I refer to the current "Regulation 18" consultation on the Brentwood Draft Local Plan Site Allocations Development Plan Document (DPD) and set out below comments on behalf of Simons Developments Limited and R P Gaymer on the DPD in so far as it relates to their land interests at Ingatestone.

You will recall that we commented on the previous "Regulation 18" consultation in March 2016 with reference to 2.06 hectares of land to the east of Ingatestone By Pass fronting Roman Road. The broad thrust of those representations supported the removal of the site from the Green Belt and its proposed allocation for employment uses but sought a wider allocation to include for other employment generating uses outside of Class B of the Use Classes Order. Specifically the employment generating benefits of including retail uses (Classes A1 - A5) and residential care (Class C2) were noted alongside commentary as to how new convenience (food) retail floorspace would address an existing deficiency in local food shopping provision.

Following meetings to discuss the above representations we submitted a detailed Statement of Delivery in late 2016 which was supported by highways, flood risk and drainage, noise, ecology, landscape and visual impact, and heritage analysis. On the basis that Statement has not been submitted thus far as part of any formal consultation it is attached to Email 2 of these representations for completeness.

In so far as the current Preferred Site Allocations DPD is concerned I set out below a number of observations:

1. We welcome the additional housing proposed at Ingatestone which equates to 218 new dwellings over the plan period.

2. The additional residential development will exacerbate the existing deficiency in local food shopping provision. As previously identified Ingatestone - by reference to the Brentwood Retail and Commercial Leisure Study (BR&CLS) 2014 - attracts only a small percentage of available convenience goods expenditure from the local area. Specifically, the Co-Op attracts only 8.2% and the Budgens 9.9% of that expenditure. This is very low and represents an unsustainable pattern of food shopping with a significant number of linked trips to large format out of centre food stores further afield.

3. Figure 23 of the Preferred Site Allocations DPD identifies an employment land requirement of between 33.76 hectares and 45.96 hectares and an allocation of 47.39 hectares. Whilst that is a surplus of +0.43 hectares against the upper requirement allowing for pipeline change of use it is a surplus of +12.63 hectares against the lower requirement. Accordingly there is clear scope for flexibility and a wider mix of uses on the proposed allocation at Ingatestone.

4. Whilst it is appreciated that this current "Regulation 18" consultation is effectively a rerun of of that undertaken in March 2016 save for the introduction of additional housing and employment sites the local planning authority has missed an opportunity to incorporate greater flexibility at this early stage of the plan making process.

5. Against the background of the numbered points above we would welcome a further dialogue with the local planning authority prior to "Regulation 19" consultation in order to ensure that the emerging Preferred Site Allocations DPD contains a policy framework which is sufficiently flexible to deliver a mixed use scheme along the lines of that proposed at Section 5 of the Statement of Delivery. That scheme would deliver 134-192 new jobs. That being significantly higher than a scheme of Class B uses only.

6. It is understood that the local planning authority is in the process of updating its evidence base in respect of retail planning matters and we would welcome the opportunity to engage with officers and their appointed consultants regarding the case to underpin further retail floorspace in Ingatestone.

In addition to the above Simons Developments Limited and R P Gaymer propose a further allocation in Ingatestone as per summary discussions with Officers in late 2017. That site is the "Island Site" as identified on the plan attached to Email 3. The site comprises 1.22 hectares of land effectively circled by Roman Road to the west of the A12. It is suggested that the site be allocated for Class B uses.

During our initial discussions with you further information on access and landscape impact was requested and that has now been completed. That analysis concludes that:

1. The site can be safely accessed. See Highways Technical Note prepared by Connect Consultants attached to Email 4.

2. The site can be developed without adverse landscape and visual impact. See Landscape Briefing Note prepared by Aspect Landscape Planning attached to Email 5. That notes that the sites proximity to the A12 and the existing urban edge combined with topography and vegetation provide an opportunity for development with only glimpses views from transient receptors moving along road corridors within the context of the urban edge.

