Further employment land needs to be allocated within the plan. Please refer to the detailed submission made by Sphere 25 on behalf of Cambria Autos Plc, regarding the proposed allocation of the Land Lying South of Brook Street.

Sphere 25 is a Brentwood based Town Planning Consultancy, which has been instructed by the Land Owner, Cambria Automobiles plc, to make a formal submission to the consultation on the New Local Plan for Brentwood. This planning report responds to the Brentwood Local Plan 2016 to 2033, Pre- Submission, Regulation 19 consultation. The specific form completed in response to the Reg 19 Consultation is included as Appendix 1 to this report. The draft Local Plan is hereby referred to as the PSDLP, 2019. Representations on the soundness and legal compliance of the Local Plan were invited from Tuesday 5 February 2019 to 5pm Tuesday 19 March 2019. This submission is specific to the area of land identified in the document completed by SRA Architects and included as Appendix 2. It refers to the Land Lying to the South of Brook Street, hereafter referred to as 'The Site'. A more detailed description of the Site and surroundings is presented under the relevant sub-heading below. (Figure included in original document attached). The purpose of this report is to affirm our position that whilst the PDSLP, 2019 comprises a logical approach to promoting sustainable development, it is unsound because it does not identify the required quantum of employment land to deliver the economic and employment growth objectives of the plan. Inclusion of The Site will help to ensure the soundness of the plan by providing a high quality site in a strategic location to deliver a range and mix of jobs and inward investment during the Plan period to 2033. At present the plan allows for growth to meet employment targets but does not allocate land, which can generate significant growth and prosperity. By allocating more strategically located employment sites, the Local Plan can encourage higher rates of economic growth and job creation to fulfil the objectives of the plan. The remainder of this report sets out the following key items: 1. Description of The Site location and surroundings; 2. Indicative description of the proposed/potential uses of The Site; 3. Planning Note on the green belt and an assessment of The Site; 4. Assessment of the need for Employment Land in the borough; 5. Assessment of economic benefit in terms of jobs and inward investment on-site; and 6. Conclusions on why The Site should be included as an employment allocation in the Local Plan. The following Appendices are included with this report: Appendix 1 - Brentwood Local Plan Consultation Form; Appendix 2 - Masterplan and Street Scene Visuals; Appendix 3 - Assessment of Potential Employment Creation; and Appendix 4 - Company Information on Cambria (all included attached). The purpose of this report is to clearly justify why The Site should be allocated for development in the emerging Local Plan for Brentwood. It is our contention that the benefits derived from including The Site as an employment allocation, would far outweigh any perceived harm arising when the impact of development of The Site is assessed against the purposes of the Green Belt. The form of the development on The Site is such that there is a buffer between Junction 28 of the M25 and any built development on The Site. Development could be brought forward as displayed in the indicative SRA design document at Appendix 2. Releasing The Site will still leave a swathe of open land between the western extremities of the Brentwood settlement boundary and the M25. The proposed site allocation will comprise a prestige "gateway development" for Brentwood in a strategic location at the entry to the largest settlement in the borough. Paragraph 3.11 of the PSDLP, 2019 refers to the importance of connectivity and the key development corridors in the borough, stating that: "Brentwood has two key transit corridors running through the borough: the 'Central Brentwood Growth Corridor', with the A12, the Great Eastern Main Line to London Liverpool Street Station, and the Elizabeth Line; and the 'Southern Brentwood Growth Corridor', with the A127 and the London, Tilbury and Southend Railway to London Fenchurch Street Station. These form key connectivity axes. Focusing growth along these axes will ensure that future development is sustainable, maximising the benefits of transport infrastructure. While some investment to improve the transport network will be inevitable, this growth strategy ensures economies of scale are reached, with the critical mass of development making it more viable for such investment to occur." The proposed allocation is entirely consistent with the overarching approach of focusing growth in key transit corridors. The Site occupies a consummate location in proximity to the strategic highway network helping to ensure that the requisite critical mass of development is achieved to sustain significant investment in infrastructure. The proposals for remodelling of Junction 28 of the M25 are an example of the types of investment that will unlock further development and growth. opening of the Elizabeth Line Cross Rail service will represent a significant step change in the connectivity to London and beyond. Figure 3.3 of the Local Plan provides a map illustrating the key gateways in the borough and shows The Site as being directly adjacent to the key gateway location identified at Junction 28 of the M25. (Figure included in original document see attached). The Site comprises an 8.1 Ha parcel of land located to the south of Brook Street to the east of junction 28 of the M25. The Grade II Listed Nags Head pub/building and plot