1.0 Introduction
1.1 These representations have been prepared by Strutt & Parker on behalf of M Scott Properties Ltd (Scott Properties) pursuant to Brentwood Borough Council's (the Council) Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) (Focussed Changes). They are submitted in addition to and should be read alongside those submitted in response to the previous Regulation 19 consultation held in February - March 2019.
1.2 Scott Properties have an interest in land to the west of Crossby Close, Mountnessing (the Site), which has been actively promoted as part of the Council's plan-making process, site reference 073 (AECOM (January 2019) SA Report). Previous representations have been made at various stages of the Local Plan, including the Call for Sites exercises and each consultation regarding the emerging Local Plan.
1.3 Scott Properties, in their capacity as a provider of specialist accommodation, are promoting the Site for specialist accommodation for those aged 55 and over, as well as those with, or supporting someone with a disability, in order to address an identified and unmet need locally and within the Borough.
1.4 Our earlier response to the Regulation 19 Consultation included evidence which demonstrated the existence of a local need for specialist accommodation within Mountnessing, and support for this type of accommodation through an online local needs consultation which received 92 positive responses.
1.5 These representations raise concerns as to:
 the impact of the higher Local Housing Need (LHN) figure;
 the lack of reasonable alternatives considered in making the Focussed Changes;
 the ability of the Focussed Changes to meet local housing needs, particularly older people; and
 the robustness of the SHLAA in light of the Focussed Changes.
2.0 Higher Local Housing Need (LHN)
2.1 These representations seek to focus on the proposed focussed changes to the Pre-Submission Local Plan (PSLP), set out in the consultation draft of the Focussed Changes. However, there are inevitable consequences resulting from the proposed amendments that draw together matters not specifically intended to be the focus of the addendum. We highlight these to ensure there is a holistic understanding of the effects of the changes proposed in the addendum and changes to national and local circumstances that should be considered prior to submission of the Plan.
2.2 Since the publication of the Pre-Submission Local Plan, Planning Practice Guidance (PPG) has been updated (in February 2019, during the previous Regulation 19 consultation) and confirms that the 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method.1 The Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report Addendum - October 2019 (the SA Addendum) confirms at paragraph 2.9.3 that the LHN figure is now understood to equate to 454 dwellings per annum (dpa).
2.3 We expressed our concerns in our response to the previous Regulation 19 representations that there was insufficient flexibility within the PSLP's target figure of 456 dpa, which incorporates a 20% buffer on the housing requirement of 350 dpa as set out therein.2 Based on the actual housing need figure, as confirmed at 454 dpa within the SA Addendum, there now exists a buffer of just two dwellings per annum, which does not provide sufficient flexibility to ensure the Borough's housing needs are met. This is confirmed in paragraph 2.9.6 of the SA Addendum, which states that:
"the proposed supply figure of 456 dpa can no longer be said to put in place a significant 'buffer' over-and above the housing requirement."
2.4 In addition, it also highlights the risks of delays in delivery, as a result of increasing the housing supply to be provided at Dunton Hill Garden Village (DHGV) within the Plan period, confirming the importance of a buffer over-and-above the housing requirement for this reason. The Nathaniel Litchfield Study From Start to Finish (2016) confirms that the planning process takes on average 2.5 years for a planning application determination period for schemes of up to 500 units, but that this can double for schemes of 1,000 units and over. This not only confirms that it is unlikely that DHGV will deliver as early as 2022/23 as stated in the housing trajectory, but also points towards a necessity to ensure there is adequate provision within the Plan to meet housing requirements in the short-term. Within our earlier representations we stated that is was unrealistic that DHGV could deliver 100 dwellings as soon as 2022/23 as set out in the PSLP. Given that this was predicated (partly) on the adoption of the Local Plan in 2019, this timeframe is now clearly unrealistic and adoption by the end of 2020 remains challenging, with obvious implications for the proposed trajectory.
2.5 We consider that the Focussed Changes should have included an update to the LHN and the trajectory, without which the Plan can no longer be considered sound. Paragraph 11 of the NPPF requires plan-makers to positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change (our emphasis). It is considered that this is now not the case as a result of the updated LHN, given the Focussed Changes make no attempt to positively seek opportunities to meet development needs within the Borough. This is also set out in our comments regarding the lack of consideration of reasonable alternatives. This renders the plan inconsistent with national policy and unsound.
2.6 Paragraph 2.9.3 of the SA Addendum states that:
"It is fair to conclude that there is naturally a degree of increased risk associated with reliance on DHGV, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery; however, discussions between the Council and the site promoter have served to indicate that the 70 homes additionally assigned to the site through the Focussed Changes are deliverable within the plan period, and indeed can be delivered in a timely fashion such that the Local Plan housing delivery trajectory is unaffected."
2.7 The updated housing trajectory in the Focussed Changes shows the 70 homes reallocated to DHGV, as a result of the decreases from Focused Changes numbers.2-5, between years 15 and 17 (2030-2033), which does not represent delivery in a 'timely fashion', nor is the trajectory unaffected as a result. The Focussed Changes reduce the housing delivery within the earlier years of the Plan and thus the Plan's ability to meet its needs within those years. Our concern as to the robustness of the decision to adopted a stepped trajectory as raised in our response to the previous Regulation 19 consultation remains. We consider that the effect of the Focussed Changes in further reducing the Plan's ability to meet its needs within the earlier years of the Plan; a concern that we raised in our previous Regulation 19 response.
2.8 We have concerns as to the accuracy of the updated housing trajectory, which shows an increase in the Total Housing Provision within years 12 and 13, but no corresponding increases within the expected delivery from the Plan Allocations. Furthermore, the additional housing allocated to DHGV in year 17 does not correspond with the Total Housing Provision. This results in an over-estimated supply within years 12 and 13, and an under-estimation in year 17. We would expect the Council to clarify these errors, as it is casts uncertainty as to the exact effect of the Focussed Changes on the housing trajectory.
2.9 The table attached at Appendix A shows the updated housing trajectory (assuming a Total Housing Provision that aligns with expected delivery of the allocations) against the updated LHN. This shows that by year 7 (2022/23) there will be a deficit of 1,151 dwellings, and this is based on optimistic delivery rates for sites without planning permission expected to deliver in year 5 and onwards, so likely represents the best-case scenario. It also assumes that DHGV will commence delivery as early as year 7 (2022/23), which, as stated above and within our response to the previous Regulation 19 consultation, is an unrealistic expectation.
2.10 As a result of the increased LHN, the Total Housing Provision within the Plan provides a buffer of only 69 dwellings over the Plan's total housing requirement, which equates to just 0.9% of the requirement across the Plan period. The PSLP sought to provide a buffer of 20% against the housing requirement and we would highlight that the Chelmsford Local Plan, which has recently been examined, proposes a 20% buffer and this has been found to be suitable by the Inspector. The situation for the PSLP is that, again, the Plan demonstrates a lack of flexibility contrary to best practice, contrary to the rationale of the PSLP itself and contrary to Paragraph 11(a) of the NPPF. The Plan is therefore not positively prepared, nor will it be effective in meeting its needs across the Plan period.
3.0 Ability to Meet Local Housing Need (LHN)
3.1 Our representations to the previous Regulation 19 consultation highlighted the ageing population within the Borough, as recognised within paragraph 6.6 of the PSLP, and our concerns as to the lack of provision for specialist accommodation within the PSLP to meet present and future needs.
3.2 The Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report October 2019 (the SA) states at paragraph 9.5 that:
"There is also a need to address the health inequalities that exist within the population, and which are set to worsen, including because of the ageing population."
3.3 The Focussed Changes reduce the Plan's ability to meet local needs, particularly those of an ageing population, firstly, by reducing housing numbers in areas where housing needs are likely to be the highest, as quoted within the SA Addendum.3
3.4 Policies R25 and R26 require a provision for a minimum of 25% of the dwellings provided to be made available to those with a local connection, or to those aged 50 and over. The reduction in the number of dwellings not only reduces the potential availability of housing suitable for older people, but also raises concerns as to viability, as recognised within the SA Addendum. It states at paragraph 2.9.2 that:
"A reduced number of homes will have implications for scheme viability, and it is noted that these sites are subject to a policy requirement in respect of reserving a minimum of 25% of the proposed dwellings to be reserved for people with a strong and demonstrable local connection or those over 50 years of age; however, it is not possible to conclude any significant risk of the schemes becoming undeliverable."
3.5 Although this concludes that the schemes themselves may not become undeliverable, there is a real possibility that viability will affect the provision for these 25% homes for local people and those aged 50 and over coming forward through these allocations.
3.6 In addition, the Brentwood Local Development Plan Health Impact Assessment Version 3 October 2019 (HIA) notes that the reduction in dwellings on allocation R19 means that no wheelchair accessible dwellings will be required on site, taking it below the 60 dwelling threshold as set out in Policy HP01 of the PSLP.
3.7 Although the reduction in housing numbers on R18-19 and R25-26 will be redistributed to DHGV as part of the Focussed Changes, we would reiterate our concerns in relation to the provision and delivery of specialist accommodation at DHGV. Firstly, as stated above, the redistributed housing is not expected to be delivered at DHGV until year 12, reducing the ability of the Plan to address needs earlier in the Plan period.
3.8 Secondly, the provision for specialist accommodation at DHGV is to be delivered in accordance with Policy HP04. Paragraph 9.9.4 of the SA states that the provision of specialist accommodation at DHGV is not clear. Our response to the Regulation 19 consultation also raised concerns as to the lack of clarity regarding the definition of specialist accommodation within the supporting text of this Policy. The supporting text fails to give an accurate representation as to which type of specialist accommodation the Plan is seeking to deliver and for which group(s).
3.9 In light of this, it is considered that the Focussed Changes negatively affect the delivery of specialist accommodation for older people within the Plan period. We consider that the identification of additional suitable sites to meet needs within the short to medium term of the Plan period would enable the Plan to meet its housing needs specifically for older people. In the absence of this, we consider the Plan to be unsound and in direct conflict with the 'Housing for older and disabled people' 26 June 2019 addition to the NPPG.
4.0 Lack of Reasonable Alternatives Considered
4.1 The Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report Addendum (October 2019) (the SA Addendum) states at paragraph 1.2.5 that as part of preparing the Focussed Changes and updating the SA, there was not considered to be a need to give further formal consideration to reasonable alternatives, as it was considered unlikely that alternatives would lead to notably different side effects. This was in reliance of Planning Practice Guidance (PPG) paragraph 009 Reference ID: 11-009-20140306, which states:
"The sustainability appraisal should only focus on what is needed to assess the likely significant effects of the plan."
4.2 We consider that the conclusions as to the effects of the Focused Changes, particularly in respect of the 'Housing' objective as stated within the Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report October 2019 (SA) clearly demonstrate that reasonable alternatives should have been considered.
4.3 The SA states that there will be 'uncertain negative implications' for the achievement of the 'Housing' objectives.4 This is on the basis that the housing has been reduced in areas where needs are likely to be highest, and, has been moved to Dunton Hills Garden Village (DHGV), potentially increasing the risk of not delivering the housing requirement. It also makes reference to the higher LHN figure. In comparison, the PSLP, prior to the Focussed Changes, was assessed as likely to have 'significant positive effects' on the basis of ability to meet the LHN and provide for specialist accommodation.