Based on the above there is a clear opportunity for the allocation of further land for employment uses at Ingatestone should the local planning authority remain concerned about the ability to meet its upper requirement.

Whilst we do not consider it essential in order to justify a broader mix of uses on the primary site (land fronting Roman Road) the "Island Site" could sensibly be allocated or safeguarded for employment uses to come forward during the plan period as and when required in response to market demand.

In so far as the primary site is concerned we would welcome the opportunity to agree a draft allocation policy for "Regulation 19" consultation and based on our experience nationwide that would ideally specify the uses identified in the Statement of Delivery or recognise the benefits and acceptability of other employment generating uses subject to compliance with other policies in the plan. The former would clearly provide greater certainty and is in our view appropriate given the deficiency in local food shopping provision particularly.

I trust that the above and attachments on Emails 2, 3, 4, and 5 are of assistance and look forward to discussing further in due course.

If you could confirm safe receipt of these emails that would be appreciated.

Best regards

I refer to the current "Regulation 18" consultation on the Brentwood Draft Local Plan Site Allocations Development Plan Document (DPD) and set out below comments on behalf of Simons Developments Limited and R P Gaymer on the DPD in so far as it relates to their land interests at Ingatestone.

You will recall that we commented on the previous "Regulation 18" consultation in March 2016 with reference to 2.06 hectares of land to the east of Ingatestone By Pass fronting Roman Road. The broad thrust of those representations supported the removal of the site from the Green Belt and its proposed allocation for employment uses but sought a wider allocation to include for other employment generating uses outside of Class B of the Use Classes Order. Specifically the employment generating benefits of including retail uses (Classes A1 - A5) and residential care (Class C2) were noted alongside commentary as to how new convenience (food) retail floorspace would address an existing deficiency in local food shopping provision.

Following meetings to discuss the above representations we submitted a detailed Statement of Delivery in late 2016 which was supported by highways, flood risk and drainage, noise, ecology, landscape and visual impact, and heritage analysis. On the basis that Statement has not been submitted thus far as part of any formal consultation it is attached to Email 2 of these representations for completeness.

In so far as the current Preferred Site Allocations DPD is concerned I set out below a number of observations:

1. We welcome the additional housing proposed at Ingatestone which equates to 218 new dwellings over the plan period.

2. The additional residential development will exacerbate the existing deficiency in local food shopping provision. As previously identified Ingatestone - by reference to the Brentwood Retail and Commercial Leisure Study (BR&CLS) 2014 - attracts only a small percentage of available convenience goods expenditure from the local area. Specifically, the Co-Op attracts only 8.2% and the Budgens 9.9% of that expenditure. This is very low and represents an unsustainable pattern of food shopping with a significant number of linked trips to large format out of centre food stores further afield.

3. Figure 23 of the Preferred Site Allocations DPD identifies an employment land requirement of between 33.76 hectares and 45.96 hectares and an allocation of 47.39 hectares. Whilst that is a surplus of +0.43 hectares against the upper requirement allowing for pipeline change of use it is a surplus of +12.63 hectares against the lower requirement. Accordingly there is clear scope for flexibility and a wider mix of uses on the proposed allocation at Ingatestone.

4. Whilst it is appreciated that this current "Regulation 18" consultation is effectively a rerun of of that undertaken in March 2016 save for the introduction of additional housing and employment sites the local planning authority has missed an opportunity to incorporate greater flexibility at this early stage of the plan making process.

5. Against the background of the numbered points above we would welcome a further dialogue with the local planning authority prior to "Regulation 19" consultation in order to ensure that the emerging Preferred Site Allocations DPD contains a policy framework which is sufficiently flexible to deliver a mixed use scheme along the lines of that proposed at Section 5 of the Statement of Delivery. That scheme would deliver 134-192 new jobs. That being significantly higher than a scheme of Class B uses only.