lies outside the site boundary to the north east corner; and Nags Head Lane forms the eastern boundary of the site as it runs in a southwest direction towards the Great Eastern Mainline alignment, which forms the southern boundary of the site. The A1023 Brook Street forms the northern boundary of the Site and the proposed frontage is opposite the Holiday Inn and the Brentwood Garden Centre on Vicarage Close. The A12 corridor is located just to the north of the buildings/sites. The western boundary of the Site runs from Brook Street down to the railway alignment, bisecting the existing agricultural land and leaving a significant and regular shaped plot of open green belt framed by the M25 to the west. The old farm house is located adjacent to the M25 to the west of the subject site within the green belt. The somewhat tired condition of the existing buildings fronting the northern edge of Brook Street detracts from the image of Brentwood at this prominent entry point. The existing built form is characterised by a haphazard arrangement of buildings of relatively poor architectural quality. The proposed high-quality buildings and uses fronting Brook Street contained in the proposed scheme will transform the impression of Brentwood for visitors to the town. The Site levels vary across the site with a slope up from Brook Street with a sharp change in levels at the junction with Nags Head Lane. There is a slope upwards to the centre of the Site and the landscape across the plot undulates somewhat with an overall change in levels towards the northern boundary on Brook Street which is at a lower level. There is a slope on a gentle running east west along Brook Street. There are tree-lines bisecting the Site at various points, but the Site is largely open and agricultural in character. There is a line of trees along the perimeter of the Site along the Brook Street and Nags Head Lane boundaries. The Aerial Site Plan below shows a plot edged in blue fronting Brook Street with the wider site boundary bordered in red. (Figure included in original document see attached). It is envisaged that the area bordered in blue would be brought forward by the Land Owner, who will develop a prestigious car dealership development and occupy the premises for their operational business, trading as 'Grange'. The Grange business was founded in Brentwood and has been a local employer for many years. The remainder of The Site will form a mixture of largely "B Class" employment uses, although it is envisaged that some sui generis buildings and other uses that are compatible with an employment development could be located on the Site. The location of the Site is such that it will appeal to a range of industrial and office occupiers. Given the extent of employment floorspace that has been converted to residential dwellings in recent years there is an acute shortage of well-located and high-quality mixed employment land in Brentwood. Some images depicting the quality of the proposed buildings that will be contained within the prestige car dealership development are titled Proposed External Visuals in the SRA document at Appendix 2 to this report. The mixed employment uses identified on the remainder of the Site are integral to the longer-term aspirations for the development. The Site will not work commercially without the wider employment allocation. The premium brands that will be located on the Site require exceptional quality buildings with wide and open frontages to showcase the vehicles on display. The three separate buildings along the Brook Street frontage will house six premium brands, all of which will have a visual presence on the street. The frontage will be characterised by a detailed landscaping scheme, which will involve removal of some of the low-quality trees along Brook Street and replacement with species that will add considerably to the appearance of the Site and surrounding area. There will be an area provided for parking/external showcasing of some of the premium vehicles at prominent points along Brook Street; this high-quality landscaped setting will be a key focal point for visitors to Brentwood as they enter the town from the M25. It is envisaged that this new "gateway" development will raise the profile of Brentwood and encourage inward investment in the town. The Site Area and Use Plan included in Appendix 2 shows the overall site area and the potential separation between indicative uses on the Site. Area 1: 2.78 hectares - incorporating the car show room area shaded blue on the Site and Phasing Plan Area 2: 2.0 hectares - incorporating potential B1 uses shown to the north of the main internal service road as shown on the Site and Phasing Plan Area 3: 2.56 hectares - the remainder of the Site to the south of the main service road as shown on the Site and Phasing Plan. Overall the Site is 8.1 hectares, with the balance of the land (0.76 hectare) being that outside the annotated phases i.e. principle access road. It is proposed that Areas 2 and 3 will be brought forward as a mixed employment site offering a range of opportunities for occupiers seeking well located B1 (office), B2 (manufacturing) and B8 (warehousing) and potentially other specialist employment space. There is enormous appetite in Brentwood from investors and occupiers for sites and new employment floorspace in proximity to key transport infrastructure. The Local Plan highlights the need for sites and properties to accommodate the forecast job growth and economic aspirations to 2033. The indicative masterplan included within Appendix 2 highlights how the employment floorspace could potentially be delivered on-site, based upon a site configuration incorporating two separate access points off Brook