The plan would be positively prepared if it stated support for a foodstore on Site R15 of a scale and type that could address the need identified in the evidence base.
Lidl proposes also that Policy R15 be revised to explain that the eventual number of dwellings on the site will be determined having regard to the expectation that it will also accommodate a foodstore to meet a proportion of the retail need set out in Policy PC07, but that it is expected to be able to accommodate up to 80 units within Use Classes C2 or C3.

Lidl GB Ltd is the owner of Site R15 and is promoting its mixed use redevelopment for a foodstore and residential use, in accordance with draft Policy R15. Lidl will submit an application for redevelopment after the expiry of the consultation period on the Pre‐Submission Draft Local Plan. The application will be a hybrid with the foodstore element submitted in full, and the residential element in outline. The application will promote Class C2 or Class C3 use (with any C3 use likely to be for retirement living). Based on architectural studies, this will generate a site capacity of around 60 units for C3 use, or up to 80 units if developed for C2 use. In reaching conclusions on capacity Lidl has had regard to relevant design and parking standards, the draft 'Design Plan' and the policies in the Pre‐Submission plan.
Lidl is concerned that a proposal for the mixed use development of Site R15 for a foodstore and C2/C3 use would be in accordance with the objectives of Policy R15, and would promote the objectives of the Local Plan for the delivery of retail and housing within the Brentwood Urban Area (and on Site R15), but might fall nominally short of the "around 80" dwellings aspiration for site R15. The significance of this for the decision‐making process will depend on (i) the final content of the application; (ii) the interpretation of the word "around" in Policy R15 and (iii) the extent to which the housing strategy might in due course incorporate greater flexibility than in the Pre‐Submission draft. At the same time, Lidl will be promoting a foodstore of a scale that will promote an important
objective of the Local Plan, by virtue of the delivery of new convenience floorspace on a preferred site allocated for retail use, in addition to housing.
There are a number of references in the retail evidence base (the 2014 NLP Retail Study) which inform the content of draft Policy PC07 and the mixed use policies in the Pre‐Submission Draft Plan including R14 (William Hunter Way Car Park) and R15 (Wates Way Industrial Estate).

Para 3.112 notes there is only one large food store in the Borough (Sainsbury's at William Hunter Way) which it is said "dominates shopping patterns within the Borough"
Para 3.115 confirms that "The discount food sector is not currently represented in the Borough with the closest Aldi and Lidl stores located in Romford and Basildon". This has not changed.
Para 3.116 confirms that there was surplus convenience goods expenditure in Brentwood at 2014 and recommends that "the priority for short to medium term food store development should be within Brentwood town centre, where the Sainsbury's store dominates the convenience retail provision".
In relation to the William Hunter Way Car Park, NLP note that the permission to develop the site to include 7,340 sqm of convenience and comparison goods floorspace would no longer be progressed and suggest that it "may be more appropriate for the focus to be on providing a greater proportion of comparison goods floorspace within the amended proposals for the site, strengthening the town's high street offer".
NLP note at para 5.21 that Lidl had purchased Site R15 and say that while any application for retail development on the site would need to be properly assessed, "it would benefit the convenience retail offer of Brentwood town centre if another supermarket is provided. Based on a typical Lidl store size, this could potentially absorb around 1,500 sqm of the identified convenience goods floorspace requirement for Brentwood". They conclude also that within the rest of the town centre, development options are limited.
Table 6.1 set out NLP's convenience goods floorspace projections for Brentwood town centre, including 2,913 sqm (gross) for the period 2014‐2020. Table 6.4 suggests how that may be absorbed by "developments that may come forward in the town centre over the Plan period". This includes specific reference to Wates Way.
Paragraph 20 of the NPPF confirms that strategic policies in Local Plans should set out an overall strategy for the pattern, scale and quality of development, "and make sufficient provision for" housing, employment, retail, leisure and other commercial development. Paragraph 35 note that plans are 'sound' if they are: "a) Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs". The same tests of soundness will be applied to non‐strategic policies "taking into account the extent to which they are consistent with relevant strategic policies for the area". Under the heading 'Ensuring the vitality of town centres' the NPPF advises that policies should allocate suitable sites to meet the scale and type of development likely to be needed, looking at least ten years ahead. Para 7.47 goes on to note that the Council's policy approach should aim to "at least fully meet retail needs". In this context there are no other sites in Brentwood Centre identified in the evidence base or Submission Draft local plan that could accommodate the identified retail needs.
The Pre‐Submission Plan explains (para 9.2) how the site specific allocations should be read. Each includes reference to the "Amount and type of development" which is to be read as setting:‐ "an approximate number of new homes considered appropriate for a site according to certain characteristics, such as surrounding density and character, and the amount of land considered to be developable.... In addition any land/floorspace requirements for employment and retail provision are included".
Policy R15 states that land at Wates Way is allocated for housing and retail development and that proposals should "consider" the following:
"a. provision for around 80 new homes of mixed size and type, including affordable housing; and
b. provision for retail/ commercial use".1
Lidl is keen to contribute to the delivery of the housing and retail development targets set out in the Submission Draft Local Plan. The need for convenience floorspace in the Town Centre is clearly expressed in the evidence base, and through draft Policy PC07, and would be met by the delivery of a
foodstore on a site proposed for mixed retail and housing use. In the absence of any other means of accommodating the identified need, the plan would be 'positively prepared' if it stated support for a foodstore on Site R15.
The reason for the reference to "around" 80 dwellings is understood. Lidl agrees that the policy should not be prescriptive, particularly as the site is also to accommodate retail development to support the delivery of Policy PC07. There is however a risk that reference to "around" 80 dwellings will be applied as a minimum, and a consequent risk that the delivery of one objective relating to retail need may be compromised if the development delivers fewer than 80 dwellings.
To avoid this conflict, and to ensure that the plan is positively prepared in its approach to meeting identified retail and housing needs, Lidl proposes that Policy R15 be revised to refer to "up to" 80 units within use Classes C2 and/or C3, or to a range with an upper limit of 80 dwellings.