Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its commercial assets at Eagle Way, Warley, Brentwood (the Site'). Iceni has been instructed by Ford to prepare and submit comments on the 'focused changes' to the pre-submission' Local Plan (2019) consultation.
On behalf of our Client, we welcome the opportunity to comment the Addendum of Focussed Changes to the Pre-Submission Local Plan ('AFC' October 2019). This is the final stage of consultation on the new Local Plan, following which the plan will be submitted to the Planning Inspectorate for independent examination. It is noted that Ford have submitted representations to each stage of consultation to date, including promotion of the site for housing and delivery in the earliest years of the plan period.
We therefore assert that this stage of consultation should consider comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2019) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy.
Our Client is broadly supportive of the Site's Draft allocation as a strategic site for housing under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness, we wish to question the below aspects of the draft allocation (in the absence of robust evidence) and the inclusion of the site within years 9-17 of the Housing Trajectory as shown
in Appendix 1 of the AFC (versus years 6-10):
* Retention of 2.0 hectares of employment land - Land south of Eagle Way (i.e. main Ford Headquarters);
* Delivery of residential care home providing 60 x bed spaces; and
* 5% self-build and custom build across the entire allocation (including the Council Depot).
This is contrary to the fundamental sustainability objectives of the NPPF and all previous representations submitted by Ford, demonstrating the early deliverability and availability of the Site in providing much needed housing for the Borough - at a brown field location. Our Client therefore considers that the current plan has failed to be positively prepared and should therefore be reviewed prior to Examination in public.
This representation is submitted in line with the consultation deadline of Tuesday 26th November 2019.
a. The Site
Location / Description
The Site comprises of 8.51 hectares (21.03 acres) of land located within Warley, forming the southern edge of the Brentwood settlement boundary. It is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway.
Eagle Way runs east-west through the Site, dividing it into two parcels of land, as outlined below:
* 'The northern parcel' - 1.37 hectares (3.39 acres) of land to the north of Eagle Way, currently utilised for staff car parking. A bus station is located on The Drive which runs along the western boundary, with Eagle Way running along the southern boundary of the northern parcel. To the north there is council-owned land which is currently being utilised as additional car parking, as well as the highways depot and auto garage known as Council Depot. Located adjacent to the east is the Marillac nursing home and to the west there is a local centre with retail and commercial uses, beyond which there are predominantly residential uses.
* 'The southern parcel' - 7.14 hectares (17.64 acres) of land to the south of Eagle Way where the main office building is located. The 6-7 storey office building has a NIA of 43,664 sq.m (470,000 sq.ft.), together with an ancillary data centre building, car parking and landscaping. The southern parcel is bounded by woodland and Warley Gap to the south, Clive Road to the west, Eagle Way to the north and woodland to the east. There are two dwellings located within 70m south of the site, with the Essex Regiment Chapel and Royal Anglian Regiment being located to the west.
b. Response to AFC Consultation
Amended Housing Trajectory
In line with Ford's previous representations, we wish to request that the draft allocation for the Site within the next stage of the new Local Plan is updated to reflect the Site's anticipated availability earlier in the Plan period. Notably, it is realistic that the site could be delivered within 6 -10 years (2021-2025) versus the 9 -17 years (2025-2033) (currently stated in Appendix 1 of the AFC). The HELAA 2018, presented data in table 2 which indicated that the potential new housing trajectory for the borough would be brought forward on brownfield sites within the early years in the Plan.
All potential options should be explored in detail to increase the supply of housing in the early years. We therefore request that BBC review and update the Site's inclusion in the housing trajectory, including considering the Ford owned and Council Depot sites separately (see further comments below) - bringing forward the Ford owned land in years 6-10 (which Ford have demonstrated is available and deliverable). In our opinion this is necessary in order to ensure the Plan is positively prepared, having regard to the requirements of Paragraph 35 of the NPPF 2019.