Street, and two access points off Nags Head Lane, and a simple network of internal roads working from a main central service road running between Brook Street and Nags Head Lane. The wider site is of sufficient scale to enable a number of separate plots to come forward; this will enable a genuinely mixed-employment offer to be delivered. The indicative masterplan shows a range of different building/site layouts that could be suited to offices, self-storage, warehousing, light industrial and specialist manufacturing amongst others. The assumptions underpinning the indicative masterplan for the wider site show floorspace as identified below: Area 2: B1 Business offices - 16,787m² (a mix of 3 and 4 storey accommodation); Area 3: B1 Business offices - 1,350m² (two storey accommodation); B2 (Light Industrial): 6,487m² (assumes 1.5 storey accommodation); and B8 Distribution & Storage: 4,015m² (assumes single story warehouse at 3,295m² and 2 storey support office accommodation at 720m²). Detail on the number of construction and operational jobs that it is envisaged will be provided on the Site in each of the phases is presented in the assessment of economic benefits section below. The subject site forms part of a wider area of green belt between Nags Head Lane and the Junction 28 of the M25. The area of land to the east of Nags Head Lane has been included as an allocated residential site in the PSDLP, 2019. The Holiday Inn to the north of Brook Street is a developed site within the Green Belt, whereby in 1980s, the National Green Belt Policy (PPG2) tests for 'very special circumstances' were demonstrated, which enabled what is termed 'inappropriate development' to be delivered in the form of a Use Class C1 Hotel on the site. National Planning Policy Framework (NPPF) states, in paragraph 133, that "the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open: the essential characteristics of Green Belts are their openness and their permanence." NPPF sets out the 5 purposes of Green Belt: 1. To check the unrestricted sprawl of large built-up areas; 2. To prevent neighbouring towns from merging into one another; 3. To assist in safeguarding the countryside from encroachment; 4. To preserve the setting and special character of historic towns; and 5.To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. At local level a Green Belt Study was completed to inform the PSDLP, undertaken in 2018. This report was divided into three separate phases: Part 1 - London Metropolitan Green Belt Review: identifying Brentwood's role in the wider Green Belt; Part 2 - Green Belt Parcel Definition and Review: defining the individual parcels of Green Belt and the characteristics; and Part 3 - Assessment of Potential Housing, Employment and Mixed-Use sites in the Green Belt. Within Part 2 of the Green Belt study, the land at Brook Street is identified as part of a wider area of Green Belt of 33.68 Ha in size. The extract from the Green Belt Study is presented in Figure 4 below. (See attached). The overall assessment of Site 27B identified the land as making a moderate contribution to the purposes of the Green Belt as defined in the NPPF. Of the 70 sites assessed, 40 were assessed to make a greater contribution to the purposes of the Green Belt than the site. Only 2 sites were assessed as being in the low-moderate contribution to the Green Belt category. Therefore, the subject site was one of the 28 sites considered to be of moderate importance to the Green Belt. The wider site 27B scored most highly because it is deemed to comprise an important countryside gap. However, if only part of the Site is brought forward, this will retain a key area of open countryside between the subject site and Junction 28 of the M25. Therefore, if the subject site was assessed in isolation of the wider site 27B it would score more positively against this criterion. Overall, whilst the Site does contribute to the objectives of the Green Belt, it makes a lesser contribution than the majority of sites in the borough. Furthermore, the subject site occupies an optimum location for employment uses due to its proximity to highways infrastructure. Therefore, there is a trade-off between the potential role of the Site as an optimum employment location and the moderate contribution the Site makes to the purposes of the Green Belt. This matter is considered in further detail in the Employment Land section below. The size, location and connectivity of Brentwood make it a highly attractive settlement for economic activity and inward investment. The economic evidence base underpinning the Local Plan suggests that there will be increased demand/need for jobs, floorspace and well-located employment land over the plan period to 2019. It is imperative for the Local Plan that the right amount of land is identified and that such land is in the right location and of the right quality to ensure that the right type of jobs and inward investment will accrue to the borough over the plan period. Furthermore, it is imperative that sites which can be delivered early in the plan period are included as allocations. Brentwood Borough Council has identified employment land at the junction of the A127 and Junction 29 of the M25 for inclusion within the Local Plan. With the proposed river crossing connecting with the north Thames road network very close to this site it is envisaged that considerable preparatory work needs to be completed which will result in a delay in delivering any floorspace and jobs from this site during the early stages of the plan. The Brook Street site with similar links to major road networks can be achieved within a relatively short time and will help to ensure that the right land, in the right place of the