4.4 In our previous representations to the Regulation 19 consultation, we disputed this conclusion and the ability of the plan to deliver specialist accommodation. A number of concerns were received from respondents to the Regulation 19 consultation as to the effectiveness of the Plan to meet the needs of older people, which should have prompted the Council to review the strategy in this regard as part of the Focussed Changes. The Site (reference 073) has consistently been promoted for specialist accommodation for older people, to meet a locally identified need within Mountnessing, as detailed in our previous representations, and represents a missed opportunity. Not only would this help to address a locally identified need, it would also enable delivery in the early years of the plan period; two concerns that were prevalent in the responses to the Regulation 19 consultation. This further supports the argument that reasonable alternatives to the Focussed Changes should have been considered.
4.5 Despite this, the SA then goes onto conclude that the assessment of the PSLP against the housing objective (significant positive effects) 'broadly holds true' for the Focussed Changes (uncertain negative effects). This is clearly not the case, and it is considered that this conclusion is both incorrect and misleading.
4.6 It is considered that the change from 'significant positive effects' (PSLP) to 'uncertain negative implications' (Focussed Changes) in achieving the 'Housing' objective amounts to a significant effect of the Focussed Changes. Therefore, in accordance with the PPG (as referenced above), consideration should have been given to reasonable alternatives, and the definitive conclusion that alternatives would not have led to notably different side effects is unjustified. As a minimum, the Council should have considered reasonable alternatives to ascertain whether there was a more suitable strategy which would enable the Plan to meet its housing needs, thus enabling the Plan to achieve a more positive and beneficial outcome in respect of the 'Housing' objective. We consider this to be fundamentally important to ensuring a sound Local Plan.
4.7 Given the decrease in housing within areas with the highest needs as raised in the SA, regard should have been had to allocating additional suitable sites to meet housing needs at a local level (which the plan failed to do prior to the Focussed Changes). This would help to address local housing requirements, including the provision of specialist accommodation, as well as providing a more substantial buffer over and above the increased LHN and help to minimise the risks associated with potential delays in delivery at DHGV; a concern that is highlighted in the SA.
4.8 Following from this, it would seem highly appropriate to consider settlements on key transport corridors such as Mountnessing, that contain sites that scored better than many of the allocated sites in the SA such as Site 073 (Land adjacent to Mountnessing Primary School), that could deliver housing to meet identified local needs within the first 5 years of the Plan, before choosing, what should be a last resort given the trajectory already discussed, increasing housing numbers at DHGV. Our representations to the previous Regulation 19 consultation contained evidence of local support via a social media consultation, which received 96 responses in total, all of whom were interested in a new build bungalow specifically for those aged 55 and over on the Site.5 Appendix B contains a summary of this. This demonstrates a locally supported site which is a suitable alternative to the Focussed Changes, yet one which has been overlooked.
4.9 The Plan has failed to consider alternative, suitable sites, to balance the reduction in housing numbers in the sites subject to the Focussed Changes when identifying suitable solutions to correct this.
5.0 Robustness of SLAA
5.1 We argued clearly within previous representations that the approach to assessing sites within the SA using the 'traffic light' scoring system was primitive, inconsistent and unjustified, which resulted in subjective and ill-informed conclusions. This is clearly shown in relation to the Site - land west of Crossby Close, Mountnessing, as shown below:
 the Site scored higher than many of the allocated sites, yet was not allocated due to 'potential highways access issues' despite previous representations confirming Essex County Council Highways have no objection to the access, and which agree with the proposed access strategy;
 the scoring system as to a Site's classification of agricultural land (criterion 17) the dataset for which, as confirmed in the SA, is described as 'of a poor resolution.' This resulted in some sites being scored 'red' or 'amber' when in fact they were brownfield or non-agricultural land. The Site was incorrectly assessed as 'amber' for this criterion, yet it has not been in agricultural use since the current owner's acquisition in 1995 (with evidence adduced as part of our response to the previous Regulation 19 consultation to support this);
5.2 This further demonstrates inconsistencies and inaccuracies within the site assessment process, which we consider fails to demonstrate that the Plan has been positively prepared. However, despite pointing these out, the Focussed Changes do not include any rectification of these errors, and instead has taken a selective and non-transparent approach to amend existing allocations in response to objections received in the previous Regulation 19 consultation. We consider that this should have formed part of the consideration of reasonable alternatives to the Focussed Changes, which, as discussed above, was unjustifiably overlooked by the Council, in preference for amending the evidence base to suit the desired outcome. As a result, the Plan is not justified and cannot be considered sound.
6.0 The Unclear Approach to R18, R19, R25 and R26
6.1. The Council has decided to reduce the densities on allocations R18, R19, R25 and R26 (Focussed Changes 2-5), citing a considerable number of representations raising concerns as to the suitability of the sites for the proposed densities as the justification.
6.2. In redistributing the housing numbers from the above allocations to DHGV, the large number of objections received during the previous Regulation 19 consultation in respect of DHGV, including from statutory consultees, have been ignored. Instead, the Focussed Changes have gone against a number of comments, which highlight the unrealistic delivery timetable, and the need for sites which can deliver in the early years of the Plan.
6.3. There were also objections received in respect of other allocations within the Plan, as well as comments in respect of omission sites, such as our response to that consultation, which sought to clarify inaccuracies about the Site within the site assessment and show that earlier concerns regarding the access arrangements had been addressed.
6.4. The Addendum of Focussed Changes explains that the total loss of 70 homes across the four aforementioned sites will be off-set by altering another allocation to increase the number of new homes provided at Dunton Hill Garden Village (Focussed Change 1). However, the addendum does confirm that the overall number of new homes will not be increased, merely that there will be a faster rate of delivery at Dunton Hills Garden Village, resulting in more dwellings being provided before 2033 than previously projected (resulting in fewer post-2033).
6.5. We have a number of concerns with the proposed approach to addressing the shortfall that Focussed Changes 2-5 necessitate by simply altering Dunton Hills Garden Village to deliver at a greater rate than previously calculated, and at just a fast enough rate to account for the shortfall created by the need to reduce the proposed capacities for site R18, R19, R25, and R26. The lack of clarity in how both the reduction and the increase have been justified is unhelpful in being able to comment on the justification for the Focused Changes.
7.0 Cross-boundary and Statutory Consultee Objections
7.1. Basildon Borough Council have objected to the DHGV allocation in its response to the previous Regulation 19 consultation, in which it raised concerns regarding the cross-boundary impacts of this site, questioning the soundness of the Plan in this respect. Similarly, Essex County Council also raised concerns in respect of the transport evidence base for DHGV. As part of the Focussed Changes, the Council have seemingly overlooked these comments, in the absence of any evidence to the contrary, seeking instead to direct more housing numbers to this allocation within the Plan period, and failing to consider any reasonable alternatives.
7.2. As for the key concerns raised, it is concerning that the site assessments undertaken to date have failed to identify the numerous cited issues raised by respondents. Notwithstanding the inaccuracies in the assessment of our Site (land west of Crossby Close, Mountnessing) as mentioned above and in detail in our response to the previous Regulation 19 consultation, this casts further doubt on the robustness and the overall accuracy of the site assessment process which underpins the allocations within the Plan. This also substantiates our previous concerns that the site assessment process was inadequate, and therefore potentially undermines the remaining allocations within the Plan, as it is unclear as to whether any significant objection was raised in relation to those through the previous Regulation 19 consultation.
8.0 Conclusion
8.1. We consider that the Plan remains unsound as a result of the Focussed Changes. The higher confirmed LHN has not been incorporated within the Plan, nor the effects of this on whether the Plan should identify a suitable buffer to provide flexibility to adapt to rapid change. The Plan is therefore failing to meet the requirements of the NPPF and failing to meet the identified need for the Borough. The Focussed Changes do not demonstrate that the Plan will be effective in meeting housing needs, given it seeks to re-direct housing delivery from the short-term to the later years of the Plan, further decreasing its ability to meet its needs early in the Plan period. This is particularly concerning given the results of the Housing Delivery Test for the Borough (2019).
8.2. The trajectory as set out in the Focussed Changes remains overly optimistic, with the concerns as to the effects of a slippage in delivery at DHGV raised forming part of the reason for the SA conclusions that the Focussed Changes will have 'uncertain negative effects' on the 'Housing' objective. We strongly disagree with the SA's further conclusions that the assessment of the PSLP against the 'Housing' objective (significant positive effects) 'broadly holds true' for the Focussed Changes (uncertain negative effects).
8.3. The decision to discount the need for consideration of reasonable alternatives is inconsistent with national policy, and unjustified. This is apparent from the SA conclusions (discussed above), and we are highly concerned that this has reduced the ability of the Plan to meet the housing needs of the Borough going forward. The Council should have considered the merits of identifying additional, suitable sites to deliver in the short-medium term, including those which provide specialist accommodation to meet an identified local need, such as the land west of Crossby Close (site 073). As discussed above and shown in Appendix B, this represents a suitable site with local support for specialist accommodation that has been overlooked.

1.0 Introduction
1.1 These representations have been prepared by Strutt & Parker on behalf of M Scott Properties Ltd (Scott Properties) pursuant to Brentwood Borough Council's (the Council) Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) (Focussed Changes). They are submitted in addition to and should be read alongside those submitted in response to the previous Regulation 19 consultation held in February - March 2019.
1.2 Scott Properties have an interest in land to the west of Crossby Close, Mountnessing (the Site), which has been actively promoted as part of the Council's plan-making process, site reference 073 (AECOM (January 2019) SA Report). Previous representations have been made at various stages of the Local Plan, including the Call for Sites exercises and each consultation regarding the emerging Local Plan.
1.3 Scott Properties, in their capacity as a provider of specialist accommodation, are promoting the Site for specialist accommodation for those aged 55 and over, as well as those with, or supporting someone with a disability, in order to address an identified and unmet need locally and within the Borough.
1.4 Our earlier response to the Regulation 19 Consultation included evidence which demonstrated the existence of a local need for specialist accommodation within Mountnessing, and support for this type of accommodation through an online local needs consultation which received 92 positive responses.
1.5 These representations raise concerns as to:
 the impact of the higher Local Housing Need (LHN) figure;
 the lack of reasonable alternatives considered in making the Focussed Changes;
 the ability of the Focussed Changes to meet local housing needs, particularly older people; and
 the robustness of the SHLAA in light of the Focussed Changes.
2.0 Higher Local Housing Need (LHN)
2.1 These representations seek to focus on the proposed focussed changes to the Pre-Submission Local Plan (PSLP), set out in the consultation draft of the Focussed Changes. However, there are inevitable consequences resulting from the proposed amendments that draw together matters not specifically intended to be the focus of the addendum. We highlight these to ensure there is a holistic understanding of the effects of the changes proposed in the addendum and changes to national and local circumstances that should be considered prior to submission of the Plan.