We maintain that the BBC's proposed phased approach to the annual housing requirement, may not deliver sufficient quantum of housing within the early years of the Plan following adoption. As such we consider that this approach would be unsound, as the Plan would not be positively prepared in this regard, unless clear evidence can be provided to demonstrate that all potential options to boost housing supply in the early years of the Plan have been explored in detail.
The Ford site is already identified by BBC as a proposed allocation and will make a vital contribution towards the anticipated trajectory in this context, particularly as a less constrained medium scale site. However, we consider that the further efforts should be made to ensure the capacity for the site to deliver housing on brownfield land early in the plan period are maximised, in order to ensure that the annual requirement is sound.
Draft Policy R04 and R05: Ford Headquarters and Council Depot
Ford notes that the current draft policy includes the Warley Site under draft 'Site Allocation R04' (Land South of Eagle Way)' and 'Site Allocation R05' (Land North of Eagle Way)' (collectively referred to as
3
the 'Ford Headquarters and Council Depot, Warley for housing and employment development, with the potential for specialist care accommodation (referred to as 'Other Indicative uses').
The draft allocation sets out that sites R04 and Ro5 have a collective site area of 9.4 hectares (ha) of which, 8 ha is developable; with an indicative dwelling yield (net) of 473 residential units across the two sites. The allocations are currently anticipated by BBC to come forward within years 9-17 of the proposed plan period. The Ford owned land can be delivered in the early years of the plan period and we would challenge the proposed housing trajectory for the site as outlined in Appendix 1: Schedule of Focussed Changes to Brentwood Pre-Submission Local Plan (October 2019).
Ford remains broadly supportive of the strategic housing allocation but recognises that the current pairing of the Headquarters and the Depot has potential to limit the delivery of the site in the short to medium term. We are aware that the Depot currently has no scheduled availability date at this stage and its employment function will need to be moved elsewhere in the Borough. In the interest of early delivery, we are proposing that the Northern Land parcel (R05) is separated from the Southern parcel (R04), enabling the site to come forward for housing in the early years of the plan period. This is supported through Ford providing certainty over the future availability of the Site as part of the headquarters relocation and long standing, open engagement with BBC - in addition to formal representations to all previous consultations to the emerging Local Plan.
The need for BBC to identify additional land for housing is also required in order address cross-boundary pressures such as London's future housing growth, which has been exemplified within relevant London Plan EiP hearing sessions. In this context, the Mayor of London has confirmed that local planning authorities within the wider south east, where the housing market is influenced by that of London should be working collaboratively with the GLA to significantly boost the supply of housing and ensure that Local Plans meet full objectively assessed needs. The arrival of Crossrail at Brentwood and Shenfield further exemplifies this requirement. This will undoubted bring even greater connections to central London, inevitably resulting in an increase in people living in the local area. This places further pressure on land for development, with the Site at Warley providing a key brownfield opportunity for much need new housing.
We consider the Ford Warley Site to the be a highly deliverable site, available for housing development. The NPPF (2019) is clear in stating that "to be considered deliverable, sites should be available now, offer a suitable location for development, and be achievable with a realistic prospect that housing will be delivered on site within five years." The current plan, its Housing Trajectory and inclusion of the Ford site should be updated in line with this national requirement.
c. Summary
We trust that this letter provides further information to inform amendments to the Pre-submission Local Plan 2019. We request that the housing trajectory is updated to reflect the early delivery of new housing at the Site within plan period years 6-10. Our Client would welcome discussing this in further detail with BBC, prior to the Pre-submission Local Plan (2019) being submitted to the Secretary of State. Should you have any questions please do not hesitate to contact me (agale@iceniprojects.com) or my colleague Lucy Howes (lhowes@iceniprojects.com).

The Ford site is identified by BBC as a proposed allocation and will make a vital contribution towards the anticipated trajectory in this context, particularly as a less constrained medium scale site. However, we consider that the further efforts should be made to ensure the capacity for the site to deliver housing on brownfield land early in the plan period are maximised, in order to ensure that the annual requirement is sound.

Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its commercial assets at Eagle Way, Warley, Brentwood (the Site'). Iceni has been instructed by Ford to prepare and submit comments on the 'focused changes' to the pre-submission' Local Plan (2019) consultation.
On behalf of our Client, we welcome the opportunity to comment the Addendum of Focussed Changes to the Pre-Submission Local Plan ('AFC' October 2019). This is the final stage of consultation on the new Local Plan, following which the plan will be submitted to the Planning Inspectorate for independent examination. It is noted that Ford have submitted representations to each stage of consultation to date, including promotion of the site for housing and delivery in the earliest years of the plan period.
We therefore assert that this stage of consultation should consider comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2019) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy.
Our Client is broadly supportive of the Site's Draft allocation as a strategic site for housing under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness, we wish to question the below aspects of the draft allocation (in the absence of robust evidence) and the inclusion of the site within years 9-17 of the Housing Trajectory as shown
in Appendix 1 of the AFC (versus years 6-10):
* Retention of 2.0 hectares of employment land - Land south of Eagle Way (i.e. main Ford Headquarters);
* Delivery of residential care home providing 60 x bed spaces; and
* 5% self-build and custom build across the entire allocation (including the Council Depot).
This is contrary to the fundamental sustainability objectives of the NPPF and all previous representations submitted by Ford, demonstrating the early deliverability and availability of the Site in providing much needed housing for the Borough - at a brown field location. Our Client therefore considers that the current plan has failed to be positively prepared and should therefore be reviewed prior to Examination in public.
This representation is submitted in line with the consultation deadline of Tuesday 26th November 2019.
a. The Site
Location / Description
The Site comprises of 8.51 hectares (21.03 acres) of land located within Warley, forming the southern edge of the Brentwood settlement boundary. It is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway.
Eagle Way runs east-west through the Site, dividing it into two parcels of land, as outlined below:
* 'The northern parcel' - 1.37 hectares (3.39 acres) of land to the north of Eagle Way, currently utilised for staff car parking. A bus station is located on The Drive which runs along the western boundary, with Eagle Way running along the southern boundary of the northern parcel. To the north there is council-owned land which is currently being utilised as additional car parking, as well as the highways depot and auto garage known as Council Depot. Located adjacent to the east is the Marillac nursing home and to the west there is a local centre with retail and commercial uses, beyond which there are predominantly residential uses.
* 'The southern parcel' - 7.14 hectares (17.64 acres) of land to the south of Eagle Way where the main office building is located. The 6-7 storey office building has a NIA of 43,664 sq.m (470,000 sq.ft.), together with an ancillary data centre building, car parking and landscaping. The southern parcel is bounded by woodland and Warley Gap to the south, Clive Road to the west, Eagle Way to the north and woodland to the east. There are two dwellings located within 70m south of the site, with the Essex Regiment Chapel and Royal Anglian Regiment being located to the west.
b. Response to AFC Consultation
Amended Housing Trajectory
In line with Ford's previous representations, we wish to request that the draft allocation for the Site within the next stage of the new Local Plan is updated to reflect the Site's anticipated availability earlier in the Plan period. Notably, it is realistic that the site could be delivered within 6 -10 years (2021-2025) versus the 9 -17 years (2025-2033) (currently stated in Appendix 1 of the AFC). The HELAA 2018, presented data in table 2 which indicated that the potential new housing trajectory for the borough would be brought forward on brownfield sites within the early years in the Plan.
All potential options should be explored in detail to increase the supply of housing in the early years. We therefore request that BBC review and update the Site's inclusion in the housing trajectory, including considering the Ford owned and Council Depot sites separately (see further comments below) - bringing forward the Ford owned land in years 6-10 (which Ford have demonstrated is available and deliverable). In our opinion this is necessary in order to ensure the Plan is positively prepared, having regard to the requirements of Paragraph 35 of the NPPF 2019.
We maintain that the BBC's proposed phased approach to the annual housing requirement, may not deliver sufficient quantum of housing within the early years of the Plan following adoption. As such we consider that this approach would be unsound, as the Plan would not be positively prepared in this regard, unless clear evidence can be provided to demonstrate that all potential options to boost housing supply in the early years of the Plan have been explored in detail.
