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

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

Publication of the Policies Proposals Map to enable it to be consulted upon and to
provide context to the references to it within the draft Submission Plan.

The Plan is not legally compliant as not all submission documents required to form a
Local Plan, namely a Policies Map, have been produced during all the stages of
consultation. The Appendix 4 of the pre-submission, Regulation 19 Document identifies that the production of a new Policies Map will require changes to the 2005 Proposals Map. Maps setting out the changes to the Plan were stated to be published as part of the Regulation 19 but this has not happened. As such, the plan preparation and consultation process has not adhered to requirements in failing to publish all relevant documents for consultation. In particular, the adopted Replacement Local Plan (2005) identifies land within Protected Urban Open Space (PUOS), a matter addressed with Emerging Policy BE23. The policy makes specific reference to the Brentwood Policies Map in identifying such designated areas. "POLICY BE23: Open Space, Sport And Recreational Facilities 1. Within the borough's urban areas, permission will not be granted for development of land allocated on the Brentwood Policies Map as Protected Urban Open Space or Local Green Space unless it can be demonstrated..." However, in assessing open spaces position within the Borough, the Council rely on the Sport Leisure and Open Space Assessment, 2016, which considers the contribution sites with the PUOS designation make, assessed against three criteria: * Public Accessibility; * Recreational Value; and * Amount Value. Sites such as land at Playfield at Brentwood Ursuline (Sport Leisure and Open Space Assessment, 2016, Appendix 12, Site ID:19b) score very low against these criteria and, therefore, the justification for its retention within the PUOS designation does not exist. We have made representations on this land through the Local Plan Review process, including specific reference at the Call for Sites, 2009 and the Issues and Options Consultation 2013. More general comment has been made in respect at the Council's spatial strategy of focusing on the sequential use of land, which prioritises brownfield land first and then considers growth in settlements in terms of their relative sustainability, at the strategic Growth Options consultation 2015 and the Preferred Sites Allocation consultation 2018. These representations have identified the little contribution the site at the Ursuline Playing field (Site ID: 19b) makes to open space and the worthiness of removing it from the designation to allow for its potential development as a parcel in a central urban area and very well located to the town centre, the public transport network, public open space and other services. However, without having had the opportunity to view the new Policies Proposal Map at any stage during the consultation process, the designation of this piece of land is unknown and, thus, the ability to make detailed comments on such matters has been denied. In addition, the soundness of the Plan is brought into question where decisions made on the extent and location of designations, such as Protected Urban Open Space, have not been published. Thus, no judgement can be made as to whether such decisions/designations are justified and supported by the evidence base and whether
the Plan, in this respect, is sound. If it is the case that the PUOS designation remains unchanged from the 2005 Proposals Map, this position is not supported by the evidence base which scores the subject site (Site ID: 19b) very lowly against the assessment criteria. However, without confirmation in the form of a new Policies Map, this position is unclear and the Respondent is prejudiced by it. The Respondent in this case would wish to reserve the right to make representation on
the extent of the Protected Urban Open Space designation, as they see fit, once the
Policies Proposal Map has been made publically available.

Publication of the Policies Proposals Map to enable it to be consulted upon and to
provide context to the references to it within the draft Submission Plan.

