We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,

We welcome the opportunity to submit representations to the above consultation on behalf St. Modwen and S & J Padfield and Partners, who control the land identified as the Brentwood Enterprise Park (E11) in the Pre-Submission Local Plan. This submission to the Consultation on the Addendum of Focussed Changes (AFC) is made having regard to the previous representations submitted at the Regulation 19 stage consultation in March 2019 in respect of site E11.
Previous representations and focused changes
Representations were made to the Pre-Submission Local Plan (Regulation 19) Consultation in March 2019, and set out proposed amendments to the wording of the policies associated with the site in particular with regard to the allocation areas required to provide for site access and, flexibility regarding the delivery of infrastructure requirements, and also that the site can come forward earlier in the plan period (1-5 years). Furthermore, the representations commented on various documents making up the evidence for the Local Plan, including the Strategic Environmental Assessment Sustainability Appraisal (SEA/SA) and Infrastructure Delivery Plan (IDP).
The information submitted to the Council contained within the representations was intended to promote an opportunity for possible amendments to the Local Plan before submission for Examination. We note some of these changes have not at present been included as part of this focused consultation and we consider it important these are considered further prior to formal submission. These changes are set out in the attached representation, and listed below for reference;
 Amendments to the wording of Policy E11 concerning the Public Right of Way, Infrastructure Requirements, and timescales of the delivery of the Brentwood Enterprise Park;
 Additional updates to policies concerning Green Belt and Landscaping requirements;
 Amendments to the Economic evidence base documents relating to the anticipated provision of jobs;
 Updates to the Transport evidence base documents, including provision of additional information showing land required to achieve access and in the case that the proposed Lower Thames Crossing comes forward at a later date.
 Amendments to draft policies set out in the sections relating to; Spatial Objectives, Transport and Connectivity, Prosperous Communities, and Natural Environment.
 Comments and proposed amendments to the assessment of the site within the Sustainability Appraisal, particularly with regard to scores given against certain criteria of the assessment.
Whilst we have no comments on the proposed reduction to the number of homes for Blackmore or Shenfield, we do consider that minor amendments, such as those listed above, should be able to be made to other allocations within the Regulation 19 Pre-submission Local Plan where required, such as site E11.
To support our representations, we draw attention to requirements of the National Planning Policy Framework (NPPF) that Plans should;
 Make sufficient provision for employment development (Para 20, a));
 Ensure that new housing has sufficient access to services and employment opportunities (Para 72, b));
 Take a positive approach to applications for alternative uses of land which is currently developed, but not allocated for a specific purpose in plans, where this would help to meet identified development needs. In particular, they should support proposals to use retail and employment land for homes in areas of high housing demand (Para 121, a)).
Our submitted representations supporting the allocations for E11 at pre-submission stage in March emphasise that the Brentwood Enterprise Park can be relied upon to deliver 55% of the Borough's employment land requirement.
Whilst it appears to be the councils view that none of the focused changes directly impact on the BEP site, it is our view that the consultation does provide an opportunity for the council to set out and explain updates on key matters which may not be considered to be minor. We would like to reiterate the points made in our Regulation 19 Representation, as set out earlier in this submission.
We have also noted that the Council have published a number of updates to various evidence base documents alongside the Pre-Submission Local Plan. We have made further comments on the updates on certain documents as set out below;
Infrastructure Delivery Plan
The Infrastructure Delivery Plan (IDP) has been updated to October 2019. The Development Typology chapter of the IDP provides a detailed breakdown of anticipated employment. This includes anticipated floor space from the different sites along with job totals, with pages 34-35 covering the contribution which is likely made by the Enterprise Park site. This chapter more accurately reflects the anticipated job numbers set out within information that we previously submitted to the Council, specifying that the Brentwood Enterprise Park has the potential to deliver circa 2,435 jobs across a number of sectors.
The Transport and Movement chapter also provides details on measures proposed to facilitate safe and efficient access to the allocated site. Such measures include:
- T16 - A127 Corridor Strategic Cycle Route
- T17 - A127 Bus Infrastructure
- T18 - West Horndon New Transport Interchange
We note the above measures are listed as likely to be delivered in the Medium to Long term. It is anticipated that employment provision at Brentwood Enterprise Park will commence early in the Local Plan period to provide jobs to support growth in the Borough, and consider it is imperative that these measures are planned for the immediate term in order to support the much needed employment provision.
We also consider the Transport & Movement document should also make reference to the potential role that Demand Responsive public transport can play. As the Council is aware, this element of the Transport work is being progressed by a number of parties who are engaging proactively in seeking to rationalise and progress solutions for delivering the identified sites along the Southern Growth Corridor (SGC), and this should be referenced in the IDP.
Currently, the sections of the Transport and Movement document referring to buses are focused on provision of traditional fixed route bus services, which may only one be solution adopted at Brentwood Enterprise Park. Additional work is required by all parties with regard to the proposed segregated cycle network for the southern growth corridor if this is to be delivered without the need for third party land and the progression of development on key sites should therefore not be reliant on this from day one.
With regard to specific mitigation measures, T24 covers improvements at the B186/A127 junction. We are currently in discussion with ECC as to how the proposed access to Brentwood Enterprise Park can be delivered alongside these solutions. It should be noted that the measures set out at T24 will need to cater for the wider planned growth in the Borough, and not be seen as a measure wholly to ensure the delivery of the Brentwood Enterprise Park.
Sustainability Appraisal (Oct 2019)
We note the Sustainability Appraisal has been republished dated October 2019 but does not appear to have been updated to reflect our previous comments. At present, the Brentwood Enterprise Park site continues to be scored negatively against Local Wildlife Site, Ancient Wood and AQMA, GP, and school provision. Our previous representation states that we consider these criteria should be considered differently when applied to an allocation for employment land rather than residential proposals. Additionally, it is considered that through appropriate design and landscaping, any adverse impacts can be avoided. A neutral or 'depending on implementation' scoring for a number of these criteria would be much more appropriate. We would state that the same comment applies to the allocation at Codham Hall Farm (101C), which has also scored negatively against Local Wildlife Sites.
The commentary on Economy and Employment also refers to the 'Enterprise Corridor' and the role of the Enterprise Park along the corridor. We note that paragraph 9.6.8 suggests that access will be directly to Junction 29 and the M25, while the draft plan indicates that access may be achieved via the B186.
We would welcome further liaison with the Council regarding this submission and our previous representations as the Local Plan proceeds to the examination stage.
I would be grateful to receive acknowledgment of this representation. If you require any further information, please do not hesitate to get in touch.
Yours sincerely,