The Ford site is already identified by BBC as a proposed allocation and will make a vital contribution towards the anticipated trajectory in this context, particularly as a less constrained medium scale site. However, we consider that the further efforts should be made to ensure the capacity for the site to deliver housing on brownfield land early in the plan period are maximised, in order to ensure that the annual requirement is sound.
Draft Policy R04 and R05: Ford Headquarters and Council Depot
Ford notes that the current draft policy includes the Warley Site under draft 'Site Allocation R04' (Land South of Eagle Way)' and 'Site Allocation R05' (Land North of Eagle Way)' (collectively referred to as
3
the 'Ford Headquarters and Council Depot, Warley for housing and employment development, with the potential for specialist care accommodation (referred to as 'Other Indicative uses').
The draft allocation sets out that sites R04 and Ro5 have a collective site area of 9.4 hectares (ha) of which, 8 ha is developable; with an indicative dwelling yield (net) of 473 residential units across the two sites. The allocations are currently anticipated by BBC to come forward within years 9-17 of the proposed plan period. The Ford owned land can be delivered in the early years of the plan period and we would challenge the proposed housing trajectory for the site as outlined in Appendix 1: Schedule of Focussed Changes to Brentwood Pre-Submission Local Plan (October 2019).
Ford remains broadly supportive of the strategic housing allocation but recognises that the current pairing of the Headquarters and the Depot has potential to limit the delivery of the site in the short to medium term. We are aware that the Depot currently has no scheduled availability date at this stage and its employment function will need to be moved elsewhere in the Borough. In the interest of early delivery, we are proposing that the Northern Land parcel (R05) is separated from the Southern parcel (R04), enabling the site to come forward for housing in the early years of the plan period. This is supported through Ford providing certainty over the future availability of the Site as part of the headquarters relocation and long standing, open engagement with BBC - in addition to formal representations to all previous consultations to the emerging Local Plan.
The need for BBC to identify additional land for housing is also required in order address cross-boundary pressures such as London's future housing growth, which has been exemplified within relevant London Plan EiP hearing sessions. In this context, the Mayor of London has confirmed that local planning authorities within the wider south east, where the housing market is influenced by that of London should be working collaboratively with the GLA to significantly boost the supply of housing and ensure that Local Plans meet full objectively assessed needs. The arrival of Crossrail at Brentwood and Shenfield further exemplifies this requirement. This will undoubted bring even greater connections to central London, inevitably resulting in an increase in people living in the local area. This places further pressure on land for development, with the Site at Warley providing a key brownfield opportunity for much need new housing.
We consider the Ford Warley Site to the be a highly deliverable site, available for housing development. The NPPF (2019) is clear in stating that "to be considered deliverable, sites should be available now, offer a suitable location for development, and be achievable with a realistic prospect that housing will be delivered on site within five years." The current plan, its Housing Trajectory and inclusion of the Ford site should be updated in line with this national requirement.
c. Summary
We trust that this letter provides further information to inform amendments to the Pre-submission Local Plan 2019. We request that the housing trajectory is updated to reflect the early delivery of new housing at the Site within plan period years 6-10. Our Client would welcome discussing this in further detail with BBC, prior to the Pre-submission Local Plan (2019) being submitted to the Secretary of State. Should you have any questions please do not hesitate to contact me (agale@iceniprojects.com) or my colleague Lucy Howes (lhowes@iceniprojects.com).

Request that BBC review and update the Site's inclusion in the housing trajectory, including considering the Ford owned and Council Depot sites separately (see further comments below) - bringing forward the Ford owned land in years 6-10 (which Ford have demonstrated is available and deliverable). In our opinion this is necessary in order to ensure the Plan is positively prepared, having regard to the requirements of Paragraph 35 of the NPPF 2019.