2.2 Since the publication of the Pre-Submission Local Plan, Planning Practice Guidance (PPG) has been updated (in February 2019, during the previous Regulation 19 consultation) and confirms that the 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method.1 The Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report Addendum - October 2019 (the SA Addendum) confirms at paragraph 2.9.3 that the LHN figure is now understood to equate to 454 dwellings per annum (dpa).
2.3 We expressed our concerns in our response to the previous Regulation 19 representations that there was insufficient flexibility within the PSLP's target figure of 456 dpa, which incorporates a 20% buffer on the housing requirement of 350 dpa as set out therein.2 Based on the actual housing need figure, as confirmed at 454 dpa within the SA Addendum, there now exists a buffer of just two dwellings per annum, which does not provide sufficient flexibility to ensure the Borough's housing needs are met. This is confirmed in paragraph 2.9.6 of the SA Addendum, which states that:
"the proposed supply figure of 456 dpa can no longer be said to put in place a significant 'buffer' over-and above the housing requirement."
2.4 In addition, it also highlights the risks of delays in delivery, as a result of increasing the housing supply to be provided at Dunton Hill Garden Village (DHGV) within the Plan period, confirming the importance of a buffer over-and-above the housing requirement for this reason. The Nathaniel Litchfield Study From Start to Finish (2016) confirms that the planning process takes on average 2.5 years for a planning application determination period for schemes of up to 500 units, but that this can double for schemes of 1,000 units and over. This not only confirms that it is unlikely that DHGV will deliver as early as 2022/23 as stated in the housing trajectory, but also points towards a necessity to ensure there is adequate provision within the Plan to meet housing requirements in the short-term. Within our earlier representations we stated that is was unrealistic that DHGV could deliver 100 dwellings as soon as 2022/23 as set out in the PSLP. Given that this was predicated (partly) on the adoption of the Local Plan in 2019, this timeframe is now clearly unrealistic and adoption by the end of 2020 remains challenging, with obvious implications for the proposed trajectory.
2.5 We consider that the Focussed Changes should have included an update to the LHN and the trajectory, without which the Plan can no longer be considered sound. Paragraph 11 of the NPPF requires plan-makers to positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change (our emphasis). It is considered that this is now not the case as a result of the updated LHN, given the Focussed Changes make no attempt to positively seek opportunities to meet development needs within the Borough. This is also set out in our comments regarding the lack of consideration of reasonable alternatives. This renders the plan inconsistent with national policy and unsound.
2.6 Paragraph 2.9.3 of the SA Addendum states that:
"It is fair to conclude that there is naturally a degree of increased risk associated with reliance on DHGV, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery; however, discussions between the Council and the site promoter have served to indicate that the 70 homes additionally assigned to the site through the Focussed Changes are deliverable within the plan period, and indeed can be delivered in a timely fashion such that the Local Plan housing delivery trajectory is unaffected."
2.7 The updated housing trajectory in the Focussed Changes shows the 70 homes reallocated to DHGV, as a result of the decreases from Focused Changes numbers.2-5, between years 15 and 17 (2030-2033), which does not represent delivery in a 'timely fashion', nor is the trajectory unaffected as a result. The Focussed Changes reduce the housing delivery within the earlier years of the Plan and thus the Plan's ability to meet its needs within those years. Our concern as to the robustness of the decision to adopted a stepped trajectory as raised in our response to the previous Regulation 19 consultation remains. We consider that the effect of the Focussed Changes in further reducing the Plan's ability to meet its needs within the earlier years of the Plan; a concern that we raised in our previous Regulation 19 response.
2.8 We have concerns as to the accuracy of the updated housing trajectory, which shows an increase in the Total Housing Provision within years 12 and 13, but no corresponding increases within the expected delivery from the Plan Allocations. Furthermore, the additional housing allocated to DHGV in year 17 does not correspond with the Total Housing Provision. This results in an over-estimated supply within years 12 and 13, and an under-estimation in year 17. We would expect the Council to clarify these errors, as it is casts uncertainty as to the exact effect of the Focussed Changes on the housing trajectory.
2.9 The table attached at Appendix A shows the updated housing trajectory (assuming a Total Housing Provision that aligns with expected delivery of the allocations) against the updated LHN. This shows that by year 7 (2022/23) there will be a deficit of 1,151 dwellings, and this is based on optimistic delivery rates for sites without planning permission expected to deliver in year 5 and onwards, so likely represents the best-case scenario. It also assumes that DHGV will commence delivery as early as year 7 (2022/23), which, as stated above and within our response to the previous Regulation 19 consultation, is an unrealistic expectation.
2.10 As a result of the increased LHN, the Total Housing Provision within the Plan provides a buffer of only 69 dwellings over the Plan's total housing requirement, which equates to just 0.9% of the requirement across the Plan period. The PSLP sought to provide a buffer of 20% against the housing requirement and we would highlight that the Chelmsford Local Plan, which has recently been examined, proposes a 20% buffer and this has been found to be suitable by the Inspector. The situation for the PSLP is that, again, the Plan demonstrates a lack of flexibility contrary to best practice, contrary to the rationale of the PSLP itself and contrary to Paragraph 11(a) of the NPPF. The Plan is therefore not positively prepared, nor will it be effective in meeting its needs across the Plan period.
3.0 Ability to Meet Local Housing Need (LHN)
3.1 Our representations to the previous Regulation 19 consultation highlighted the ageing population within the Borough, as recognised within paragraph 6.6 of the PSLP, and our concerns as to the lack of provision for specialist accommodation within the PSLP to meet present and future needs.
3.2 The Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report October 2019 (the SA) states at paragraph 9.5 that:
"There is also a need to address the health inequalities that exist within the population, and which are set to worsen, including because of the ageing population."
3.3 The Focussed Changes reduce the Plan's ability to meet local needs, particularly those of an ageing population, firstly, by reducing housing numbers in areas where housing needs are likely to be the highest, as quoted within the SA Addendum.3
3.4 Policies R25 and R26 require a provision for a minimum of 25% of the dwellings provided to be made available to those with a local connection, or to those aged 50 and over. The reduction in the number of dwellings not only reduces the potential availability of housing suitable for older people, but also raises concerns as to viability, as recognised within the SA Addendum. It states at paragraph 2.9.2 that:
"A reduced number of homes will have implications for scheme viability, and it is noted that these sites are subject to a policy requirement in respect of reserving a minimum of 25% of the proposed dwellings to be reserved for people with a strong and demonstrable local connection or those over 50 years of age; however, it is not possible to conclude any significant risk of the schemes becoming undeliverable."
3.5 Although this concludes that the schemes themselves may not become undeliverable, there is a real possibility that viability will affect the provision for these 25% homes for local people and those aged 50 and over coming forward through these allocations.
3.6 In addition, the Brentwood Local Development Plan Health Impact Assessment Version 3 October 2019 (HIA) notes that the reduction in dwellings on allocation R19 means that no wheelchair accessible dwellings will be required on site, taking it below the 60 dwelling threshold as set out in Policy HP01 of the PSLP.
3.7 Although the reduction in housing numbers on R18-19 and R25-26 will be redistributed to DHGV as part of the Focussed Changes, we would reiterate our concerns in relation to the provision and delivery of specialist accommodation at DHGV. Firstly, as stated above, the redistributed housing is not expected to be delivered at DHGV until year 12, reducing the ability of the Plan to address needs earlier in the Plan period.
3.8 Secondly, the provision for specialist accommodation at DHGV is to be delivered in accordance with Policy HP04. Paragraph 9.9.4 of the SA states that the provision of specialist accommodation at DHGV is not clear. Our response to the Regulation 19 consultation also raised concerns as to the lack of clarity regarding the definition of specialist accommodation within the supporting text of this Policy. The supporting text fails to give an accurate representation as to which type of specialist accommodation the Plan is seeking to deliver and for which group(s).
3.9 In light of this, it is considered that the Focussed Changes negatively affect the delivery of specialist accommodation for older people within the Plan period. We consider that the identification of additional suitable sites to meet needs within the short to medium term of the Plan period would enable the Plan to meet its housing needs specifically for older people. In the absence of this, we consider the Plan to be unsound and in direct conflict with the 'Housing for older and disabled people' 26 June 2019 addition to the NPPG.
4.0 Lack of Reasonable Alternatives Considered
4.1 The Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report Addendum (October 2019) (the SA Addendum) states at paragraph 1.2.5 that as part of preparing the Focussed Changes and updating the SA, there was not considered to be a need to give further formal consideration to reasonable alternatives, as it was considered unlikely that alternatives would lead to notably different side effects. This was in reliance of Planning Practice Guidance (PPG) paragraph 009 Reference ID: 11-009-20140306, which states:
"The sustainability appraisal should only focus on what is needed to assess the likely significant effects of the plan."
4.2 We consider that the conclusions as to the effects of the Focused Changes, particularly in respect of the 'Housing' objective as stated within the Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report October 2019 (SA) clearly demonstrate that reasonable alternatives should have been considered.
4.3 The SA states that there will be 'uncertain negative implications' for the achievement of the 'Housing' objectives.4 This is on the basis that the housing has been reduced in areas where needs are likely to be highest, and, has been moved to Dunton Hills Garden Village (DHGV), potentially increasing the risk of not delivering the housing requirement. It also makes reference to the higher LHN figure. In comparison, the PSLP, prior to the Focussed Changes, was assessed as likely to have 'significant positive effects' on the basis of ability to meet the LHN and provide for specialist accommodation.
4.4 In our previous representations to the Regulation 19 consultation, we disputed this conclusion and the ability of the plan to deliver specialist accommodation. A number of concerns were received from respondents to the Regulation 19 consultation as to the effectiveness of the Plan to meet the needs of older people, which should have prompted the Council to review the strategy in this regard as part of the Focussed Changes. The Site (reference 073) has consistently been promoted for specialist accommodation for older people, to meet a locally identified need within Mountnessing, as detailed in our previous representations, and represents a missed opportunity. Not only would this help to address a locally identified need, it would also enable delivery in the early years of the plan period; two concerns that were prevalent in the responses to the Regulation 19 consultation. This further supports the argument that reasonable alternatives to the Focussed Changes should have been considered.
4.5 Despite this, the SA then goes onto conclude that the assessment of the PSLP against the housing objective (significant positive effects) 'broadly holds true' for the Focussed Changes (uncertain negative effects). This is clearly not the case, and it is considered that this conclusion is both incorrect and misleading.
4.6 It is considered that the change from 'significant positive effects' (PSLP) to 'uncertain negative implications' (Focussed Changes) in achieving the 'Housing' objective amounts to a significant effect of the Focussed Changes. Therefore, in accordance with the PPG (as referenced above), consideration should have been given to reasonable alternatives, and the definitive conclusion that alternatives would not have led to notably different side effects is unjustified. As a minimum, the Council should have considered reasonable alternatives to ascertain whether there was a more suitable strategy which would enable the Plan to meet its housing needs, thus enabling the Plan to achieve a more positive and beneficial outcome in respect of the 'Housing' objective. We consider this to be fundamentally important to ensuring a sound Local Plan.
