Although no one really wants housing built near them, I believe the plan does offer the housing required, without adversely affecting the area as a whole. The proposed sites do appear to have been carefully chosen and each one stands as reasonable in their own rights.

I object to the building of 96 additional homes within Blackmore village. This number represents a major increase of around 30% on the existing village size, which is ridiculously high. There will be significant additional pressure on the local primary school and health centre, both of which are already at capacity, which would mean major additional infrastructure works to enlarge them will be required. In order to accommodate access to these houses significant widening will be required to Red Rose Lane, and the increase in traffic in the village will be highly dangerous for the elderly and young residents. Further the village has increasingly been subject to flooding after heavy rains, and these new houses will add to the increased flood risk unless significant work to address this is undertaken. For these reasons I believe the number of new houses is unsustainable in the village of Blackmore. A reduced number, say, 20 addressing local elderly and first-time buyers would be more sensible. It is also unclear why the village of Blackmore has been singled out for additional housing when other large villages such as Doddinghurst have none.

Priest Lane is already overfilled with traffic heading towards brentwood, this further devlopment will cause further chaos.

The housing densities intimated provide no cohereent reasoning and indeed will be used by developers of windfall developments in the adjacent areas to force up the densities accepeted for the central Brentwood area in particular. Of particular concern is the fact that every existing office building in the town now has prior approval for conversion to residential use . The removal of large areas of carparking for conversion into housing of a high density will further extagrate the parking on streets in the town centre as with all commercial use been pushed to the outskirts of the town

How can Shenfield transport links and local infrastructure cope with what is being proposed inn terms of housing numbers? It cannot cope at present. What about doctors, dentist, schools, leisure facilities?

Figure 9 is grossly misleading because it shows subtotals for green belt that do not include Dunton Hills Garden Village. This will make residents assume that Dunton Hills is not green belt so they will wrongly favour development there. Brentwood Council should immediately issue a clarification notice to let everyone know that Dunton Hills is also green belt and should be included in the green belt total.

If car parks are to be built on where will people park their vehicles? There appears to be no provision for car parking

Building on William Hunter Way car park would lose the opportunity for an open area where people could meet. At present there are no public meeting areas.

I support the Council's approach of using the borough's current settlement hierarchy.

The sequential approach and the vision which is committed to enabling new economic growth leads to a plan which will reduce the quality of life for people living and working in Brentwood. The proposals will lead to urban sprawl, areas close to the A12 and M25 and the railway stations. The present overloaded road network will degrade further leading to unacceptable traffic conditions and pollution. The increased housing density will deprive people of open spaces. Brentwood's character will change permanently and for the worse under this building programme.

Site allocations at Officer's Meadow, land off Alexander Lane: this site includes a section of Arnold's Wood Complex Local Wildlife. The Arnold's Wood Complex comprises sections of fragmented ancient woodland, with some recent secondary woodland within the network of railway lines. Prior to the construction of the various railway lines, this Site is thought to have comprised three separate ancient woods (Arnold's Wood, Arnold's Shaw and Brickley Shaw), as indicated by their structure and floral composition. Since then, recent woodland has spread within the railway land to help link these three woods
ecologically. Development at this site must be designed to protect the sensitive woodland habitat from harm and should provide generous buffer habitat around the woodland, with alternative green space provided to reduce recreational impacts.

Hermes Investment Management support the allocation shown by "Brownfield Land within settlement boundary - other locations". The revised capacity of the estate is shown as 580 dwellings. Whilst this is probably closer to the capacity of the combined sites than the previous figure (500), Hermes considers that the plan would be improved by making it clear that this figure represent as desired minimum number of new dwellings the Council would like to see the site yield.

Section 12 - Dunton Hills Garden Village (DHGV) "evidence base is increasing including masterplan work" and
Section 64 e - "Developing a comprehensive masterplan for the new garden village at Dunton Hills, to engrain the core garden village design principles"
* how can an objective view be made on site selection before this masterplan detail is presented and made available to the public?

Section 26 - "Commited to growth . . . but in a way that maintains and enhances unique local character"
* wheras DHGV will completely destroy the unique local character of Dunton Village which is right on its border.

Section 28 - Strategic Objectives - S04 "A new well connected community at Dunton Hills"
* Please see fuller comments below - but how can it be well connected when it isolated from the rest of Brentwood, isolated from the railway and bound by already heavily congested roads

Figure 9 - page 26/27 - Proposed Housing Led Allocations
* DHGV is not included in the Green Belt total, effectively masking the extent of Green Belt land being developed
* Out of 381.25 Hectares of land allocated, 342.65 (257 + 85.65) is green belt. That's a staggering 89.8% Green belt land, which does not deliver a sustainable, ecological allocation plan.

