Chapter 7 Prosperous Communities, Delivering Economic Growth
Policy PC03 Employment Land Allocations
We write to support allocation of East Horndon Hall as employment allocation and release from the green belt. The northern part of the site has a complex background planning history and is previously developed land with lawful use as a storage and transport yard, vehicle maintenance buildings and former farm buildings converted to office use. It is a site we have promoted as far back as 2009 thus over ten years through the early stages of Local Plan review and site selection. Large tracks of the land in the north east portion have been subject to engineering works and have large mounds of former road plainings. That northern part of the site is in part derelict and despoiled land and not capable of use for agriculture.
Gateways
The spatial Development principles of the plan set out in Chapter 3, page 42, the Borough Gateways and figure 3.3 defines the key gateways. This site at the junction of the A128 and A127 has been identified as a key gateway area. It is logical and practical that given the good infrastructure links that it should be identified as an employment opportunity. It is well related to public transport infrastructure and the primary road network.
New Employment Land Allocations
The land at East Horndon Hall is identified as 5.5 hectares available and a site designation E13. Paragraph 7.24 of the general text endorses the excellent access onto the strategic highway network for both Brentwood Enterprise Park and land south of East Horndon Hall
Brentwood Local Plan - Employment
Chapter 7 Prosperous Communities sets out the policies for delivering economic growth from page 169. Policy PC01 sets out its proactive policy to maintain high and stable levels of local economic growth etc. In Part B PC01 sub-criteria c explains that this will be secured by intensification of vacant and underutilised employment floorspace and sites and the regeneration of previously developed land in sustainable locations.
Policy PC02 titles Job Growth and Employment Land criteria C states:
"Areas allocated for employment purposes are set out in policy PC03 Employment Land Allocations and identified on the Brentwood Policies Map".
Policy PC03 Employment Land Allocations sets out in table form figure 7.6 employment site allocations. Under the heading new employment land allocations:
"E13 Land at East Horndon Hall 5.5 hectares".
The general text under paragraph 7.23 b sub-criteria iii providing new employment land south of East Horndon Hall (site E04). Reinforcing in paragraph 7.24 that land south of East Horndon Hall together with proposed land at Brentwood Enterprise Park will accommodate mixed B-Uses. "The excellent access onto the strategic highway network, makes a very desirable place for certain businesses".
Further reference in paragraph 7.29 is made to the fact that the Council will work with developers and service providers to ensure employment sites such as East Horndon Hall and Dunton Hills will be well connected to existing and new housing sites, including Dunton Hills Garden Village.
Chapter 9 deals with the site allocations, from page 301 the strategic employment allocations, East Horndon Hall - site is set out on page 306-307, Policy E13 East Horndon Hall. The relevant site allocations plan is page 346 E13.
Appendix 4 refers to the production of the new policies map for adoption, not yet published.
Sustainability Appraisal
All Local Plans require a Sustainability Appraisal (SA) to support a new Local Plan. The document sets out the Council's approach to their choice of strategic objectives and allocations for the Plan. Section 5 addresses the strategic objectives and strategic site options. Paragraph 5.3.2 refers to Dunton Hills Garden Village (DHGV). Figure 5.2 sets out the strategic site options which excludes the subject site while figure 5.3 provides a plan of Housing and Economic Land Availability Assessment (HELAA) which shows East Horndon Hall as a deliverable and developable site. The remainder of the chapter addressing how the Council treats the various sites identified for development and omission of sites.
Table 8.3 sets out the proposed employment allocations and page 48 identifies the new stand-alone employment sites and their hecterage. In Chapter 9 under the heading of Economy and Employment there is commentary on the spatial strategy (paragraph 9.6.1 page 69). The general text explains:
"The A127 Corridor will see significant economic growth, mainly because of the opportunity to redevelop brownfield land at M25 junction 29 a project known as Brentwood Enterprise Park. This location provides excellent access onto the strategic highway network, making it a very desirable place for businesses. Also a small extension is proposed to existing nearly employment land at Childerditch Industrial Estate and there will be provision of new employment land at the eastern end of the A127 as part of the Dunton Hills Garden Village proposal and the opportunity will be taken to formally designate existing employment land around the A127, specifically those close to M25 junction 29".