4.7 Given the decrease in housing within areas with the highest needs as raised in the SA, regard should have been had to allocating additional suitable sites to meet housing needs at a local level (which the plan failed to do prior to the Focussed Changes). This would help to address local housing requirements, including the provision of specialist accommodation, as well as providing a more substantial buffer over and above the increased LHN and help to minimise the risks associated with potential delays in delivery at DHGV; a concern that is highlighted in the SA.
4.8 Following from this, it would seem highly appropriate to consider settlements on key transport corridors such as Mountnessing, that contain sites that scored better than many of the allocated sites in the SA such as Site 073 (Land adjacent to Mountnessing Primary School), that could deliver housing to meet identified local needs within the first 5 years of the Plan, before choosing, what should be a last resort given the trajectory already discussed, increasing housing numbers at DHGV. Our representations to the previous Regulation 19 consultation contained evidence of local support via a social media consultation, which received 96 responses in total, all of whom were interested in a new build bungalow specifically for those aged 55 and over on the Site.5 Appendix B contains a summary of this. This demonstrates a locally supported site which is a suitable alternative to the Focussed Changes, yet one which has been overlooked.
4.9 The Plan has failed to consider alternative, suitable sites, to balance the reduction in housing numbers in the sites subject to the Focussed Changes when identifying suitable solutions to correct this.
5.0 Robustness of SLAA
5.1 We argued clearly within previous representations that the approach to assessing sites within the SA using the 'traffic light' scoring system was primitive, inconsistent and unjustified, which resulted in subjective and ill-informed conclusions. This is clearly shown in relation to the Site - land west of Crossby Close, Mountnessing, as shown below:
 the Site scored higher than many of the allocated sites, yet was not allocated due to 'potential highways access issues' despite previous representations confirming Essex County Council Highways have no objection to the access, and which agree with the proposed access strategy;
 the scoring system as to a Site's classification of agricultural land (criterion 17) the dataset for which, as confirmed in the SA, is described as 'of a poor resolution.' This resulted in some sites being scored 'red' or 'amber' when in fact they were brownfield or non-agricultural land. The Site was incorrectly assessed as 'amber' for this criterion, yet it has not been in agricultural use since the current owner's acquisition in 1995 (with evidence adduced as part of our response to the previous Regulation 19 consultation to support this);
5.2 This further demonstrates inconsistencies and inaccuracies within the site assessment process, which we consider fails to demonstrate that the Plan has been positively prepared. However, despite pointing these out, the Focussed Changes do not include any rectification of these errors, and instead has taken a selective and non-transparent approach to amend existing allocations in response to objections received in the previous Regulation 19 consultation. We consider that this should have formed part of the consideration of reasonable alternatives to the Focussed Changes, which, as discussed above, was unjustifiably overlooked by the Council, in preference for amending the evidence base to suit the desired outcome. As a result, the Plan is not justified and cannot be considered sound.
6.0 The Unclear Approach to R18, R19, R25 and R26
6.1. The Council has decided to reduce the densities on allocations R18, R19, R25 and R26 (Focussed Changes 2-5), citing a considerable number of representations raising concerns as to the suitability of the sites for the proposed densities as the justification.
6.2. In redistributing the housing numbers from the above allocations to DHGV, the large number of objections received during the previous Regulation 19 consultation in respect of DHGV, including from statutory consultees, have been ignored. Instead, the Focussed Changes have gone against a number of comments, which highlight the unrealistic delivery timetable, and the need for sites which can deliver in the early years of the Plan.
6.3. There were also objections received in respect of other allocations within the Plan, as well as comments in respect of omission sites, such as our response to that consultation, which sought to clarify inaccuracies about the Site within the site assessment and show that earlier concerns regarding the access arrangements had been addressed.
6.4. The Addendum of Focussed Changes explains that the total loss of 70 homes across the four aforementioned sites will be off-set by altering another allocation to increase the number of new homes provided at Dunton Hill Garden Village (Focussed Change 1). However, the addendum does confirm that the overall number of new homes will not be increased, merely that there will be a faster rate of delivery at Dunton Hills Garden Village, resulting in more dwellings being provided before 2033 than previously projected (resulting in fewer post-2033).
6.5. We have a number of concerns with the proposed approach to addressing the shortfall that Focussed Changes 2-5 necessitate by simply altering Dunton Hills Garden Village to deliver at a greater rate than previously calculated, and at just a fast enough rate to account for the shortfall created by the need to reduce the proposed capacities for site R18, R19, R25, and R26. The lack of clarity in how both the reduction and the increase have been justified is unhelpful in being able to comment on the justification for the Focused Changes.
7.0 Cross-boundary and Statutory Consultee Objections
7.1. Basildon Borough Council have objected to the DHGV allocation in its response to the previous Regulation 19 consultation, in which it raised concerns regarding the cross-boundary impacts of this site, questioning the soundness of the Plan in this respect. Similarly, Essex County Council also raised concerns in respect of the transport evidence base for DHGV. As part of the Focussed Changes, the Council have seemingly overlooked these comments, in the absence of any evidence to the contrary, seeking instead to direct more housing numbers to this allocation within the Plan period, and failing to consider any reasonable alternatives.
7.2. As for the key concerns raised, it is concerning that the site assessments undertaken to date have failed to identify the numerous cited issues raised by respondents. Notwithstanding the inaccuracies in the assessment of our Site (land west of Crossby Close, Mountnessing) as mentioned above and in detail in our response to the previous Regulation 19 consultation, this casts further doubt on the robustness and the overall accuracy of the site assessment process which underpins the allocations within the Plan. This also substantiates our previous concerns that the site assessment process was inadequate, and therefore potentially undermines the remaining allocations within the Plan, as it is unclear as to whether any significant objection was raised in relation to those through the previous Regulation 19 consultation.
8.0 Conclusion
8.1. We consider that the Plan remains unsound as a result of the Focussed Changes. The higher confirmed LHN has not been incorporated within the Plan, nor the effects of this on whether the Plan should identify a suitable buffer to provide flexibility to adapt to rapid change. The Plan is therefore failing to meet the requirements of the NPPF and failing to meet the identified need for the Borough. The Focussed Changes do not demonstrate that the Plan will be effective in meeting housing needs, given it seeks to re-direct housing delivery from the short-term to the later years of the Plan, further decreasing its ability to meet its needs early in the Plan period. This is particularly concerning given the results of the Housing Delivery Test for the Borough (2019).
8.2. The trajectory as set out in the Focussed Changes remains overly optimistic, with the concerns as to the effects of a slippage in delivery at DHGV raised forming part of the reason for the SA conclusions that the Focussed Changes will have 'uncertain negative effects' on the 'Housing' objective. We strongly disagree with the SA's further conclusions that the assessment of the PSLP against the 'Housing' objective (significant positive effects) 'broadly holds true' for the Focussed Changes (uncertain negative effects).
8.3. The decision to discount the need for consideration of reasonable alternatives is inconsistent with national policy, and unjustified. This is apparent from the SA conclusions (discussed above), and we are highly concerned that this has reduced the ability of the Plan to meet the housing needs of the Borough going forward. The Council should have considered the merits of identifying additional, suitable sites to deliver in the short-medium term, including those which provide specialist accommodation to meet an identified local need, such as the land west of Crossby Close (site 073). As discussed above and shown in Appendix B, this represents a suitable site with local support for specialist accommodation that has been overlooked.

Revise Allocation Total for Plan period as suggested.

INTRODUCTION
1.1 These Representations are submitted to Brentwood Borough Council (BBC) in response to the 'Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) Local Plan' and Brentwood Local Plan Pre-submission Document (February 2019) (henceforth referred to as 'the Consolidated Changes'). The addendum was published on Tuesday 15 October for consultation and will close on Tuesday 26 November 2019. These Representations have been prepared by GL Hearn, on behalf of Tesco. Tesco has a land interest at Sawyers Hall Farm (also referred to as Hopefield Animal Sanctuary) (site ref: 024a and 024b).
1.2 Firstly, please note that GL Hearn has on two previous occasions objected to the subdivision of the site (Sawyers Hall Farm) into two separate parcels. This has resulted in the site being subject to two separate site appraisals (please see Paragraph 2.46 'Representations to Brentwood Local Plan, dated 18/03/19' AND Paragraph 2.30 'Representations to Brentwood Draft Local Plan Proffered Site Allocation, dated 12/03/2018). The failure to resolve this matter and amend the Sustainability Appraisal Report (Consolidated) (October 2019) amounts to a failure to follow local plan preparation procedures. If BBC does not revise 'the Consolidated Changes' prior to resubmission, then GL Hearn asks that the appointed Inspector discharges his/her duty under Regulation 23 of the Town and Country Planning (Local Planning) (England) Regulations 2012 and recommends that BBC conducts a thorough and balanced assessment of the site, taking into account of the site's full potential for a housing allocation within the plan.
1.3 This document provides our commentary on the proposed 'Consolidated Changes' and accompanying 'Sustainability Appraisal Report Addendum' dated October 2019. The purpose of this report is to assess 'the Consolidated Changes' against the legal and procedural requirements as set out in the Planning and Compulsory Purchase Act 2004 (henceforth referred to as 'the Act'), Town and Country Planning (Local Planning)(England)(Amendment) Regulations 2012 (henceforth referred to as 'the Regulations') and the 'four tests' of 'soundness' as detailed in Paragraph 35 of the NPPF (2019). This report does not intend to repeat the arguments made from previous representations and therefore we ask that this report is read in conjunction with the representations made on 18/03/2019 (Regulation 19), 26/03/2016 (Draft Local Plan Regulation 18) and the representations on the 'Strategic Growth Options Consultation' submitted on 17/02/2015.
1.4 We argue that 'the Consolidated Changes' have not been prepared in accordance with legal and procedural requirements. The policies contained within the plan have not been positively prepared,
Representations to Brentwood Local Development Plan - Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation
19) (October 2019) Tesco Stores Ltd, Brentwood CM15 9BZ (FINAL)
GL Hearn Page 5 of 14
nor have they been justified, or if adopted would be effective in delivering enough housing to meet the Borough's Local Housing Needs (LHN). 'The Consolidated Changes' are not consistent with national policy. GL Hearn concludes that upon examination an Inspector would not find the plan 'sound'. The delay in adopting a 'sound' plan would very likely leave the Borough vulnerable to sporadic and unsustainable patterns of development and therefore we urge BBC to make early revisions before submitting the plan to the Secretary of State.
1.5 We advise BBC to rethink its proposed strategy which has over the course of three drafts increased housing allocations at Dunton Hills Garden Village (DHGV). The Draft Local Plan 2018 (Regulation 18) allocated 2,500 dwellings which increased [without justification] to 2,700 dwellings in February 2019 (Regulation 19). 'The Consolidated Changes' proposes to increase the allocation at DHGV to 2,770 dwellings despite previous objections. The SA Report Addendum (2019) identifies the following negative impacts relating to the spatial strategy:
* 'The Consolidated Changes' would lead to an increase in car movements through Brentwood Town Centre Air Quality Management Area (AQMA) (located 6km away) (Paragraph 2.2.5 of Sustainability Report Addendum, October 2019). It should be noted that concerns over congestion within the urban area was a key reason why the number of dwellings allocated at sites R18 & R19 had been reduced [by 20 and 30 dwellings respectively]. The evidence shows that the reallocation of 50 dwellings from the urban area to DHGV results in no net improvement to the levels of congestion or air quality within the urban area.