Section 67 - Total dwellings
* Figure 9 shows a total allocated dwelling number of 6,154 houses. DHGV makes up 40% of this total. However, section 67 states this figure could increase to 9080 with accelerated growth within DHGV to deliver 3500 dwellings.
* This will add a huge burden to the surrounding infrastructure. With an estimated 9000 residents (section 105), a large level of investment will need to be made regarding roads, health, schools, shopping and work provisions. A sticking plaster approach will just not work given that many of these areas are already stretched to within breaking point.
* It just seems that not enough effort has been put into dispersing these houses across the borough. It is just lazy of the council to allocate it 1) on green belt land and 2) land from a single land owner - just to make the allocation process easier

Figure 13 - page 33 - Provision of traveller sites
* Travellers do not contribute funding in the same way that the general public do through council tax, national insurance etc. and therefore it does not seem appropriate to creating infrastructure specifically for one minority group
* That said, if traveller provisions do need to be created, surely it is better for all concerned to allocate them away from large communities and therefore the 30 allocations at DHGV would seem wholly inappropriate in that regard

Figure 22 - page 57 - New Employment Site Allocations
* The largest proportion of new employment areas are extensions onto green belt land - again along the A127 corridor, further burdening the already gridlocked roadways. The A127 is already experiencing pollution levels above EU allowable levels.
* The erosion of Greenbelt along the A127 means that there is almost no division from the urban sprawl of London and Brentwood / Basildon meaning that there will no longer be any green belt

Having read your draft plan, I find it very difficult to reconcile proposals for the brownfield land within Brentwood urban area.
1. Wates Way, Western Road and William Hunter Way are situated within a stones throw of each other, in the most congested part of town. Here, there is a proposal to construct an estimated dwelling yield of 425. These sites between them have a comparable developable area to The Drive (2.38 ha), yet the dwelling yield there is only 123. That is approximately three times fewer in a comparable area.
2. The two proposals for Shenfield (Crescent Drive and the Eagle and Child pub) equate to a gross site of 1.78 ha and a developable area of 1.63 ha. Despite this sizeable area of land, only 75 dwellings are proposed. This is a much larger area than the William Hunter Way site, where the dwelling yield is estimated at up to 300.
3. Of sites with a similar or greater developable area as William Hunter Way, the estimated dwelling yield is substantially smaller, with Crescent Drive only expecting a dwelling yield of 55 and the council depot (whose area is much larger than William Hunter Way) expecting a dwelling yield of just 123.

I understand the need for development and housing. I would like for my children to be able to be residents of Brentwood should they wish. However, I simply do not understand these figures. They are anomalous. Too much development is being concentrated in too small an area which happens to be in the centre of the most congested parts of the town. Shenfield appears to very limited development proposals. Why is there such a concentration of development in the centre of town? The William Hunter Way site simply does not have the capacity for a dwelling yield of 300. Why are the dwelling yields in other areas much smaller by comparison? Can you please explain this? It does not appear to add up.

Having read your draft plan, I find it very difficult to reconcile proposals for the brownfield land within Brentwood urban area.
1. Wates Way, Western Road and William Hunter Way are situated within a stones throw of each other, in the most congested part of town. Here, there is a proposal to construct an estimated dwelling yield of 425. These sites between them have a comparable developable area to The Drive (2.38 ha), yet the dwelling yield there is only 123. That is approximately three times fewer in a comparable area.
2. The two proposals for Shenfield (Crescent Drive and the Eagle and Child pub) equate to a gross site of 1.78 ha and a developable area of 1.63 ha. Despite this sizeable area of land, only 75 dwellings are proposed. This is a much larger area than the William Hunter Way site, where the dwelling yield is estimated at up to 300.
3. Of sites with a similar or greater developable area as William Hunter Way, the estimated dwelling yield is substantially smaller, with Crescent Drive only expecting a dwelling yield of 55 and the council depot (whose area is much larger than William Hunter Way) expecting a dwelling yield of just 123.

I understand the need for development and housing. I would like for my children to be able to be residents of Brentwood should they wish. However, I simply do not understand these figures. They are anomalous. Too much development is being concentrated in too small an area which happens to be in the centre of the most congested parts of the town. Shenfield appears to very limited development proposals. Why is there such a concentration of development in the centre of town? The William Hunter Way site simply does not have the capacity for a dwelling yield of 300. Why are the dwelling yields in other areas much smaller by comparison? Can you please explain this? It does not appear to add up.