Iceni Projects Limited ('Iceni') are appointed by Ford Motor Company ('Ford' / our 'Client') to advise on planning matters associated with its commercial assets at Eagle Way, Warley, Brentwood (the Site'). Iceni has been instructed by Ford to prepare and submit comments on the 'focused changes' to the pre-submission' Local Plan (2019) consultation.
On behalf of our Client, we welcome the opportunity to comment the Addendum of Focussed Changes to the Pre-Submission Local Plan ('AFC' October 2019). This is the final stage of consultation on the new Local Plan, following which the plan will be submitted to the Planning Inspectorate for independent examination. It is noted that Ford have submitted representations to each stage of consultation to date, including promotion of the site for housing and delivery in the earliest years of the plan period.
We therefore assert that this stage of consultation should consider comments on the soundness of the document in line with the National Planning Policy Framework ('NPPF') (2019) - including whether the plan has been positively prepared, is justified, effective and consistent with national planning policy.
Our Client is broadly supportive of the Site's Draft allocation as a strategic site for housing under Draft Policy RO4 and RO5: 'Ford Headquarters and the Council Depot'. However, and in accordance with the tests of soundness, we wish to question the below aspects of the draft allocation (in the absence of robust evidence) and the inclusion of the site within years 9-17 of the Housing Trajectory as shown
in Appendix 1 of the AFC (versus years 6-10):
* Retention of 2.0 hectares of employment land - Land south of Eagle Way (i.e. main Ford Headquarters);
* Delivery of residential care home providing 60 x bed spaces; and
* 5% self-build and custom build across the entire allocation (including the Council Depot).
This is contrary to the fundamental sustainability objectives of the NPPF and all previous representations submitted by Ford, demonstrating the early deliverability and availability of the Site in providing much needed housing for the Borough - at a brown field location. Our Client therefore considers that the current plan has failed to be positively prepared and should therefore be reviewed prior to Examination in public.
This representation is submitted in line with the consultation deadline of Tuesday 26th November 2019.
a. The Site
Location / Description
The Site comprises of 8.51 hectares (21.03 acres) of land located within Warley, forming the southern edge of the Brentwood settlement boundary. It is located approximately 1.36km south of Brentwood Train Station and 2.5km southeast of Junction 28 of the M25 Motorway.
Eagle Way runs east-west through the Site, dividing it into two parcels of land, as outlined below:
* 'The northern parcel' - 1.37 hectares (3.39 acres) of land to the north of Eagle Way, currently utilised for staff car parking. A bus station is located on The Drive which runs along the western boundary, with Eagle Way running along the southern boundary of the northern parcel. To the north there is council-owned land which is currently being utilised as additional car parking, as well as the highways depot and auto garage known as Council Depot. Located adjacent to the east is the Marillac nursing home and to the west there is a local centre with retail and commercial uses, beyond which there are predominantly residential uses.
* 'The southern parcel' - 7.14 hectares (17.64 acres) of land to the south of Eagle Way where the main office building is located. The 6-7 storey office building has a NIA of 43,664 sq.m (470,000 sq.ft.), together with an ancillary data centre building, car parking and landscaping. The southern parcel is bounded by woodland and Warley Gap to the south, Clive Road to the west, Eagle Way to the north and woodland to the east. There are two dwellings located within 70m south of the site, with the Essex Regiment Chapel and Royal Anglian Regiment being located to the west.
b. Response to AFC Consultation
Amended Housing Trajectory
In line with Ford's previous representations, we wish to request that the draft allocation for the Site within the next stage of the new Local Plan is updated to reflect the Site's anticipated availability earlier in the Plan period. Notably, it is realistic that the site could be delivered within 6 -10 years (2021-2025) versus the 9 -17 years (2025-2033) (currently stated in Appendix 1 of the AFC). The HELAA 2018, presented data in table 2 which indicated that the potential new housing trajectory for the borough would be brought forward on brownfield sites within the early years in the Plan.