* 'The Consolidated Changes' would impact on the Government's plans to reduce roadside nitrogen dioxide concentrations along the A127 corridor (Paragraph 2.2.10 and 2.211 of Sustainability Report Addendum, October 2019),
* 'The Consolidated Changes' would have a greater impact on sensitive biodiversity assets (Paragraph 2.3.1) and cause "significant negative effects" on land with high performing landscape and Greenbelt attributes (Paragraph 2.10.4 - 2.10.5 of Sustainability Report Addendum, October 2019),
* 'The Consolidated Changes' would reallocate housing away from the Brentwood/Shenfield Urban Area where the demand for housing is greatest and where it is near existing community and transport infrastructure THEN direct 35% of the Boroughs housing allocation to a single 257 ha Greenfield site which is heavily dependent on the timing and delivery of expensive infrastructure. The spatial strategy presents a greater risk to the housing trajectory and this is discussed in section 2 below. (Paragraph 2.9.1 - 2.9.4 of Sustainability Report Addendum, October 2019).
Representations to Brentwood Local Development Plan - Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation
19) (October 2019) Tesco Stores Ltd, Brentwood CM15 9BZ (FINAL)
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FOCUSSED CHANGE 1: POLICY R01 (I): DUNTON HILLS GARDEN VILLAGE STRATEGIC ALLOCATION
National Planning Policy Context - Tests for 'Soundness'
2.1 We acknowledge the Council's adoption of the new higher LHN figure of 454 dwellings per annum (dpa). The requirement equates to 2,270 net dpa in years 1 to 5. Paragraph 73(c) of the NPPF (2019) dictates that where there has been a significant under delivery of housing over the previous three years BBC should include a 20% buffer (moved forward from years 6 to 15 in the plan period). To comply with the NPPF (2019) and for 'the Consolidated Changes' to be found 'sound' BBC must identify a supply of specific and deliverable sites for years 1 to 5 with a capacity for 2,725 net dwellings (545 dpa).
2.2 Appendix 1 'Schedule of Focussed Changes to Brentwood Pre-Submission Local Plan' of 'The Consolidated Changes' (Page 7) provides a breakdown of the site allocation for the plan period. The method used to calculate the 'Allocation Total' does not accord with the methodology stated in the NPPF (2019). Paragraph 22 of the NPPF (2019) states that Plans should look ahead over a minimum of 15 years from adoption and therefore the completions included for years 2016/17 and 2017/18 (363 net homes or 5% of the allocation total) should be discounted as the plan has not yet been adopted and is unlikely to be adopted until after 2021.
2.3 The 'Allocation Total' includes 926 net homes with extant permissions as of 01/04/2018. The NPPF (2019) Part (a), page 66 provides one such definition of deliverable: "sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years"
2.4 'The Consolidated Changes' does not mention when the extant permissions were granted therefore it is impossible to know when they will expire or likely be implemented. It would be reasonable to assume that most [if not all] 926 dwellings included within the extant permissions had been granted circa. 18 months prior to April 2018 (i.e. granted around October 2016). The expiration or implementation of all 926 dwellings should have occurred around October 2019. Since October 2019 precedes the adoption of the local plan then 926 dwellings should be discounted from the 'Allocation Total'. Unless BBC can provide evidence that the permissions for all 926 dwellings will still be extant at the point that the Local Plan is adopted then 926 dwellings should be discounted from the 'Allocation Total'.
Representations to Brentwood Local Development Plan - Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation
19) (October 2019) Tesco Stores Ltd, Brentwood CM15 9BZ (FINAL)
GL Hearn Page 7 of 14
2.5 Paragraph 70 of the NPPF (2019) states that windfall sites should only be included in the anticipated housing calculation if there is compelling evidence to suggest they are a reliable source of supply. Compelling evidence should be realistic having regard to (i) the strategic housing land availability assessment, (ii) expected future trends (iii) historic windfall delivery rates. Paragraph 4.17 of The Brentwood Local Plan Pre-submission Document (February 2019) and Housing and Economic Land Availability Assessment (2018) provides the basis for the projected supply of 410 dwellings on windfall sites. The allocation of windfall sites is based exclusively on past delivery records and has not had regard to either (i) land availability or (ii) the impact of future trends affecting the delivery of housing on windfall sites. In the absence of compelling evidence 410 dwellings should be discounted from the 'Allocation Total'.
2.6 Table 1 below provides a revised 'Allocation Total' for the plan period which correctly discounts (1) 'Completions 2016/2017/18' (2) 'Extant permissions' and (3) 'Windfall Allowances'. The Revised 'Allocation Total' in Table 1 has been formulated using the correct method defined in Paragraphs 22 and 70, and Page 66, Part (a) of the NPPF (2019).
[Table 1: see attachment]
2.7 Table 2 provides a revision to the housing trajectory for the plan period which appropriately commences in 2021/2020 [in line with the correct method defined in Paragraph 22 of the NPPF (2019)]. The delivery rates for DHGV has been reduced to reflect the likely rates of delivery for a strategic site of this kind. Based on empirical evidence undertaken by Savills on behalf of Barret Homes (see Urban Extensions - Assessment of Delivery Rates, October 2014) DHGV may only deliver up to 120 dpa. The figures contained in Table 2 below represents the highest expected yield pa. The expected delivery rate of up to 120 dpa is supported by observations of 78 urban extensions on greenfield sites. 32% of case studies had been located within the south east of England and are an accurate proxy for estimating expected housing delivery rates at DHGV. BBC has not provided any evidence to suggest that delivery rates will exceed 120 dpa and therefore the revised housing trajectory in table 2 should be 'material' when assessing the 5 year housing land supply and the overall 'soundness' of 'The Consolidated Changes'.
[Table 2: See attachment]
2.8 Short term: 'The Consolidated Changes' must identify a supply of specific and deliverable sites capable of providing 545 dpa in years 1 to 5. Table 1 demonstrates that the Plan would fall short in meeting LHN in years 1 and 2 by a significant margin (-429 and -274 dwellings respectively).
2.9 Long term: 'The Consolidated Changes' would fall short in allocating a suitable number of housing sites over the plan period by 3,177 dwellings (see Table 2).
Local Plan Legal Compliance
Significant cross boundary impacts
2.10 Section 33A of the Act and Paragraph 24 of the NPPF (2019) imposes a duty on BBC to cooperate with adjoining Local Authorities on issues that would have significant and/or cross boundary impacts on other areas. The duty imposed on BBC requires constructive and active engagement on an on-going basis. Cooperation between adjoining Local Authorities must take place before 'The Consolidated Changes' are submitted to the Secretary of State for examination.
2.11 DHGV is located within close proximity to the administrative boundaries of Basildon and Thurrock Council. Both Councils have objected to the allocation of 2,700 homes in previous consultations. The objections raised are very likely to intensify following the allocation of an additional 70 homes at DHGV. Basildon Council made the following objection during the March 2019 (Regulation 19) consultation:
"Basildon Council would like to seek assurances written into Policy R01(II) that it will be invited by Brentwood Council to become more involved in the detailed design and delivery of the new village.
This will ensure that the strategic and cross-boundary impacts covered by the Duty to Cooperate and raised during the Council's response to the Plan at Regulation 18 and 19 stages are managed effectively during the development's implementation stages (assuming it is considered sound), alongside the Basildon Borough Local Plan's own implementation. Delivery of DHGV will commence in 2022/23 at a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within Green Belt, requires masterplanning and will need to go through a planning application and elements of the condition discharge process before development can commence.
No evidence is provided as to how the housing trajectory has been developed. No evidence or any form of a development framework/ masterplan for DHGV explains how the proposed accelerated rate of delivery will be possible. The Plan and the Transport Assessment fails to investigate the possible impacts on Basildon's road and rail infrastructure arising from commuters or other road users choosing to access facilities within the Basildon Borough instead.
The need for new connections into Basildon was not mentioned as being necessary to make it sustainable. No evidence was present to demonstrate that DHGV's growth demands have been evaluated in combination with the projected demands from Basildon Local Plan. The Plan should not assume that such growth can just be absorbed by the nearby infrastructure and services in Basildon and investment through developer contributions".
2.12 Details of the other objections from neighbouring Local Authorities have been reproduced in Box 2.2, on page 9 of the SA Report Addendum (October 2019).
2.13 The objections from Basildon and Thurrock Council are clear indicators that there has been insufficient engagement with adjoining Local Authorities over important cross boundary issues. 'The Consolidated Changes' should not be adopted until all concerning Local Authorities have discharged their duties to cooperate [in addressing all the issues relating to DHGV] as required by the Act and NPPF (2019).
Unmet housing need
2.14 BBC confirm that adjoining Local Authorities are unwilling and unable to take any identified housing need from the Borough.
CONCLUSION
3.1 We therefore conclude that additional work is still required in order to make the 'The Consolidated Changes' 'sound' and legally compliant. BBC must increase the number of allocations for housing in sustainable locations and preferably near the urban area. BBC must address the Boroughs' short-term housing needs (5 year housing land supply) and long-term LHN for the entirety of the plan in order to be considered 'sound'. Therefore to address this matter we recommend that the Sawyers Hall Farm site (ref: 024a and 024b) is allocated as this site is available for development now. Table 2 (above) provides a 'best case' housing forecast and shows the greatest housing shortfall in years 1 and 2. Any delay in implementing DHGV in line with the revised housing trajectory (see table 1 and 2) would result in housing shortfalls in years 3 to 5 and potentially the remainder of the plan period. The planning for DHGV will require a substantial amount and the timely delivery of new infrastructure to address the impact of development and overcome the objections raised by consultees and adjoining Local Authorities. We have demonstrated categorically that the implementation of DHGV will not correspond to the Council's own housing trajectory. The Sawyers Hall Farm site would support the delivery of up to 450 new homes in years 1 and 2 and would contribute significantly towards helping BBC meet its local development needs and preparing a 'sound' Local Plan for timely adoption.
3.2 This report highlighted the risks posed by the current strategy in meeting the LHN over the period of the plan. 'The Consolidated Changes' have not been prepared in accordance with legal and procedural requirements set out in the Act and NPPF (2019). The policies contained within the plan have not been positively prepared, nor have they been justified, or if adopted would be effective in delivering enough housing to meet the Borough's Local Housing Needs (LHN). GL Hearn concludes that the plan [if not changed in accordance with recommendation to increase housing allocation closer to the urban area) would not be found 'sound' by the appointed Inspector.