Paragraph 9.6.7 - 9.6.8 makes reference to East Horndon Hall requiring full traffic assessment and travel plan to accompany an application. Elsewhere in the chapter paragraph 9.11.1 under the sub-heading of Soils and Commentary on the Spatial Strategy, as a topic sets out there is a need to make best use of brown field land and protect the Borough's resource of productive agricultural land. Finally in that chapter paragraph 9.14.4 under the sub-heading of Cumulative Effects, page 73, second bullet point:
"A127 Corridor - The Brentwood Local Plan targets significant housing and employment growth the A127 Corridor, which is potentially supportive of the sub-regional objective to develop the A127 as an enterprise corridor; however, there is a need to rely on delivery of significant upgrades to road infrastructure if problematic traffic congestion is to be avoided".
Appendix ii to the SA summarises context and baseline review and identifies amongst others the A127 A128 as a key road junction which has always been one of the firm's arguments and as a key gateway into the town which we would endorse. Finally Appendix iii deals with the site options Appraisal which sets out the criteria set to categorise the performance of individual sites. The evidence base shows that this is a site that performs well.
Policy PC04: Development and Expansion of Business Space and Policy PC05: Employment
Development Criteria
As policies they are found to be sound and provide sufficient flexibility to encourage employment related development.
Not Sound
Policy PC04 should not restrict new offices, development and research facilities to just in designated centres but also should allow for such facilities to come forward within the new allocated employment or existing employment sites where there are established public transport links.
Recommendation
Insert in Policy A a new sub-criteria c. New employment allocated sites or established employment sites where there are public transport links including bus services. We consider the Plan is generally sound subject to minor modifications and to provide the greatest flexibility to encourage employment, we have suggested a minor modification to Policy PC04. See comment in question 2 above.
Wider modification to PC04. Insert in Policy A a new sub-criteria c. New employment allocated sites or established employment sites where there are public transport links including bus services. We have fully supported the general soundness of the emerging employment policies in particular the allocation of the Site E13 Land at East Horndon Hall, 5.5 hectares but with some amendment to general employment policy to prodive greater flexibility and encouragement of general employment within the NPPF.
It is an important part of the Plan and if not resolved consider attendance at the EiP would assist.

Recommendation: Insert in Policy A a new sub-criteria c". New employment allocated sites or established employment sites where there are public transport links including bus services."

Chapter 7 Prosperous Communities, Delivering Economic Growth
Policy PC03 Employment Land Allocations
We write to support allocation of East Horndon Hall as employment allocation and release from the green belt. The northern part of the site has a complex background planning history and is previously developed land with lawful use as a storage and transport yard, vehicle maintenance buildings and former farm buildings converted to office use. It is a site we have promoted as far back as 2009 thus over ten years through the early stages of Local Plan review and site selection. Large tracks of the land in the north east portion have been subject to engineering works and have large mounds of former road plainings. That northern part of the site is in part derelict and despoiled land and not capable of use for agriculture.
Gateways
The spatial Development principles of the plan set out in Chapter 3, page 42, the Borough Gateways and figure 3.3 defines the key gateways. This site at the junction of the A128 and A127 has been identified as a key gateway area. It is logical and practical that given the good infrastructure links that it should be identified as an employment opportunity. It is well related to public transport infrastructure and the primary road network.
New Employment Land Allocations
The land at East Horndon Hall is identified as 5.5 hectares available and a site designation E13. Paragraph 7.24 of the general text endorses the excellent access onto the strategic highway network for both Brentwood Enterprise Park and land south of East Horndon Hall
Brentwood Local Plan - Employment
Chapter 7 Prosperous Communities sets out the policies for delivering economic growth from page 169. Policy PC01 sets out its proactive policy to maintain high and stable levels of local economic growth etc. In Part B PC01 sub-criteria c explains that this will be secured by intensification of vacant and underutilised employment floorspace and sites and the regeneration of previously developed land in sustainable locations.
Policy PC02 titles Job Growth and Employment Land criteria C states:
"Areas allocated for employment purposes are set out in policy PC03 Employment Land Allocations and identified on the Brentwood Policies Map".
Policy PC03 Employment Land Allocations sets out in table form figure 7.6 employment site allocations. Under the heading new employment land allocations:
"E13 Land at East Horndon Hall 5.5 hectares".