6. It is understood that the local planning authority is in the process of updating its evidence base in respect of retail planning matters and we would welcome the opportunity to engage with officers and their appointed consultants regarding the case to underpin further retail floorspace in Ingatestone.

In addition to the above Simons Developments Limited and R P Gaymer propose a further allocation in Ingatestone as per summary discussions with Officers in late 2017. That site is the "Island Site" as identified on the plan attached to Email 3. The site comprises 1.22 hectares of land effectively circled by Roman Road to the west of the A12. It is suggested that the site be allocated for Class B uses.

During our initial discussions with you further information on access and landscape impact was requested and that has now been completed. That analysis concludes that:

1. The site can be safely accessed. See Highways Technical Note prepared by Connect Consultants attached to Email 4.

2. The site can be developed without adverse landscape and visual impact. See Landscape Briefing Note prepared by Aspect Landscape Planning attached to Email 5. That notes that the sites proximity to the A12 and the existing urban edge combined with topography and vegetation provide an opportunity for development with only glimpses views from transient receptors moving along road corridors within the context of the urban edge.

Based on the above there is a clear opportunity for the allocation of further land for employment uses at Ingatestone should the local planning authority remain concerned about the ability to meet its upper requirement.

Whilst we do not consider it essential in order to justify a broader mix of uses on the primary site (land fronting Roman Road) the "Island Site" could sensibly be allocated or safeguarded for employment uses to come forward during the plan period as and when required in response to market demand.

In so far as the primary site is concerned we would welcome the opportunity to agree a draft allocation policy for "Regulation 19" consultation and based on our experience nationwide that would ideally specify the uses identified in the Statement of Delivery or recognise the benefits and acceptability of other employment generating uses subject to compliance with other policies in the plan. The former would clearly provide greater certainty and is in our view appropriate given the deficiency in local food shopping provision particularly.

I trust that the above and attachments on Emails 2, 3, 4, and 5 are of assistance and look forward to discussing further in due course.

If you could confirm safe receipt of these emails that would be appreciated.

Best regards

I refer to the current "Regulation 18" consultation on the Brentwood Draft Local Plan Site Allocations Development Plan Document (DPD) and set out below comments on behalf of Simons Developments Limited and R P Gaymer on the DPD in so far as it relates to their land interests at Ingatestone.

You will recall that we commented on the previous "Regulation 18" consultation in March 2016 with reference to 2.06 hectares of land to the east of Ingatestone By Pass fronting Roman Road. The broad thrust of those representations supported the removal of the site from the Green Belt and its proposed allocation for employment uses but sought a wider allocation to include for other employment generating uses outside of Class B of the Use Classes Order. Specifically the employment generating benefits of including retail uses (Classes A1 - A5) and residential care (Class C2) were noted alongside commentary as to how new convenience (food) retail floorspace would address an existing deficiency in local food shopping provision.

Following meetings to discuss the above representations we submitted a detailed Statement of Delivery in late 2016 which was supported by highways, flood risk and drainage, noise, ecology, landscape and visual impact, and heritage analysis. On the basis that Statement has not been submitted thus far as part of any formal consultation it is attached to Email 2 of these representations for completeness.

In so far as the current Preferred Site Allocations DPD is concerned I set out below a number of observations:

1. We welcome the additional housing proposed at Ingatestone which equates to 218 new dwellings over the plan period.

2. The additional residential development will exacerbate the existing deficiency in local food shopping provision. As previously identified Ingatestone - by reference to the Brentwood Retail and Commercial Leisure Study (BR&CLS) 2014 - attracts only a small percentage of available convenience goods expenditure from the local area. Specifically, the Co-Op attracts only 8.2% and the Budgens 9.9% of that expenditure. This is very low and represents an unsustainable pattern of food shopping with a significant number of linked trips to large format out of centre food stores further afield.