In order to address the soundness issues we consider that the housing target should be reviewed with regard to the new evidence and that further sources of land supply should be identified, not only to deal with shortfalls over the plan period in total, but also specifically within its first 10 years. Land to the north of West Horndon railway station is available, suitable and deliverable and can contribute to meeting this shortfall. Importantly, it can come forward independently of the wider area of growth being promoted by EASL to the south of the settlement (in Thurrock Borough). The Brentwood Local Plan needs to seriously consider early delivery to ensure the Plan provides sufficient housing for Five Year Housing Land Supply, and for years 5 - 10. Early delivery of West Horndon would assist DHGV coming forward as it would act as a catalyst for housing delivery in this area of Brentwood and enhance the attractiveness of DHGV from a purchaser's perspective. It would also help a Local Plan inspector determine that Brentwood's Local Plan is sound; as is self-evident from the present draft of the Local Plan that Brentwood's ability to meet its housing needs is inextricably linked with the release of Green Belt land, primarily at DHGV. The failure to adopt a local plan would not only result in Brentwood being unable to address its housing needs, it would deprive DHGV of the policy context in which to come forward as a planning application proposal, thereby exacerbating the deficit. We had previously set out in the West Horndon Delivery Statement (Appendix 1 to our March 2019 representations) that the site could deliver first completions by 2024. This would mean that significant numbers of homes could be delivered within the first 5 - 10 years of the plan period helping to address the soundness issues identified. We trust these representations clarify our position and that they are taken into consideration in the advancement of the Local Plan.

I write on behalf of my client, Estates and Agency Strategic Land (EASL), in relation to the aforementioned consultation. This submission follows previous representations we have submitted, most recently to the Pre-Submission Local Plan (Regulation 19) in March 2019. EASL is promoting land west of Thorndon Avenue, West Horndon which constitutes the most sustainable undeveloped site in Brentwood Borough given its proximity to West Horndon railway station (one of just four stations in the Borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads. There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. In fact, the evidence supports the allocation of this site, particularly to assist with housing delivery in the early years of the Plan period. For information, EASL is also promoting land to the south of the railway line, which largely defines the existing community of West Horndon. This land, which lies within the administrative area of Thurrock, has been identified as a potential location for a new settlement in the Issues and Options Draft (Regulation 18) Thurrock Local Plan. EASL is therefore uniquely placed to contribute to the transformational change of land within the environs of West Horndon railway station, both to the benefit of Brentwood Borough and Thurrock. These representations raise the following matters for consideration - * The proposed modifications are further delaying the delivery of housing until later in the Plan period pushing out 70 dwellings from Years 7 - 9 to Years 15 - 17. While this is a modest number of homes it demonstrates the significant challenge the Council is facing in the delivery of housing in the early years of the Plan period; * The SA accompanying the Consultation states that the Local Housing Need (LHN) figure has increased from 350 to 454 dwellings. The Consultation does not provide any evidence to demonstrate what this figure is based on, albeit it is closely related to the capped standardised method for the Borough of 452 dwellings. However, the PPG requires the Planning Authority to seek to meet the uncapped figure, which in the case of Brentwood would require the delivery of 469 dwellings per annum. Moreover, the Council has failed to consider the increased housing figure that will occur as a result of Crossrail's opening, which it is estimated will give rise to an additional need of 1,000 dwellings over the Plan Period; In terms of housing supply the Pre-Submission Plan is seeking to deliver just a 1% buffer on top of the minimum LHN of 454 dwellings. The Sustainability Appraisal accompanying the Consultation warns against this approach, stating that there is an over reliance on Dunton Hills Garden Village for housing delivery "which leads to an increased degree of risk in respect of delays to delivery (the very reason why a buffer over-and-above the housing requirement is appropriate;" * The Focused Consultation demonstrates that it is imperative that the Council consider the allocation of additional sites. Land at West Horndon is available, suitable and deliverable and can contribute to meeting this shortfall. The land does not require any significant infrastructure and therefore can come forward in the early part of the Plan period to assist the Council in meeting its short to medium term housing needs. The changes put forward by Brentwood Council primarily seek to address the projected reduction in developable capacity of four site allocations, equating to a reduction of some 70 units (Policy Allocations R18, R19, R25 and R26). The Council seek to offset this loss by allocating 70 additional units within the Dunton Hills Garden Village Strategic Allocation (Policy R01(I)). We consider, not only are these changes unsound but that they also highlight and exacerbate the previous soundness concerns we had raised with the Local Plan by placing too much emphasis on Dunton Hills Garden Village (GC) to meet a large majority of the identified housing need in the Borough. The Housing Trajectory set out at Appendix 1 of the Addendum document (proposed amendment 13) identifies that the 70-unit reduction across the four sites reduces supply across years (7 - 9) 2022/23 - 2024/25 of the Plan i.e. within the first 10 years of the plan period. However, the replacement of these units comes at the back end of the plan period through the Dunton Hills GC allocation; between 2030/31 - 2032/33 (years 15 - 17 of the plan). We further note that there is an error in the 'allocation total' row on page 14 of the consultation document. The totals in rows 'year 12' and 'year 13' have been incorrectly increased by a total of 20 units whereas this increase should occur in row 'year 17' taking account of the numbers in the table above this. We are concerned with the approach of delaying much needed housing to the latter years of the plan period as this approach is contrary to national policy. The National Planning Policy Framework 2019 (NPPF), at paragraph 67, requires that local plans should identify a sufficient supply of specific, deliverable sites for years one to five; and specific, developable sites or broad locations for growth for years 6-10 and, where possible, for years 11-15 of the plan. Therefore, the NPPF clearly advocates an approach of securing housing delivery in the early part of the plan period. If the Council were to consider that the available delivery from allocated sites were to reduce by 70 units within the Plan's first 10-years, then in order to support soundness, the focus must be on replacing these units with the same initial 10-year period and not delaying this to years 15-17. The rationale for the increase of 70 units at Dunton Hills GC is set out in paragraph 5 of the Addendum of Focused Changes document. This explains that the total capacity of the site is 4,000 units (with 2,500 units of these to be delivered within the plan period). As such bringing forward additional units within the period will require a faster rate of delivery. The Addendum of Focused Changes document does not however, provide any evidence of how these faster rates can be facilitated. The only reference to justifying the uplift is provided in the Sustainability Appraisal (SA) Report Addendum (October 2019), which states at paragraph 2.9.3: "discussions between the Council and the site promoter have served to indicate that the 70 homes additionally assigned to the site through the Focussed Changes are deliverable within the plan period, and indeed can be delivered in a timely fashion such that the Local Plan housing delivery trajectory is unaffected". No further information is provided as to where the additional units would fall within the phasing of the development and as such, we raise issue with the insufficient evidence to support this increase. In addition to the redistribution of 70 dwellings, the Sustainability Appraisal (SA) (October 2019) has confirmed that the Local Housing Need has increased to 454 dwellings per annum. The SA states that there are updates to the evidence-base since January 2019, including the new higher Local Housing Need (LHN) figure for Brentwood Borough, which is 454 dwellings per annum. 452 is the minimum figure identified in the Government standardised method, the starting point as it were for assessing the housing requirement for the Borough as detailed in Table 1 (see attached). It is unclear whether the Local Planning Authority intend to amend the Pre-Submission Local Plan to take account of the revised LHN figure - this would appear to be a prerequisite since the housing need section, and specifically section 4.11 onwards, is predicated on a LHN figure of 350. The Local Plan needs to be updated to state that the 452 new households is the minimum LHN figure. Moreover, there does not appear to be any additional evidence supporting this consultation which justifies the LHN figure. As detailed in the EASL representations on the Pre-Submission Plan (March 2019), the minimum local housing need figure is however influenced by a cap. The uncapped housing need for Brentwood is for 469 dpa (as shown in Table 1 above). Over the 17 year plan period this would equate to a need for 7,973 dwellings. Para 2a-007-20190220 in the Planning Practice Guidance (PPG) states that: "The cap reduces the minimum number generated by the standard method, but does not reduce housing need itself. Therefore strategic policies adopted with a cap applied may require an early review and updating to ensure that any housing need above the capped level is planned for as soon as is reasonably possible. Where the minimum annual local housing need figure is subject to a cap, consideration can still be given to whether a higher level of need could realistically be delivered. This may help prevent authorities from having to undertake an early review of the relevant policies." The actual (or full) level of housing need shown by the standard method is therefore 7,973 dwellings. This is 220 dwellings above the housing requirement in the Plan. The PPG is clear that consideration should be given to whether this level of housing need can realistically be delivered. Moreover, as detailed in full in our previous set of representations, the Council has failed to take into account the increased housing figure as a result of Crossrail's opening, which it is estimated will give rise to a need of 1,000 dwellings over the Plan period. Land at West Horndon is available, suitable and deliverable and can contribute to meeting this shortfall. The land does not require any significant infrastructure and therefore can come forward in early part of the Plan period to assist the Council in meeting the short to medium term housing needs. The Pre-Submission Local Plan detailed the need to provide for a 'buffer' over-and-above LHN (identified in the Sustainability Appraisal as 454 dpa) in order to ensure a robust housing supply trajectory (recognising the risk of unanticipated delays to deliver at one or more sites). The Focused Changes confirms that the Council will not be providing a buffer and instead only to meet the minimum housing requirement. The housing supply is detailed further below. Policy SP02 in the Pre-Submission Plan makes provision for 7,752 new dwellings over the 17 year plan period 2016-33. This is equivalent to 456 dwellings per annum. It thus marginally exceeds the capped standard method figure by less than 1%. Effectively it aligns with the minimum need figure.