right quality can be delivered at the right time to fulfil the aspirations of the Local Plan. The Brentwood Economic Futures Report 2013 - 2033 completed in January 2018 refers to identified needs for net additional employment land of 'between 8.1 and 20.3ha.' (Para 3.40). Furthermore, existing employment sites will be released over the plan period, therefore significantly more employment land needs to be identified than the 20.3 Ha mentioned above. Para 7.19 of the PSDLP confirms a requirement for 45.96 Ha of employment land. Paragraph 7.28 of the PSDLP states that: 'The Essex Grow-on Space Feasibility Study (2016) has highlighted a gap in supply and demand in the borough in relation to the availability of smaller sized office and industrial units for emerging small businesses, curtailing the potential growth of these businesses. This identifies a concealed need for employment floorspace of 9ha arising from local businesses looking for room to grow into. The Council will encourage the provision of flexible working space, incubation units and grow-on space in the proposed employment allocations where appropriate.' The Site is large-scale and occupies an ideal location to provide smaller and more flexible business and industrial units of the type that have been identified. Paragraph 7.3 of the PSDLP, 2019 refers to the economic objectives of the plan and states; "The Council's Economic Strategy sets out a series of economic aims and strategic priorities which are reflected in the vision and strategic objectives of the Local Plan: Economic Aims: A1. Promote a mixed economic base and a discerning and sustainable approach to economic growth; A2. Encourage high value, diverse, employment uses that will provide a significant number of skilled and high-quality jobs; A3. Encourage better utilisation, upgrading and redevelopment of existing land and buildings; and A4. Enable the growth of existing business, the creation of new enterprises and encourage inward investment." In considering the employment potential of the Site, we have referenced the Employment Density Matrix in the HCA's Employment Density Guide, 2015. With reference to the detailed guidance in this report we have derived some reasoned assumptions about the potential employment yield from the different types of proposed floorspace on the Site. For the B1 accommodation, we have assumed an overall position of 20 sq. m GEA for each employee. This is a blended average across the Site, which might include some light industrial, call centre and head office space. This is a conservative estimate and we envisage the Site could deliver significantly more jobs depending on the types of floor space that are delivered. For the B2 and B8 accommodation, we have assumed 36 sq. m and 77 sq. m (GEA) per job respectively. The overall employment allocation at Brook Street has the potential to deliver circa 1,200 Full time equivalent (FTE) jobs. Area 1: 156 jobs based on the schedule included as Appendix 3 to this report; Area 2: B1 Business offices - 16,787m² (a mix of 3 and 4 storey accommodation) = 839 Area 3: B1 Business offices - 1,350m² (two storey accommodation) = 68 B2 (Light Industrial): 6,487m² (assumes 1.5 storey accommodation) = 180; B8 Distribution & Storage: 4,015m² (assumes single story warehouse at 3,295m² and 2 storey support office accommodation at 720m²). 43 + 36 = 79. We have not undertaken any detailed analysis of supply chain activity at this stage, but we envisage a significant boost to local goods and services providers. There will also be considerable employment during the construction phase(s) of the project which will give rise to opportunities or local employment and apprenticeship initiatives. Cambria Automobiles will occupy and operate Area 1 of the Site and will ensure early delivery to "kickstart" the development. Full detail on Cambria and Grange is presented in the slide presentation included as Appendix 4 to this report. As mentioned above, Grange is a local employer with a long-term connection to Brentwood where the business was formed. The business will deliver a wide range of different employment opportunities ranging from senior managerial positions to specialist technical roles involved in car maintenance and repair. It is the purpose of this report to affirm the position that the Site should be included in the emerging Local Plan for Brentwood as an allocated employment site. The Site occupies a prime position for employment, is deliverable in the short term and will promote new employment opportunities in a key gateway location. The existing site/land makes a moderate contribution to the green belt. However, it is nor of fundamental importance to the openness of the countryside. Therefore, it is our professional and considered assessment that benefits of allocating the subject site for employment will far outweigh any adverse impacts arising from the loss of an area of Green Belt, which is of moderate quality. The purpose of this report is to reiterate our position that whilst the PDSLP, 2019 comprises a logical approach to promoting sustainable development, it is unsound because it does not identify the required quantum of employment land, which is available at the right time to deliver the economic and employment growth objectives of the plan. Inclusion of the Site will help to ensure the soundness of the plan by providing a high-quality site, in a strategic location to deliver a range and mix of jobs and inward investment at an early stage during the Plan period to 2033. In particular, it is our assessment that given the anticipated delays regarding the land at Junction 29 of the M25 it is essential for further employment allocations to be made within the Local Plan.