Smith Jenkins Ltd act for McColl's Retail Group plc.
On behalf of our client we are instructed to make representations to the focussed changes made to the pre-submission draft of the Brentwood Local Plan, which we understand have been published for comment until 26th November 2019.
This response should be read in conjunction with our client's representations on the original pre-submission Local Plan, dated 19th March 2019. Both representations concern our client's headquarters at McColls House, Ashwells Road, Pilgrims Hatch, and have been prepared in order to assist the Local Authority.
We note that the focussed changes are not exhaustive and concern only five policies regarding particular allocations or sites that were already included in the pre-submission draft of the Local Plan. We have no comments on the necessity of the adjustments in housing figures that are proposed, although note that these are very minor in scale. For example, the changes to the Dunton Hills Garden Village allocation is equivalent to just a 2.5% increase in housing whilst other adjustments concern only 10 homes being deducted from allocations.
This is in marked contrast to the circumstances affecting our client's site, which, as outlined in our 19th March representation was identified as an existing employment site in the Green Belt that is effectively reserved for B-class uses under emerging Policy PC03.

Our client previously advocated the removal of their site from this policy on the grounds that it is neither effective nor positively-prepared. To confirm, this is still our client's position although this is now augmented by new information that must be considered by the Council in proceeding with the Local Plan.
On 13th September 2019, Brentwood Borough Council gave its Prior Approval for the change-of-use of our client's offices to create 55 dwellings (application reference 19/01043/PNCOU; see Appendix 1 for Decision Notice). The Council will be aware that our client has subsequently engaged in pre-application discussions for an alternative purpose-built scheme of 39 dwellings. Our client will implement one or the other of these schemes in the near future, meaning their site will be lost to employment purposes. As outlined in previous representations, the site is poorly suited to modern business use but nevertheless the loss of employment land is more than offset by the significant windfall boost to the Council's housing land supply and the efficient re-use of previously-developed land in a sustainable location.
This context not only renders the site's inclusion in Policy PC03 further unsound, but also affects the housing requirement and extant permissions in the emerging Local Plan to a greater extent than any of the proposed focussed changes. We would therefore respectfully request that the Local Plan be further amended to reflect this, either through an additional focussed change, or by way of modification at Examination stage. It is understood that the Council may have previously declined to do so on the grounds that only limited information was available as to the site's likely future. However, given our client's clear intent to use the site for residential purposes, and the extant Prior Approval allowing them to do so in principle, this matter clearly needs to be revisited in order for both the employment and housing provision within the Local Plan to be up-to-date and sound.
Please retain or add Smith Jenkins Ltd to any consultation database that is being used to publicise future Local Plan updates.
Should you require any further information regarding any of the matters in this representation, please do not hesitate to contact me or Jennifer Smith at this office.

Remove McColl's site (ref 321) from existing employment site as set out in Policy PC03, either through an additional focussed change, or by way of modification at Examination stage.

Smith Jenkins Ltd act for McColl's Retail Group plc.
On behalf of our client we are instructed to make representations to the focussed changes made to the pre-submission draft of the Brentwood Local Plan, which we understand have been published for comment until 26th November 2019.
This response should be read in conjunction with our client's representations on the original pre-submission Local Plan, dated 19th March 2019. Both representations concern our client's headquarters at McColls House, Ashwells Road, Pilgrims Hatch, and have been prepared in order to assist the Local Authority.
We note that the focussed changes are not exhaustive and concern only five policies regarding particular allocations or sites that were already included in the pre-submission draft of the Local Plan. We have no comments on the necessity of the adjustments in housing figures that are proposed, although note that these are very minor in scale. For example, the changes to the Dunton Hills Garden Village allocation is equivalent to just a 2.5% increase in housing whilst other adjustments concern only 10 homes being deducted from allocations.
This is in marked contrast to the circumstances affecting our client's site, which, as outlined in our 19th March representation was identified as an existing employment site in the Green Belt that is effectively reserved for B-class uses under emerging Policy PC03.

Our client previously advocated the removal of their site from this policy on the grounds that it is neither effective nor positively-prepared. To confirm, this is still our client's position although this is now augmented by new information that must be considered by the Council in proceeding with the Local Plan.
On 13th September 2019, Brentwood Borough Council gave its Prior Approval for the change-of-use of our client's offices to create 55 dwellings (application reference 19/01043/PNCOU; see Appendix 1 for Decision Notice). The Council will be aware that our client has subsequently engaged in pre-application discussions for an alternative purpose-built scheme of 39 dwellings. Our client will implement one or the other of these schemes in the near future, meaning their site will be lost to employment purposes. As outlined in previous representations, the site is poorly suited to modern business use but nevertheless the loss of employment land is more than offset by the significant windfall boost to the Council's housing land supply and the efficient re-use of previously-developed land in a sustainable location.
This context not only renders the site's inclusion in Policy PC03 further unsound, but also affects the housing requirement and extant permissions in the emerging Local Plan to a greater extent than any of the proposed focussed changes. We would therefore respectfully request that the Local Plan be further amended to reflect this, either through an additional focussed change, or by way of modification at Examination stage. It is understood that the Council may have previously declined to do so on the grounds that only limited information was available as to the site's likely future. However, given our client's clear intent to use the site for residential purposes, and the extant Prior Approval allowing them to do so in principle, this matter clearly needs to be revisited in order for both the employment and housing provision within the Local Plan to be up-to-date and sound.
Please retain or add Smith Jenkins Ltd to any consultation database that is being used to publicise future Local Plan updates.
Should you require any further information regarding any of the matters in this representation, please do not hesitate to contact me or Jennifer Smith at this office.