The Council is also proposing to delay the delivery of housing in the early years with a stepped trajectory to provide 310 dpa to 2023 and a higher target of 584 homes per year thereafter. Totalling 7,752 units over the plan period 2016-2033 (paragraphs 1.16 - 1.21 of the Local Plan). For the reasons given we considered these figures should be treated as minimums as the actual (or full) level of housing need shown by the standard method is 7,973 dwellings. This is 220 dwellings above the housing requirement in the Plan which demonstrates that the Council need to allocate additional sites. As a result of the stepped trajectory and the increased LHN, the Local Plan will not meet the LHN figure of 454 until 2024. All of the above seeks to further exacerbate the soundness issues we had previously raised regarding the Local Plan and its level of proposed housing delivery. Clearly, the reduction of 70 units from the first 10 years of the plan period further undermines its soundness. The SA undertaken is critical of the proposed changes stating that it causes greater uncertainty. The Council's SA states at Para 9.9.11 that: "...to concentrate housing at DHGV to a greater extent, potentially leading to a degree of increased risk in respect of delivering the Borough-wide housing requirement, has uncertain negative implications for the achievement of 'Housing' objectives." The SA emphasises the proposed changes increases the level of uncertainty stating that - "On this basis, the conclusion reached in January 2019 in respect of the Pre-submission Plan (see para 9.9.10) broadly holds true for the Pre-submission Plan plus Focussed Changes. However, this conclusion is now associated with a greater degree of uncertainty. First and foremost, this is on the basis that LHN, and therefore the annual housing requirement, is now understood to equate to 454 dpa, such that the proposed supply figure of 456 dpa can no longer be said to put in place a significant 'buffer' over-and-above the housing requirement. Secondly, the Focussed Changes will result in the housing supply being focused at DHGV to a greater extent, which leads to an increased degree of risk in respect of delays to delivery (the very reason why a buffer over-and-above the housing requirement is appropriate), albeit this risk is uncertain and may be marginal". (Our emphasis)
The SA previously assessed a range of alternatives in order to deliver the Council's housing requirement. Given that the LHN figure has altered significantly, it is considered that a fresh assessment of the alternatives should be undertaken in order to ascertain whether a more proactive and positive strategy for accommodating housing growth in the Borough can be identified. The assessment of the alternative options on a LHN figure of 350 dwelling is now simply irrelevant. In this regard, it is important to understand the respective merits of sites options through the SA process. For example, we have previously raised, in our representations to the Brentwood Local Plan Sustainability Appraisal (SA)(March 2019), that there were a number of identified effects within the SA we disagreed with. Our alternative assessment for West Horndon stated, with respect to air quality: "The spatial development strategy for the Brentwood Local Plan should seek to limit traffic through existing Air Quality Management Areas (AQMAs), which are primarily located along the A12 in proximity to Brentwood. From this perspective, development at West Horndon should be considered the preferred option. Growth in this location will be in proximity to an existing train station, thereby minimising the need for car travel, as well as resulting in improvements to the village centre to improve facilities for residents. As such, no significant negative effects in relation to air quality are anticipated." We further consider that locating growth in inherently sustainable locations, such as at West Horndon, is important to consider in the context of wider air quality matters including, air quality management of the A127. In order to address the soundness issues we consider that the housing target should be reviewed with regard to the new evidence and that further sources of land supply should be identified, not only to deal with shortfalls over the plan period in total, but also specifically within its first 10 years. Land to the north of West Horndon railway station is available, suitable and deliverable and can contribute to meeting this shortfall. Importantly, it can come forward independently of the wider area of growth being promoted by EASL to the south of the settlement (in Thurrock Borough). The Brentwood Local Plan needs to seriously consider early delivery to ensure the Plan provides sufficient housing for Five Year Housing Land Supply, and for years 5 - 10. Early delivery of West Horndon would assist DHGV coming forward as it would act as a catalyst for housing delivery in this area of Brentwood and enhance the attractiveness of DHGV from a purchaser's perspective. It would also help a Local Plan inspector determine that Brentwood's Local Plan is sound; as is self-evident from the present draft of the Local Plan that Brentwood's ability to meet its housing needs is inextricably linked with the release of Green Belt land, primarily at DHGV. The failure to adopt a local plan would not only result in Brentwood being unable to address its housing needs, it would deprive DHGV of the policy context in which to come forward as a planning application proposal, thereby exacerbating the deficit. We had previously set out in the West Horndon Delivery Statement (Appendix 1 to our March 2019 representations) that the site could deliver first completions by 2024. This would mean that significant numbers of homes could be delivered within the first 5 - 10 years of the plan period helping to address the soundness issues identified. We trust these representations clarify our position and that they are taken into consideration in the advancement of the Local Plan.

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its commercial assets at Eagle Way, Warley, Brentwood (the Site'). Iceni has been instructed by Ford to prepare and submit comments on the 'focused changes' to the pre-submission' Local Plan (2019) consultation.
On behalf of our Client, we welcome the opportunity to comment the Addendum of Focussed Changes to the Pre-Submission Local Plan ('AFC' October 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. It is noted that Ford have submitted representations to each stage of consultation to date, including promotion of the site for housing and delivery in the earliest years of the plan period.
We therefore assert that this stage of consultation should consider comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2019) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy.
Our Client is broadly supportive of the Site's Draft allocation as a strategic site for housing under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness, we wish to question the below aspects of the draft allocation (in the absence of robust evidence) and the inclusion of the site within years 9-17 of the Housing Trajectory as shown
in Appendix 1 of the AFC (versus years 6-10):
* Retention of 2.0 hectares of employment land - Land south of Eagle Way (i.e. main Ford Headquarters);
* Delivery of residential care home providing 60 x bed spaces; and
* 5% self-build and custom build across the entire allocation (including the Council Depot).
This is contrary to the fundamental sustainability objectives of the NPPF and all previous representations submitted by Ford, demonstrating the early deliverability and availability of the Site in providing much needed housing for the Borough - at a brown field location. Our Client therefore considers that the current plan has failed to be positively prepared and should therefore be reviewed prior to Examination in public.
This representation is submitted in line with the consultation deadline of Tuesday 26th November 2019.
a. The Site
Location / Description
The Site comprises of 8.51 hectares (21.03 acres) of land located within Warley, forming the southern edge of the Brentwood settlement boundary. It is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway.
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 council-owned land which is currently being utilised as additional car parking, as well as the highways depot and auto garage known as Council Depot. Located adjacent to the east is the Marillac nursing home and to the west there is a local centre with retail and commercial uses, beyond which there are predominantly residential uses.
* '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. The southern parcel is bounded by woodland and Warley Gap to the south, Clive Road to the west, Eagle Way to the north and woodland to the east. There are two dwellings located within 70m south of the site, with the Essex Regiment Chapel and Royal Anglian Regiment being located to the west.
b. Response to AFC Consultation
Amended Housing Trajectory
In line with Ford's previous representations, we wish to request that the draft allocation for the Site within the next stage of the new Local Plan is updated to reflect the Site's anticipated availability earlier in the Plan period. Notably, it is realistic that the site could be delivered within 6 -10 years (2021-2025) versus the 9 -17 years (2025-2033) (currently stated in Appendix 1 of the AFC). The HELAA 2018, presented data in table 2 which indicated that the potential new housing trajectory for the borough would be brought forward on brownfield sites within the early years in the Plan.
All potential options should be explored in detail to increase the supply of housing in the early years. We therefore request that BBC review and update the Site's inclusion in the housing trajectory, including considering the Ford owned and Council Depot sites separately (see further comments below) - bringing forward the Ford owned land in years 6-10 (which Ford have demonstrated is available and deliverable). In our opinion this is necessary in order to ensure the Plan is positively prepared, having regard to the requirements of Paragraph 35 of the NPPF 2019.
We maintain that the BBC's proposed phased approach to the annual housing requirement, may not deliver sufficient quantum of housing within the early years of the Plan following adoption. As such we consider that this approach would be unsound, as the Plan would not be positively prepared in this regard, unless clear evidence can be provided to demonstrate that all potential options to boost housing supply in the early years of the Plan have been explored in detail.
The Ford site is already identified by BBC as a proposed allocation and will make a vital contribution towards the anticipated trajectory in this context, particularly as a less constrained medium scale site. However, we consider that the further efforts should be made to ensure the capacity for the site to deliver housing on brownfield land early in the plan period are maximised, in order to ensure that the annual requirement is sound.
Draft Policy R04 and R05: Ford Headquarters and Council Depot
Ford notes that the current draft policy includes the Warley Site under draft 'Site Allocation R04' (Land South of Eagle Way)' and 'Site Allocation R05' (Land North of Eagle Way)' (collectively referred to as
3
the 'Ford Headquarters and Council Depot, Warley for housing and employment development, with the potential for specialist care accommodation (referred to as 'Other Indicative uses').
The draft allocation sets out that sites R04 and Ro5 have a collective site area of 9.4 hectares (ha) of which, 8 ha is developable; with an indicative dwelling yield (net) of 473 residential units across the two sites. The allocations are currently anticipated by BBC to come forward within years 9-17 of the proposed plan period. The Ford owned land can be delivered in the early years of the plan period and we would challenge the proposed housing trajectory for the site as outlined in Appendix 1: Schedule of Focussed Changes to Brentwood Pre-Submission Local Plan (October 2019).
Ford remains broadly supportive of the strategic housing allocation but recognises that the current pairing of the Headquarters and the Depot has potential to limit the delivery of the site in the short to medium term. We are aware that the Depot currently has no scheduled availability date at this stage and its employment function will need to be moved elsewhere in the Borough. In the interest of early delivery, we are proposing that the Northern Land parcel (R05) is separated from the Southern parcel (R04), enabling the site to come forward for housing in the early years of the plan period. This is supported through Ford providing certainty over the future availability of the Site as part of the headquarters relocation and long standing, open engagement with BBC - in addition to formal representations to all previous consultations to the emerging Local Plan.
The need for BBC to identify additional land for housing is also required in order 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 undoubted 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 development, with the Site at Warley providing a key brownfield opportunity for much need new housing.
We consider the Ford Warley Site to the be a highly deliverable site, available for housing development. The NPPF (2019) is clear in stating that "to be considered deliverable, sites should be available now, offer a suitable location for development, and be achievable with a realistic prospect that housing will be delivered on site within five years." The current plan, its Housing Trajectory and inclusion of the Ford site should be updated in line with this national requirement.
c. Summary
We trust that this letter provides further information to inform amendments to the Pre-submission Local Plan 2019. We request that the housing trajectory is updated to reflect the early delivery of new housing at the Site within plan period years 6-10. Our Client would welcome discussing this in further detail with BBC, prior to the Pre-submission Local Plan (2019) being submitted to the Secretary of State. Should you have any questions please do not hesitate to contact me (agale@iceniprojects.com) or my colleague Lucy Howes (lhowes@iceniprojects.com).

The Ford site is identified by BBC as a proposed allocation and will make a vital contribution towards the anticipated trajectory in this context, particularly as a less constrained medium scale site. However, we consider that the further efforts should be made to ensure the capacity for the site to deliver housing on brownfield land early in the plan period are maximised, in order to ensure that the annual requirement is sound.

Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its commercial assets at Eagle Way, Warley, Brentwood (the Site'). Iceni has been instructed by Ford to prepare and submit comments on the 'focused changes' to the pre-submission' Local Plan (2019) consultation.
On behalf of our Client, we welcome the opportunity to comment the Addendum of Focussed Changes to the Pre-Submission Local Plan ('AFC' October 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. It is noted that Ford have submitted representations to each stage of consultation to date, including promotion of the site for housing and delivery in the earliest years of the plan period.
We therefore assert that this stage of consultation should consider comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2019) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy.
Our Client is broadly supportive of the Site's Draft allocation as a strategic site for housing under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness, we wish to question the below aspects of the draft allocation (in the absence of robust evidence) and the inclusion of the site within years 9-17 of the Housing Trajectory as shown
in Appendix 1 of the AFC (versus years 6-10):
* Retention of 2.0 hectares of employment land - Land south of Eagle Way (i.e. main Ford Headquarters);
* Delivery of residential care home providing 60 x bed spaces; and
* 5% self-build and custom build across the entire allocation (including the Council Depot).
This is contrary to the fundamental sustainability objectives of the NPPF and all previous representations submitted by Ford, demonstrating the early deliverability and availability of the Site in providing much needed housing for the Borough - at a brown field location. Our Client therefore considers that the current plan has failed to be positively prepared and should therefore be reviewed prior to Examination in public.
This representation is submitted in line with the consultation deadline of Tuesday 26th November 2019.
a. The Site
Location / Description
The Site comprises of 8.51 hectares (21.03 acres) of land located within Warley, forming the southern edge of the Brentwood settlement boundary. It is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway.
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 council-owned land which is currently being utilised as additional car parking, as well as the highways depot and auto garage known as Council Depot. Located adjacent to the east is the Marillac nursing home and to the west there is a local centre with retail and commercial uses, beyond which there are predominantly residential uses.