The Plan is not legally compliant as not all submission documents required to form a
Local Plan, namely a Policies Map, have been produced during all the stages of
consultation. The Appendix 4 of the pre-submission, Regulation 19 Document identifies that the production of a new Policies Map will require changes to the 2005 Proposals Map. Maps setting out the changes to the Plan were stated to be published as part of the Regulation 19 but this has not happened. As such, the plan preparation and consultation process has not adhered to requirements in failing to publish all relevant documents for consultation. In particular, the adopted Replacement Local Plan (2005) identifies land within Protected Urban Open Space (PUOS), a matter addressed with Emerging Policy BE23. The policy makes specific reference to the Brentwood Policies Map in identifying such designated areas. "POLICY BE23: Open Space, Sport And Recreational Facilities 1. Within the borough's urban areas, permission will not be granted for development of land allocated on the Brentwood Policies Map as Protected Urban Open Space or Local Green Space unless it can be demonstrated..." However, in assessing open spaces position within the Borough, the Council rely on the Sport Leisure and Open Space Assessment, 2016, which considers the contribution sites with the PUOS designation make, assessed against three criteria: * Public Accessibility; * Recreational Value; and * Amount Value. Sites such as land at Playfield at Brentwood Ursuline (Sport Leisure and Open Space Assessment, 2016, Appendix 12, Site ID:19b) score very low against these criteria and, therefore, the justification for its retention within the PUOS designation does not exist. We have made representations on this land through the Local Plan Review process, including specific reference at the Call for Sites, 2009 and the Issues and Options Consultation 2013. More general comment has been made in respect at the Council's spatial strategy of focusing on the sequential use of land, which prioritises brownfield land first and then considers growth in settlements in terms of their relative sustainability, at the strategic Growth Options consultation 2015 and the Preferred Sites Allocation consultation 2018. These representations have identified the little contribution the site at the Ursuline Playing field (Site ID: 19b) makes to open space and the worthiness of removing it from the designation to allow for its potential development as a parcel in a central urban area and very well located to the town centre, the public transport network, public open space and other services. However, without having had the opportunity to view the new Policies Proposal Map at any stage during the consultation process, the designation of this piece of land is unknown and, thus, the ability to make detailed comments on such matters has been denied. In addition, the soundness of the Plan is brought into question where decisions made on the extent and location of designations, such as Protected Urban Open Space, have not been published. Thus, no judgement can be made as to whether such decisions/designations are justified and supported by the evidence base and whether
the Plan, in this respect, is sound. If it is the case that the PUOS designation remains unchanged from the 2005 Proposals Map, this position is not supported by the evidence base which scores the subject site (Site ID: 19b) very lowly against the assessment criteria. However, without confirmation in the form of a new Policies Map, this position is unclear and the Respondent is prejudiced by it. The Respondent in this case would wish to reserve the right to make representation on
the extent of the Protected Urban Open Space designation, as they see fit, once the
Policies Proposal Map has been made publically available.

Publication of the Policies Proposals Map to enable it to be consulted upon and to
provide context to the references to it within the draft Submission Plan.

The Plan is not legally compliant as not all submission documents required to form a
Local Plan, namely a Policies Map, have been produced during all the stages of
consultation. The Appendix 4 of the pre-submission, Regulation 19 Document identifies that the production of a new Policies Map will require changes to the 2005 Proposals Map. Maps setting out the changes to the Plan were stated to be published as part of the Regulation 19 but this has not happened. As such, the plan preparation and consultation process has not adhered to requirements in failing to publish all relevant documents for consultation. In particular, the adopted Replacement Local Plan (2005) identifies land within Protected Urban Open Space (PUOS), a matter addressed with Emerging Policy BE23. The policy makes specific reference to the Brentwood Policies Map in identifying such designated areas. "POLICY BE23: Open Space, Sport And Recreational Facilities 1. Within the borough's urban areas, permission will not be granted for development of land allocated on the Brentwood Policies Map as Protected Urban Open Space or Local Green Space unless it can be demonstrated..." However, in assessing open spaces position within the Borough, the Council rely on the Sport Leisure and Open Space Assessment, 2016, which considers the contribution sites with the PUOS designation make, assessed against three criteria: * Public Accessibility; * Recreational Value; and * Amount Value. Sites such as land at Playfield at Brentwood Ursuline (Sport Leisure and Open Space Assessment, 2016, Appendix 12, Site ID:19b) score very low against these criteria and, therefore, the justification for its retention within the PUOS designation does not exist. We have made representations on this land through the Local Plan Review process, including specific reference at the Call for Sites, 2009 and the Issues and Options Consultation 2013. More general comment has been made in respect at the Council's spatial strategy of focusing on the sequential use of land, which prioritises brownfield land first and then considers growth in settlements in terms of their relative sustainability, at the strategic Growth Options consultation 2015 and the Preferred Sites Allocation consultation 2018. These representations have identified the little contribution the site at the Ursuline Playing field (Site ID: 19b) makes to open space and the worthiness of removing it from the designation to allow for its potential development as a parcel in a central urban area and very well located to the town centre, the public transport network, public open space and other services. However, without having had the opportunity to view the new Policies Proposal Map at any stage during the consultation process, the designation of this piece of land is unknown and, thus, the ability to make detailed comments on such matters has been denied. In addition, the soundness of the Plan is brought into question where decisions made on the extent and location of designations, such as Protected Urban Open Space, have not been published. Thus, no judgement can be made as to whether such decisions/designations are justified and supported by the evidence base and whether
the Plan, in this respect, is sound. If it is the case that the PUOS designation remains unchanged from the 2005 Proposals Map, this position is not supported by the evidence base which scores the subject site (Site ID: 19b) very lowly against the assessment criteria. However, without confirmation in the form of a new Policies Map, this position is unclear and the Respondent is prejudiced by it. The Respondent in this case would wish to reserve the right to make representation on
the extent of the Protected Urban Open Space designation, as they see fit, once the
Policies Proposal Map has been made publically available.