3. Figure 23 of the Preferred Site Allocations DPD identifies an employment land requirement of between 33.76 hectares and 45.96 hectares and an allocation of 47.39 hectares. Whilst that is a surplus of +0.43 hectares against the upper requirement allowing for pipeline change of use it is a surplus of +12.63 hectares against the lower requirement. Accordingly there is clear scope for flexibility and a wider mix of uses on the proposed allocation at Ingatestone.

4. Whilst it is appreciated that this current "Regulation 18" consultation is effectively a rerun of of that undertaken in March 2016 save for the introduction of additional housing and employment sites the local planning authority has missed an opportunity to incorporate greater flexibility at this early stage of the plan making process.

5. Against the background of the numbered points above we would welcome a further dialogue with the local planning authority prior to "Regulation 19" consultation in order to ensure that the emerging Preferred Site Allocations DPD contains a policy framework which is sufficiently flexible to deliver a mixed use scheme along the lines of that proposed at Section 5 of the Statement of Delivery. That scheme would deliver 134-192 new jobs. That being significantly higher than a scheme of Class B uses only.

6. It is understood that the local planning authority is in the process of updating its evidence base in respect of retail planning matters and we would welcome the opportunity to engage with officers and their appointed consultants regarding the case to underpin further retail floorspace in Ingatestone.

In addition to the above Simons Developments Limited and R P Gaymer propose a further allocation in Ingatestone as per summary discussions with Officers in late 2017. That site is the "Island Site" as identified on the plan attached to Email 3. The site comprises 1.22 hectares of land effectively circled by Roman Road to the west of the A12. It is suggested that the site be allocated for Class B uses.

During our initial discussions with you further information on access and landscape impact was requested and that has now been completed. That analysis concludes that:

1. The site can be safely accessed. See Highways Technical Note prepared by Connect Consultants attached to Email 4.

2. The site can be developed without adverse landscape and visual impact. See Landscape Briefing Note prepared by Aspect Landscape Planning attached to Email 5. That notes that the sites proximity to the A12 and the existing urban edge combined with topography and vegetation provide an opportunity for development with only glimpses views from transient receptors moving along road corridors within the context of the urban edge.

Based on the above there is a clear opportunity for the allocation of further land for employment uses at Ingatestone should the local planning authority remain concerned about the ability to meet its upper requirement.

Whilst we do not consider it essential in order to justify a broader mix of uses on the primary site (land fronting Roman Road) the "Island Site" could sensibly be allocated or safeguarded for employment uses to come forward during the plan period as and when required in response to market demand.

In so far as the primary site is concerned we would welcome the opportunity to agree a draft allocation policy for "Regulation 19" consultation and based on our experience nationwide that would ideally specify the uses identified in the Statement of Delivery or recognise the benefits and acceptability of other employment generating uses subject to compliance with other policies in the plan. The former would clearly provide greater certainty and is in our view appropriate given the deficiency in local food shopping provision particularly.

I trust that the above and attachments on Emails 2, 3, 4, and 5 are of assistance and look forward to discussing further in due course.

If you could confirm safe receipt of these emails that would be appreciated.

Best regards

I refer to the current "Regulation 18" consultation on the Brentwood Draft Local Plan Site Allocations Development Plan Document (DPD) and set out below comments on behalf of Simons Developments Limited and R P Gaymer on the DPD in so far as it relates to their land interests at Ingatestone.

You will recall that we commented on the previous "Regulation 18" consultation in March 2016 with reference to 2.06 hectares of land to the east of Ingatestone By Pass fronting Roman Road. The broad thrust of those representations supported the removal of the site from the Green Belt and its proposed allocation for employment uses but sought a wider allocation to include for other employment generating uses outside of Class B of the Use Classes Order. Specifically the employment generating benefits of including retail uses (Classes A1 - A5) and residential care (Class C2) were noted alongside commentary as to how new convenience (food) retail floorspace would address an existing deficiency in local food shopping provision.

Following meetings to discuss the above representations we submitted a detailed Statement of Delivery in late 2016 which was supported by highways, flood risk and drainage, noise, ecology, landscape and visual impact, and heritage analysis. On the basis that Statement has not been submitted thus far as part of any formal consultation it is attached to Email 2 of these representations for completeness.