The general text under paragraph 7.23 b sub-criteria iii providing new employment land south of East Horndon Hall (site E04). Reinforcing in paragraph 7.24 that land south of East Horndon Hall together with proposed land at Brentwood Enterprise Park will accommodate mixed B-Uses. "The excellent access onto the strategic highway network, makes a very desirable place for certain businesses".
Further reference in paragraph 7.29 is made to the fact that the Council will work with developers and service providers to ensure employment sites such as East Horndon Hall and Dunton Hills will be well connected to existing and new housing sites, including Dunton Hills Garden Village.
Chapter 9 deals with the site allocations, from page 301 the strategic employment allocations, East Horndon Hall - site is set out on page 306-307, Policy E13 East Horndon Hall. The relevant site allocations plan is page 346 E13.
Appendix 4 refers to the production of the new policies map for adoption, not yet published.
Sustainability Appraisal
All Local Plans require a Sustainability Appraisal (SA) to support a new Local Plan. The document sets out the Council's approach to their choice of strategic objectives and allocations for the Plan. Section 5 addresses the strategic objectives and strategic site options. Paragraph 5.3.2 refers to Dunton Hills Garden Village (DHGV). Figure 5.2 sets out the strategic site options which excludes the subject site while figure 5.3 provides a plan of Housing and Economic Land Availability Assessment (HELAA) which shows East Horndon Hall as a deliverable and developable site. The remainder of the chapter addressing how the Council treats the various sites identified for development and omission of sites.
Table 8.3 sets out the proposed employment allocations and page 48 identifies the new stand-alone employment sites and their hecterage. In Chapter 9 under the heading of Economy and Employment there is commentary on the spatial strategy (paragraph 9.6.1 page 69). The general text explains:
"The A127 Corridor will see significant economic growth, mainly because of the opportunity to redevelop brownfield land at M25 junction 29 a project known as Brentwood Enterprise Park. This location provides excellent access onto the strategic highway network, making it a very desirable place for businesses. Also a small extension is proposed to existing nearly employment land at Childerditch Industrial Estate and there will be provision of new employment land at the eastern end of the A127 as part of the Dunton Hills Garden Village proposal and the opportunity will be taken to formally designate existing employment land around the A127, specifically those close to M25 junction 29".
Paragraph 9.6.7 - 9.6.8 makes reference to East Horndon Hall requiring full traffic assessment and travel plan to accompany an application. Elsewhere in the chapter paragraph 9.11.1 under the sub-heading of Soils and Commentary on the Spatial Strategy, as a topic sets out there is a need to make best use of brown field land and protect the Borough's resource of productive agricultural land. Finally in that chapter paragraph 9.14.4 under the sub-heading of Cumulative Effects, page 73, second bullet point:
"A127 Corridor - The Brentwood Local Plan targets significant housing and employment growth the A127 Corridor, which is potentially supportive of the sub-regional objective to develop the A127 as an enterprise corridor; however, there is a need to rely on delivery of significant upgrades to road infrastructure if problematic traffic congestion is to be avoided".
Appendix ii to the SA summarises context and baseline review and identifies amongst others the A127 A128 as a key road junction which has always been one of the firm's arguments and as a key gateway into the town which we would endorse. Finally Appendix iii deals with the site options Appraisal which sets out the criteria set to categorise the performance of individual sites. The evidence base shows that this is a site that performs well.
Policy PC04: Development and Expansion of Business Space and Policy PC05: Employment
Development Criteria
As policies they are found to be sound and provide sufficient flexibility to encourage employment related development.
Not Sound
Policy PC04 should not restrict new offices, development and research facilities to just in designated centres but also should allow for such facilities to come forward within the new allocated employment or existing employment sites where there are established public transport links.
Recommendation
Insert in Policy A a new sub-criteria c. New employment allocated sites or established employment sites where there are public transport links including bus services. We consider the Plan is generally sound subject to minor modifications and to provide the greatest flexibility to encourage employment, we have suggested a minor modification to Policy PC04. See comment in question 2 above.
Wider modification to PC04. Insert in Policy A a new sub-criteria c. New employment allocated sites or established employment sites where there are public transport links including bus services. We have fully supported the general soundness of the emerging employment policies in particular the allocation of the Site E13 Land at East Horndon Hall, 5.5 hectares but with some amendment to general employment policy to prodive greater flexibility and encouragement of general employment within the NPPF.
It is an important part of the Plan and if not resolved consider attendance at the EiP would assist.