Representation by S&J Padfield Estates LLP (S&J Padfield Estates LLP)
- Date submitted
- 24 February 2023
- Submitted by
- Members of the public/businesses
This relevant representation is submitted by Shoosmiths LLP on behalf of Christopher Scott Padfield, S&J Padfield & Partners LLP and S&J Padfield Estates LLP (together, our “client”), the owners of land located to the north and south of the A127 and to the east and west of the M25 at Junction 29, known collectively as Codham Hall. S&J Padfield & Partners LLP is also the owner of land at Street Farm, South Ockendon. The points our client will make in relation to the Application are outlined in full in our letter dated 24 February 2023, sent to: lowerthamescrossing@planninginspectorate.gov.uk A summary is below: There are a number of principal matters of concern in respect of which our client is seeking a satisfactory resolution, absent which our client’s position in relation to the LTC project, and now the Application, is one of firm opposition in so far as it affects our client’s land and interests: 1. Impact on the proposed development known as Brentwood Enterprise Park (“BEP”) (being allocated in the Brentwood Local Plan under site allocation E11 as a site for employment led development, the developer and promoter for which is St Modwen Developments Limited). 2. Impact on land at Codham Hall North, in particular: (i) the ongoing availability of the northern and southern accesses from the A127/M25 gyratory (off the existing roundabout at Junction 29); (ii) the permanent acquisition of land for the provision of environmental mitigation works in connection with the LTC project; (iii) the implementation of utility / diversion works in respect of which the specific works, programme and period of temporary possession remains unclear; (iv) works to the Warley Interchange, as proposed by the LTC project, the Infrastructure Delivery Plan prepared in connection with the Brentwood Local Plan and BEP, and the need for their co-ordination; and (v) the ongoing availability of field access east and west of the M25 for farming purposes. 3. Impact on land at Codham Hall West and its development potential – both immediately, for uses compatible with the land’s Green Belt location, including infrastructure and road side uses, and in the longer term, in recognition of the potential for the land to be allocated for other forms of development (such as residential, commercial and renewable energy development). 4. Impact on land at Street Farm, South Ockendon (which, together with land owned by neighbouring landowners, is under option to Bellway Homes Limited) and its future development potential – noting the identification of the land in the emerging Thurrock Local Plan (together with other land in South Ockendon) as having the potential for large scale strategic growth of in the order of 10,000 homes to meet identified housing need. We reserve our client’s right to make further and/or additional representations in relation to the LTC project proposals (as detailed in the Application).