Brentwood's public transport network. First, it changes significantly the size and distribution of the borough's population and the consequent additional requirements for ways to access work, health and education, shopping and leisure. Secondly it will add to the already problematic traffic congestion issues at known pinch-points in the borough, which are already making it very difficult for bus operators to maintain a regular and efficient service.
It is therefore a matter of extreme concern for the Association that there are only four references to public transport in the document citing preferred allocations.
Most are in the aspirational vein of the Strategic Objectives
* Improve public transport infrastructure and ensure development sites are well
connected to bus and/or rail connections.
* Secure the delivery of new infrastructure to support a lower carbon future including
electric vehicles charging points and other measures.
* Improve cycling and walking facilities across the Borough and establish a grid or
network of green transport corridors.
This contrasts with health and school capacity, which are dealt with in some detail.
There are no references to traffic congestion, to which the Plan will clearly contribute. There are three references to bus services, one in the strategic objective and two in relation to one preferred site for an employment site which "has the potential" for development of bus services i.e. there are none at the moment.
It is difficult to see how a plan can be called strategic without proper consideration of public transport (i.e. buses as rail transport relates to travel in and out of the borough) within the borough. There is no mention of how congestion, which already inhibits travel within the borough and is predicted to increase even without the additional housing and business development.
There is limited scope for road improvements in the borough and additional developments are
outside the control of the planning authority. Increased congestion will impact on the ability of bus
operators to provide a regular and efficient service, reducing the extend to which they will be taken
up by users and increasing the likelihood that they will prove uneconomic and be withdrawn.
The impact of the proposed allocations
Central Area
The Ford Offices are excluded from this section and allocated to the Outer Area in the table below as
the site, although served by buses, is too far for most people to consider the station walkable while
Brentwood High St most certainly is not.
It is assumed that most people would find it possible to walk to Brentwood station and to the High
Street. A regular bus service is available from Warley (Council Depot) and from close to the Shenfield
sites (Priests Lane is walkable to Brentwood High Street but probably closer to Shenfield Station).
Outer Area
The sites in the outer area (beyond reasonable walking distance) present some difficulty. Some (Sow
& Grow and the three Warley sites (Ford Offices, Mascalls Lane and Pastoral Way) are close to bus
routes to Brentwood Station and High Street. For convenience, residents may choose to drive rather
than wait for the regular bus services (to which they have to walk). Brook Street has a regular bus
service to the High Street but not to the station and people are likely to drive there rather than
change buses in the High Street.
Ingatestone
The Ingatestone developments are just about walkable from the station and the limited number of
shops in Ingatestone High Street. The train service from Ingatestone is less frequent than from
Shenfield and people are therefore likely to drive there rather than use their local station. There is a
half-hourly bus service into Brentwood but many people are likely to opt to drive.
Northern Villages
Existing bus services are not sufficiently attractive to residents to persuade them to use them rather
than to drive. The addition of 169 additional units is unlikely to change the economics until bus
companies can justify later evening services for returning commuters and socialising residents. It is
likely than buses will remain very much the less favoured option. The consequence is higher volumes
of traffic on feeder roads into Brentwood such as the already-congested A128 and Doddinghurst
Road.
Dunton Garden Village
It is likely that residents of the proposed Dunton Garden Village will look towards Basildon and
Lakeside for their shopping and leisure activities, meaning that the injection of consumer spend in
the core settlement of Brentwood is likely to be minimal. The demand for public transport will
reflect this, with the benefit of increased capacity and potential new routes spread laterally along
the A127/A13 corridor than northwards into the rest of the borough.
Congestion
Any additional or enhanced bus services into Brentwood will have to cope with increased congestion
in the mornings on the A128 through Herongate and Ingrave - in fact it is difficult to see how much
more traffic can be accommodated on this section of road even without additional developments.
Brentwood's centre is already heavily congested at peak times, especially since the County Council's
revised school transport policy has left many parents from the Northern Villages in particular reliant
on private transport. The congestion is acute on the A128 from Pilgrims Hatch into Brentwood and
from Herongate/Ingrave, with consequent congestion on Shenfield and London Roads. There are
other bottlenecks in Kings Road and around the cluster of schools in Sawyers Hall Lane.
All of this will only get worse as the number of vehicles follows the predicted increase and the
addition of more than 2,000 homes around Brentwood but outside walking distance (and excluding
Ingatestone and Dunton) will only make things worse.
There will be consequences for parking (already barely adequate at peak times), pollution with the
levels of gases and particulates increasing to the detriment of people's health, and for the viability of
commercial bus services as their reliability and regularity is challenged.
All this makes the Plan's strategic objective ("to improve public transport infrastructure and ensure
development sites are well connected to bus and/or rail connections") a massive challenge.
Commercial partners will not join until the revenue benefits are clear and the costs defined. It is
unlikely this will precede the developments. In some cases (Northern Villages) the proposed
developments are too small to make more than a marginal difference to the economics of public
transport but they will suffer most if the road system is catastrophically congested.
The Other Strategic Objective
The Plan offers the following objective: "to improve cycling and walking facilities across the Borough
and establish a grid or network of green transport corridors".
Cycling and walking are technically possible in the central and outer areas now. In practice
Brentwood is a hostile environment for both cyclists and pedestrians. For the former, pavements are
in a degraded state across the borough and the County Council's belated allocation of £700,000
across the County in reality allows little scope for massive improvement. Opportunities to negotiate
crossings in the High Street and immediate area are few and far between, with the priority always
seeming to be swung towards motorised traffic and the mantra of keeping traffic flows constant.
For cyclists, Brentwood is a potential death trap, with the residual potholes that fail to meet ECC
criteria for repair a constant and potentially lethal hazard. The general absence of cycle lanes
militates against safe use of the main roads; junctions are structured for vehicles and not bicycles.
For the outer areas, the high speed of traffic on the main routes, the narrowness of lanes and the
absence of cycle lanes militates against their use.
Conclusion
The Brentwood Bus and Rail Users recognises the imperative on Brentwood Borough Council to
provide additional housing in the area. It is, however, deeply concerned that the number and
distribution of proposed new dwellings will, if car ownership remains unchanged, place an
impossible burden on the existing road system and in particular on the existing network of bus
services. Delays to buses caused by congestion will not encourage greater use - and we fear the
reverse, with proportionately more people using private transport.
With no reference in the Plan to innovative solutions such as park-and-ride, and only lip service paid
to the encouragement of cycling and walking as an alternative, the Association fails to see how the
requirement that delivery of the Plan is environmentally sustainable can be met.
David Jobbins
Vice Chair, Brentwood Bus and Rail Users' Association

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).

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.

Seek to have the Council's owned land (the Depot) and the Ford site be separated to allow for the Ford site to come forwarded earlier on in the Plan period to provide residential development.

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.