In so far as the current Preferred Site Allocations DPD is concerned I set out below a number of observations:

1. We welcome the additional housing proposed at Ingatestone which equates to 218 new dwellings over the plan period.

2. The additional residential development will exacerbate the existing deficiency in local food shopping provision. As previously identified Ingatestone - by reference to the Brentwood Retail and Commercial Leisure Study (BR&CLS) 2014 - attracts only a small percentage of available convenience goods expenditure from the local area. Specifically, the Co-Op attracts only 8.2% and the Budgens 9.9% of that expenditure. This is very low and represents an unsustainable pattern of food shopping with a significant number of linked trips to large format out of centre food stores further afield.

3. Figure 23 of the Preferred Site Allocations DPD identifies an employment land requirement of between 33.76 hectares and 45.96 hectares and an allocation of 47.39 hectares. Whilst that is a surplus of +0.43 hectares against the upper requirement allowing for pipeline change of use it is a surplus of +12.63 hectares against the lower requirement. Accordingly there is clear scope for flexibility and a wider mix of uses on the proposed allocation at Ingatestone.

4. Whilst it is appreciated that this current "Regulation 18" consultation is effectively a rerun of of that undertaken in March 2016 save for the introduction of additional housing and employment sites the local planning authority has missed an opportunity to incorporate greater flexibility at this early stage of the plan making process.

5. Against the background of the numbered points above we would welcome a further dialogue with the local planning authority prior to "Regulation 19" consultation in order to ensure that the emerging Preferred Site Allocations DPD contains a policy framework which is sufficiently flexible to deliver a mixed use scheme along the lines of that proposed at Section 5 of the Statement of Delivery. That scheme would deliver 134-192 new jobs. That being significantly higher than a scheme of Class B uses only.

6. It is understood that the local planning authority is in the process of updating its evidence base in respect of retail planning matters and we would welcome the opportunity to engage with officers and their appointed consultants regarding the case to underpin further retail floorspace in Ingatestone.

In addition to the above Simons Developments Limited and R P Gaymer propose a further allocation in Ingatestone as per summary discussions with Officers in late 2017. That site is the "Island Site" as identified on the plan attached to Email 3. The site comprises 1.22 hectares of land effectively circled by Roman Road to the west of the A12. It is suggested that the site be allocated for Class B uses.

During our initial discussions with you further information on access and landscape impact was requested and that has now been completed. That analysis concludes that:

1. The site can be safely accessed. See Highways Technical Note prepared by Connect Consultants attached to Email 4.

2. The site can be developed without adverse landscape and visual impact. See Landscape Briefing Note prepared by Aspect Landscape Planning attached to Email 5. That notes that the sites proximity to the A12 and the existing urban edge combined with topography and vegetation provide an opportunity for development with only glimpses views from transient receptors moving along road corridors within the context of the urban edge.

Based on the above there is a clear opportunity for the allocation of further land for employment uses at Ingatestone should the local planning authority remain concerned about the ability to meet its upper requirement.

Whilst we do not consider it essential in order to justify a broader mix of uses on the primary site (land fronting Roman Road) the "Island Site" could sensibly be allocated or safeguarded for employment uses to come forward during the plan period as and when required in response to market demand.

In so far as the primary site is concerned we would welcome the opportunity to agree a draft allocation policy for "Regulation 19" consultation and based on our experience nationwide that would ideally specify the uses identified in the Statement of Delivery or recognise the benefits and acceptability of other employment generating uses subject to compliance with other policies in the plan. The former would clearly provide greater certainty and is in our view appropriate given the deficiency in local food shopping provision particularly.

I trust that the above and attachments on Emails 2, 3, 4, and 5 are of assistance and look forward to discussing further in due course.

If you could confirm safe receipt of these emails that would be appreciated.

Best regards