Freeths LLP act on behalf of both Simons Developments Limited (SDL) and R P Gaymer (the freehold owner of Site Reference 079C which comprises of 2.06 hectares of land adjacent to Ingatestone by pass part bounded by Roman Road). SDL have been selected as the preferred developer should the site be allocated in the emerging Development Plan (DP).

The proposed removal of the site from the Green Belt is supported, particularly given that the site is well related to the existing built up area of Ingatestone and does not fulfil any of the five purposes for including land in the Green Belt that are set out at Paragraph 80 of the National Planning Policy Framework (the Framework).

However, SDL and R P Gaymer object to the allocation as currently proposed in the draft DP for the reasons set out below.

The proposed allocation solely for employment uses (within Class B of the Use Classes Order) and the restrictive nature of criterion a - d which form part of Policy 8.4 is a sub optimal land use strategy and a wider allocation for a mix of uses would be more sustainable over the draft DP period to 2030.

More specifically, Ingatestone is identified as a Settlement Category 2 Village Service Centre and Paragraph 5.28 of the draft DP notes that it is "a district shopping centre with a good range of jobs, community and health facilities. As the largest village facilities here serve a significant catchment beyond the immediate area. Public transport accessibility is relatively good. The village has a rail station and a secondary school".

By way of additional background it is also noted that the Brentwood Retail and Commercial Leisure Study (BR&CLS) 2014 concludes, in its Audit of Centres at Appendix 5, that one of the weaknesses of Ingatestone is that it's food stores are quite small and do not attract a significant proportion of main and bulk shopping trips.

The above position is further supported by the results of the NEMS Household survey undertaken as part of the BR&CLS which identifies that the existing food stores in Ingatestone attract only a small percentage of available convenience goods (food) expenditure from the local area. To be specific the Co- Op attracts 8.2% and Budgens 9.9% (Table 4 of Appendix 2 of the BR&CLS).

Put simply the above market share of available convenience goods expenditure from the local area is very low and not characteristic of a district centre which serves a significant catchment beyond the immediate area. The result is an unsustainable pattern of main and bulk food shopping with predominately car based trips to large format out of centre food stores further afield.

Whilst the BR&CLS identifies a requirement for only 364 sq m of retail floorspace falling with Use Classes A1 to A5 over the DP period that is again, based on the existing market share for Ingatestone which is, as above, not a sustainable pattern of shopping consistent with the role and function of a district centre.

The above position is unlikely to change unless the emerging DP is amended to include a specific allocation of land on which retail uses within Classes A1 to A5 of the Use Classes Order (retail, financial and professional services, cafe/restaurant, drinking establishment and hot food takeaway uses) can be accommodated. In that context Site Reference 079C is well located proximate to the existing district centre such to ensure linked trips with existing shops therefore benefiting from the resulting increase in market share that such additional provision on Site Reference 079C would secure,

Accordingly, whilst Site Reference 079C should continue to be allocated for employment uses within Use Class B, Policy 8.4 - in so far as it relates to the site - should be amended to refer to a wider mix of appropriate land uses to include uses within Classes A1 to A5 subject of course to other policies in the emerging DP. In any event uses with Use Classes A1 - A5 (particularly a new food store) would generate a significant number of new jobs thereby ensuring that employment opportunities are provided also further contributing to the long term sustainability of Ingatestone.

In addition, and again in the interests of contributing towards the long term sustainability of Ingatestone, any mixed use allocation in respect of Site Reference 079C should also be drafted to include residential institutions such as a care home within Use Class C2 of the Use Classes Order. Again such uses make a significant contribution towards the provision of employment opportunities.

The changes proposed above are consistent with Strategic Objectives (SO) 1, 2, 4, 6 and 13 of the draft DP and also with Policy 5.1 in respect of the wider spatial strategy which identifies that Ingatestone is a sustainable location for growth (including new homes as per Policy 5.2 and 7.4 (in so far as it relates to Site Reference 079A), Policy 5.3 in respect of job growth and employment land which specifically acknowledges that retail and leisure uses contribute towards employment targets over the DP period, Policy 7.7 in respect of the provision of specialist housing such as within Class C2; and Policy 8.7 in respect of the role of local centres and the hierarchy of centres at Appendix 2.

A linked objection has however been made in respect of Policy 5.4 Retail and Commercial Leisure Growth and Policy 8.8 New Retail Development both of which fail to make adequate provision for Ingatestone as identified above.

These representations are submitted in order to form the basis of a constructive dialogue with the local planning authority with the objective of ensuring a more sustainable land allocations strategy to meet all of Ingatestones needs over the DP period to 2030.