The Plan identifies a number of potential preferred allocation sites for employment development, each with their own characteristics and ability to deliver space for a variety of B Class uses. Further assessment could usefully be undertaken to understand more precisely what each of these sites, particularly at East Horndon Hall and DHGV could most usefully deliver. The plan currently envisages a 5.5ha site for dedicated employment uses at DHGV but correctly notes at paragraph 123 that "The exact range and type of employment development at Dunton Hills is still subject to detailed site master planning, but will need to be compatible with residential uses and of a human scale which is appropriate to a garden village." Preferred Allocation 187 on land south of East Horndon Hall is specifically allocated for employment purposes with the note "Self-contained employment site capable of being linked to DHGV proposals. This allows for increased development of new homes at Dunton Hills." Finally, on this point, the Employment Typology contained in the draft IDP identifies the 5.5 hectares of employment land at DHGV as potentially including land for B1a, B1b (Research and Development,), B1c, B2 and B8 uses.
In the Promoters view the precise scale, type and location of any employment land allocation at DHGV, whether with or without the development on land south of East Horndon Hall requires further assessment. Paragraph 5.13 of the Lichfield document states that the provision of future employment land should consider carefully how businesses use premises. The report concludes on this point that "These factors mean that the Council will need to plan for a flexible employment land supply."
The changing requirements for employers and the changing nature of employment with improved technology raises genuine opportunities for new settlements such as DHGV to deliver a different form of employment generation. Economies of scale and the potential to incorporate infrastructure including high speed broadband comprehensively and from the start of development affords the opportunity to consider efficient and sustainable home working, perhaps with shared meeting facilities within the village. The Promoters continue to investigate the potential for this form of technological innovation and intend to include appropriate references within subsequent applications for planning permission. In the meantime, though it is important that opportunities of this kind are captured in any allocation policy.
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The Promoters support the economic aims and Strategic Priorities of the Plan. These contain an understanding of the contribution which Brentwood borough as a whole can make to the economic prosperity of the UK and the more immediate area in south Essex. The assessments, which include the evidence base contained in the final report of 'Brentwood Economic Futures 2013-2033 prepared by Lichfields and dated January 2018 confirms at Fig 4 and paragraph 4.12 that in all scenarios assessed for the borough as a whole the draft Local Plan will ensure a surplus of land for B1c/B2 and B8 uses but may see a shortage to meet future B1a/b requirements.
In our view, the employment land needs require some further assessment particularly taking account of the opportunities for innovative provision of space at DHGV.
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The preferred allocations have been identified through a sound and proportionate process in the preparation of the various stages of the Local Plan so far. Further clarification and assessment is required as the process progresses towards its Regulation 19 stage. These representations make comment only on the DHGV preferred allocation on which the Promoters represent the land owner, promotion and delivery strategy. As stated elsewhere in these representations, the Promoters have appointed a full consultant team and since agreeing promotion terms in 2015 have undertaken a substantial amount of site specific assessment. This assessment has confirmed the suitability and capacity of the site and confirmed that the site is 'developable' and capable of delivering homes for occupation on site from 2022. Subject to further investigations concerning market signals, early delivery of infrastructure, housing typologies, employment land typologies, early submission of applications for planning permission and innovative construction techniques the Promoters are confident that the development could deliver more homes within the plan period than the 2,500 originally considered by earlier stages of the process. The Promoters anticipate further progress on this over the next few months. The representations made here and in additional documents seek to outline the principal conclusions from some of the assessments already undertaken by the Promoters in relation to the suitability of DHGV.
As part of a clear process of assessment sufficient to give confidence that the largest strategic housing led allocation in the plan is deliverable and is so in such a way that it would achieve the intended vision and strategic objectives of the Local Plan the Promoters have made available and will continue to make available to the Local Plan process all appropriate assessments. In addition, the Promoters believe that in order to ensure that the policy framework for DHGV provides sufficient clarity to comply with Local Plan guidance, give confidence that the development will achieve garden village principles within the specific context of Brentwood and deliver homes early a dedicated new settlement chapter should be contained in the Regulation 19 These representations contain suggested chapter headings and envisage the incorporation of two separate but linked policies, one outlining Garden Village Principles and a second detailing some of the site specific requirements for DHGV. Plan. Not only would such a chapter and policies 'anchor' subsequent applications for planning permission with a sound policy framework they would satisfy the aim of Planning Practice Guidance (PPG) paragraph 12-010.
"Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interests about the nature and scale of development (addressing the 'what, where, when and how' questions).
The Promoters, together with stakeholders, continue to undertake further assessments. The intention is to feed these assessments into the suggested policies where appropriate. Revisions may include references to scale and size of community facilities to be provided, the scale and nature of the mix of housing tenures and types and detail of employment mix. In the meantime, the additional documents submitted with these representations and references to earlier evidence prepared by the Promoters may assist in the necessary understanding.