* '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. The southern parcel is bounded by woodland and Warley Gap to the south, Clive Road to the west, Eagle Way to the north and woodland to the east. There are two dwellings located within 70m south of the site, with the Essex Regiment Chapel and Royal Anglian Regiment being located to the west.
b. Response to AFC Consultation
Amended Housing Trajectory
In line with Ford's previous representations, we wish to request that the draft allocation for the Site within the next stage of the new Local Plan is updated to reflect the Site's anticipated availability earlier in the Plan period. Notably, it is realistic that the site could be delivered within 6 -10 years (2021-2025) versus the 9 -17 years (2025-2033) (currently stated in Appendix 1 of the AFC). The HELAA 2018, presented data in table 2 which indicated that the potential new housing trajectory for the borough would be brought forward on brownfield sites within the early years in the Plan.
All potential options should be explored in detail to increase the supply of housing in the early years. We therefore request that BBC review and update the Site's inclusion in the housing trajectory, including considering the Ford owned and Council Depot sites separately (see further comments below) - bringing forward the Ford owned land in years 6-10 (which Ford have demonstrated is available and deliverable). In our opinion this is necessary in order to ensure the Plan is positively prepared, having regard to the requirements of Paragraph 35 of the NPPF 2019.
We maintain that the BBC's proposed phased approach to the annual housing requirement, may not deliver sufficient quantum of housing within the early years of the Plan following adoption. As such we consider that this approach would be unsound, as the Plan would not be positively prepared in this regard, unless clear evidence can be provided to demonstrate that all potential options to boost housing supply in the early years of the Plan have been explored in detail.
The Ford site is already identified by BBC as a proposed allocation and will make a vital contribution towards the anticipated trajectory in this context, particularly as a less constrained medium scale site. However, we consider that the further efforts should be made to ensure the capacity for the site to deliver housing on brownfield land early in the plan period are maximised, in order to ensure that the annual requirement is sound.
Draft Policy R04 and R05: Ford Headquarters and Council Depot
Ford notes that the current draft policy includes the Warley Site under draft 'Site Allocation R04' (Land South of Eagle Way)' and 'Site Allocation R05' (Land North of Eagle Way)' (collectively referred to as
3
the 'Ford Headquarters and Council Depot, Warley for housing and employment development, with the potential for specialist care accommodation (referred to as 'Other Indicative uses').
The draft allocation sets out that sites R04 and Ro5 have a collective site area of 9.4 hectares (ha) of which, 8 ha is developable; with an indicative dwelling yield (net) of 473 residential units across the two sites. The allocations are currently anticipated by BBC to come forward within years 9-17 of the proposed plan period. The Ford owned land can be delivered in the early years of the plan period and we would challenge the proposed housing trajectory for the site as outlined in Appendix 1: Schedule of Focussed Changes to Brentwood Pre-Submission Local Plan (October 2019).
Ford remains broadly supportive of the strategic housing allocation but recognises that the current pairing of the Headquarters and the Depot has potential to limit the delivery of the site in the short to medium term. We are aware that the Depot currently has no scheduled availability date at this stage and its employment function will need to be moved elsewhere in the Borough. In the interest of early delivery, we are proposing that the Northern Land parcel (R05) is separated from the Southern parcel (R04), enabling the site to come forward for housing in the early years of the plan period. This is supported through Ford providing certainty over the future availability of the Site as part of the headquarters relocation and long standing, open engagement with BBC - in addition to formal representations to all previous consultations to the emerging Local Plan.
The need for BBC to identify additional land for housing is also required in order 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 undoubted 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 development, with the Site at Warley providing a key brownfield opportunity for much need new housing.
We consider the Ford Warley Site to the be a highly deliverable site, available for housing development. The NPPF (2019) is clear in stating that "to be considered deliverable, sites should be available now, offer a suitable location for development, and be achievable with a realistic prospect that housing will be delivered on site within five years." The current plan, its Housing Trajectory and inclusion of the Ford site should be updated in line with this national requirement.
c. Summary
We trust that this letter provides further information to inform amendments to the Pre-submission Local Plan 2019. We request that the housing trajectory is updated to reflect the early delivery of new housing at the Site within plan period years 6-10. Our Client would welcome discussing this in further detail with BBC, prior to the Pre-submission Local Plan (2019) being submitted to the Secretary of State. Should you have any questions please do not hesitate to contact me (agale@iceniprojects.com) or my colleague Lucy Howes (lhowes@iceniprojects.com).

Request that BBC review and update the Site's inclusion in the housing trajectory, including considering the Ford owned and Council Depot sites separately (see further comments below) - bringing forward the Ford owned land in years 6-10 (which Ford have demonstrated is available and deliverable). In our opinion this is necessary in order to ensure the Plan is positively prepared, having regard to the requirements of Paragraph 35 of the NPPF 2019.

Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its commercial assets at Eagle Way, Warley, Brentwood (the Site'). Iceni has been instructed by Ford to prepare and submit comments on the 'focused changes' to the pre-submission' Local Plan (2019) consultation.
On behalf of our Client, we welcome the opportunity to comment the Addendum of Focussed Changes to the Pre-Submission Local Plan ('AFC' October 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. It is noted that Ford have submitted representations to each stage of consultation to date, including promotion of the site for housing and delivery in the earliest years of the plan period.
We therefore assert that this stage of consultation should consider comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2019) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy.
Our Client is broadly supportive of the Site's Draft allocation as a strategic site for housing under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness, we wish to question the below aspects of the draft allocation (in the absence of robust evidence) and the inclusion of the site within years 9-17 of the Housing Trajectory as shown
in Appendix 1 of the AFC (versus years 6-10):
* Retention of 2.0 hectares of employment land - Land south of Eagle Way (i.e. main Ford Headquarters);
* Delivery of residential care home providing 60 x bed spaces; and
* 5% self-build and custom build across the entire allocation (including the Council Depot).
This is contrary to the fundamental sustainability objectives of the NPPF and all previous representations submitted by Ford, demonstrating the early deliverability and availability of the Site in providing much needed housing for the Borough - at a brown field location. Our Client therefore considers that the current plan has failed to be positively prepared and should therefore be reviewed prior to Examination in public.
This representation is submitted in line with the consultation deadline of Tuesday 26th November 2019.
a. The Site
Location / Description
The Site comprises of 8.51 hectares (21.03 acres) of land located within Warley, forming the southern edge of the Brentwood settlement boundary. It is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway.
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 council-owned land which is currently being utilised as additional car parking, as well as the highways depot and auto garage known as Council Depot. Located adjacent to the east is the Marillac nursing home and to the west there is a local centre with retail and commercial uses, beyond which there are predominantly residential uses.
* '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. The southern parcel is bounded by woodland and Warley Gap to the south, Clive Road to the west, Eagle Way to the north and woodland to the east. There are two dwellings located within 70m south of the site, with the Essex Regiment Chapel and Royal Anglian Regiment being located to the west.
b. Response to AFC Consultation
Amended Housing Trajectory
In line with Ford's previous representations, we wish to request that the draft allocation for the Site within the next stage of the new Local Plan is updated to reflect the Site's anticipated availability earlier in the Plan period. Notably, it is realistic that the site could be delivered within 6 -10 years (2021-2025) versus the 9 -17 years (2025-2033) (currently stated in Appendix 1 of the AFC). The HELAA 2018, presented data in table 2 which indicated that the potential new housing trajectory for the borough would be brought forward on brownfield sites within the early years in the Plan.
All potential options should be explored in detail to increase the supply of housing in the early years. We therefore request that BBC review and update the Site's inclusion in the housing trajectory, including considering the Ford owned and Council Depot sites separately (see further comments below) - bringing forward the Ford owned land in years 6-10 (which Ford have demonstrated is available and deliverable). In our opinion this is necessary in order to ensure the Plan is positively prepared, having regard to the requirements of Paragraph 35 of the NPPF 2019.
We maintain that the BBC's proposed phased approach to the annual housing requirement, may not deliver sufficient quantum of housing within the early years of the Plan following adoption. As such we consider that this approach would be unsound, as the Plan would not be positively prepared in this regard, unless clear evidence can be provided to demonstrate that all potential options to boost housing supply in the early years of the Plan have been explored in detail.
The Ford site is already identified by BBC as a proposed allocation and will make a vital contribution towards the anticipated trajectory in this context, particularly as a less constrained medium scale site. However, we consider that the further efforts should be made to ensure the capacity for the site to deliver housing on brownfield land early in the plan period are maximised, in order to ensure that the annual requirement is sound.
Draft Policy R04 and R05: Ford Headquarters and Council Depot
Ford notes that the current draft policy includes the Warley Site under draft 'Site Allocation R04' (Land South of Eagle Way)' and 'Site Allocation R05' (Land North of Eagle Way)' (collectively referred to as
3
the 'Ford Headquarters and Council Depot, Warley for housing and employment development, with the potential for specialist care accommodation (referred to as 'Other Indicative uses').
The draft allocation sets out that sites R04 and Ro5 have a collective site area of 9.4 hectares (ha) of which, 8 ha is developable; with an indicative dwelling yield (net) of 473 residential units across the two sites. The allocations are currently anticipated by BBC to come forward within years 9-17 of the proposed plan period. The Ford owned land can be delivered in the early years of the plan period and we would challenge the proposed housing trajectory for the site as outlined in Appendix 1: Schedule of Focussed Changes to Brentwood Pre-Submission Local Plan (October 2019).
Ford remains broadly supportive of the strategic housing allocation but recognises that the current pairing of the Headquarters and the Depot has potential to limit the delivery of the site in the short to medium term. We are aware that the Depot currently has no scheduled availability date at this stage and its employment function will need to be moved elsewhere in the Borough. In the interest of early delivery, we are proposing that the Northern Land parcel (R05) is separated from the Southern parcel (R04), enabling the site to come forward for housing in the early years of the plan period. This is supported through Ford providing certainty over the future availability of the Site as part of the headquarters relocation and long standing, open engagement with BBC - in addition to formal representations to all previous consultations to the emerging Local Plan.
The need for BBC to identify additional land for housing is also required in order 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 undoubted 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 development, with the Site at Warley providing a key brownfield opportunity for much need new housing.
We consider the Ford Warley Site to the be a highly deliverable site, available for housing development. The NPPF (2019) is clear in stating that "to be considered deliverable, sites should be available now, offer a suitable location for development, and be achievable with a realistic prospect that housing will be delivered on site within five years." The current plan, its Housing Trajectory and inclusion of the Ford site should be updated in line with this national requirement.
c. Summary
We trust that this letter provides further information to inform amendments to the Pre-submission Local Plan 2019. We request that the housing trajectory is updated to reflect the early delivery of new housing at the Site within plan period years 6-10. Our Client would welcome discussing this in further detail with BBC, prior to the Pre-submission Local Plan (2019) being submitted to the Secretary of State. Should you have any questions please do not hesitate to contact me (agale@iceniprojects.com) or my colleague Lucy Howes (lhowes@iceniprojects.com).