All potential options should be explored in detail to increase the supply of housing in the early years. We therefore request that BBC review and update the Site's inclusion in the housing trajectory, including considering the Ford owned and Council Depot sites separately (see further comments below) - bringing forward the Ford owned land in years 6-10 (which Ford have demonstrated is available and deliverable). In our opinion this is necessary in order to ensure the Plan is positively prepared, having regard to the requirements of Paragraph 35 of the NPPF 2019.
We maintain that the BBC's proposed phased approach to the annual housing requirement, may not deliver sufficient quantum of housing within the early years of the Plan following adoption. As such we consider that this approach would be unsound, as the Plan would not be positively prepared in this regard, unless clear evidence can be provided to demonstrate that all potential options to boost housing supply in the early years of the Plan have been explored in detail.
The Ford site is already identified by BBC as a proposed allocation and will make a vital contribution towards the anticipated trajectory in this context, particularly as a less constrained medium scale site. However, we consider that the further efforts should be made to ensure the capacity for the site to deliver housing on brownfield land early in the plan period are maximised, in order to ensure that the annual requirement is sound.
Draft Policy R04 and R05: Ford Headquarters and Council Depot
Ford notes that the current draft policy includes the Warley Site under draft 'Site Allocation R04' (Land South of Eagle Way)' and 'Site Allocation R05' (Land North of Eagle Way)' (collectively referred to as
3
the 'Ford Headquarters and Council Depot, Warley for housing and employment development, with the potential for specialist care accommodation (referred to as 'Other Indicative uses').
The draft allocation sets out that sites R04 and Ro5 have a collective site area of 9.4 hectares (ha) of which, 8 ha is developable; with an indicative dwelling yield (net) of 473 residential units across the two sites. The allocations are currently anticipated by BBC to come forward within years 9-17 of the proposed plan period. The Ford owned land can be delivered in the early years of the plan period and we would challenge the proposed housing trajectory for the site as outlined in Appendix 1: Schedule of Focussed Changes to Brentwood Pre-Submission Local Plan (October 2019).
Ford remains broadly supportive of the strategic housing allocation but recognises that the current pairing of the Headquarters and the Depot has potential to limit the delivery of the site in the short to medium term. We are aware that the Depot currently has no scheduled availability date at this stage and its employment function will need to be moved elsewhere in the Borough. In the interest of early delivery, we are proposing that the Northern Land parcel (R05) is separated from the Southern parcel (R04), enabling the site to come forward for housing in the early years of the plan period. This is supported through Ford providing certainty over the future availability of the Site as part of the headquarters relocation and long standing, open engagement with BBC - in addition to formal representations to all previous consultations to the emerging Local Plan.
The need for BBC to identify additional land for housing is also required in order address cross-boundary pressures such as London's future housing growth, which has been exemplified within relevant London Plan EiP hearing sessions. In this context, the Mayor of London has confirmed that local planning authorities within the wider south east, where the housing market is influenced by that of London should be working collaboratively with the GLA to significantly boost the supply of housing and ensure that Local Plans meet full objectively assessed needs. The arrival of Crossrail at Brentwood and Shenfield further exemplifies this requirement. This will undoubted bring even greater connections to central London, inevitably resulting in an increase in people living in the local area. This places further pressure on land for development, with the Site at Warley providing a key brownfield opportunity for much need new housing.
We consider the Ford Warley Site to the be a highly deliverable site, available for housing development. The NPPF (2019) is clear in stating that "to be considered deliverable, sites should be available now, offer a suitable location for development, and be achievable with a realistic prospect that housing will be delivered on site within five years." The current plan, its Housing Trajectory and inclusion of the Ford site should be updated in line with this national requirement.
c. Summary
We trust that this letter provides further information to inform amendments to the Pre-submission Local Plan 2019. We request that the housing trajectory is updated to reflect the early delivery of new housing at the Site within plan period years 6-10. Our Client would welcome discussing this in further detail with BBC, prior to the Pre-submission Local Plan (2019) being submitted to the Secretary of State. Should you have any questions please do not hesitate to contact me (agale@iceniprojects.com) or my colleague Lucy Howes (lhowes@iceniprojects.com).