1. I object to the allocations of 076 and 077 on grounds of excessive development in Blackmore Village - the proposed sites represent over 28% increase in houses in the village which is unsustainable. Of the proposed sites listed in 'Green Belt - Larger Villages' section of the LDP, nearly 70% of the proposed houses are in Blackmore and Tipps Cross Ward (116 houses out of a total of 169). This is an excessive and unwarranted increase for this small historic village which cannot be justified. In contrast neighbouring villages such as Doddinghurst have no proposed sites for development. Blackmore has limited facilities and is fairly isolated from major centres, with poor public transport services.


2. The sites 076 and 077 are Green Belt fields with the protection that designation provides - development should only be considered in exceptional circumstances. Green Belt was established to protect the boundary of built development of the village and the open countryside.


3. The proposed development will cause degradation of environment and damage to wildlife. Site 076 is home to many rare birds which are protected species such as skylark, barn owls and turtle doves which are regular visitors to the field in question.

Turtle doves have been seen and heard on the site for the past 3 years and field 076 is a known breeding site for turtle doves. The turtle dove is a Section 41 species which is of principal importance for conservation of biodiversity; they are vulnerable to global extinction and are identified in the Red List of Endangered Species. They have suffered a 91% UK population decline since 1995. More than half the remaining turtle doves breed in East Anglia with Essex being identified as one of the important 'hotspots'. The loss of this site to housing would inevitably mean the loss of this important breeding site and further loss of appropriate habitat. Turtle doves favour wide undisturbed field margins and this is not the sort of habitat which can be incorporated into housing development. Furthermore, the fact that the site is a breeding site for turtle doves raises the question as to what other species exist there. A detailed assessment of both site 076 and 077 should be undertaken to establish the ecological importance of the sites; such assessments should not be left until the planning application is submitted as it may result in the site being undeliverable and therefore Brentwood Borough Council will not be able to meet their housing requirements in respect of these sites.

4. The fact that Red Rose Lane, a narrow country lane, runs East/West to the north of the village seems to have been used to justify the allocations 076 and 077 as appropriate pieces of land.
These sites are not self-contained village infill as suggested in the LDP- the sites are on open land outside the village, and the road which is being viewed as a border -Red Rose Lane - is a narrow country lane and unsuitable for anything other than light traffic. When these sites are viewed in reality rather than on a plan, the area is open countryside and a very important part of the Green Belt.


5. Infrastructure - Red Rose Lane which borders the proposed development is a narrow country lane unsuitable for heavy traffic. Blackmore is surrounded by minor roads and is unsuited to the large increase in traffic that this development would bring. There are already problems with parking and congestion around the village shop and this will be greatly exacerbated by the proposed increase in housing.


6. Traffic - access to the sites from Red Rose Lane will be difficult and dangerous due to narrow nature of lane. In particular, if site 076 is accessed through Orchard Piece this will cause greatly increased traffic flow in what is currently a quiet cul-de-sac and will cause a danger and disturbance to current residents and their children.


7. School - Blackmore has a small primary school which is currently at capacity. Proposed development would put excessive pressure on school and facilities, and would may result in insufficient spaces being available for the children of the village.


8. Health and transport - no GP surgery within parish boundary, and nearest GP surgery is full to capacity with considerable problems obtaining appointments at short notice. Bus services which link the village to Chelmsford and Brentwood are part time only.


9. Flooding - Red Rose Lane is often subject to flooding in times of heavy rain. A site immediately adjacent to field 076 (site 250 Post Field) was rejected for development on the grounds of flooding and surface water problems. Field 076 is actually lower lying and Red Rose Lane in the area of Red Rose farm has become impassable at times due to flooding. Development would make flooding worse as green field land would be lost to housing and hard-standing.

If the development attempted to address the flooding and surface water issue by the creation of a pond for instance this would make the housing targets undeliverable.

My objections are supported by the response of Blackmore Parish Council. I urge Brentwood Borough council to reconsider these allocations and retain this important section of Green Belt land. Whilst recognising the pressure for additional housing more assessment should be carried out on brownfield land or within larger settlements which are more accessible with better facilities, or within the larger new Dunton Hills Garden village settlement.

Figure 9 - we note that this figure neglects to identify the brownfield opportunities in Green Belt locations. We object to this omission and request that it be amended to note that this has been factored into the development strategy. Redrow Homes is in the process of bringing forward a large brownfield site at Ingatestone Garden Centre. The redevelopment of this derelict site in the Green Belt will assist in meeting identified needs and in restoring the appearance of the area. It is right that the brownfield land allocation within the Green Belt is acknowledged and would be consistent with the requirements of the draft NPPF. Interim Sustainability Appraisal (SA) - The Interim SA advises that it welcomes comments from stakeholders. Redrow Homes owns one of
the proposed allocation sites (site 128). It intends to bring this site forward for development as soon as planning permission is granted. Site 128 is included in the Interim SA and the appraisal so far raises a few concerns that Redrow Homes wishes to comment on. These relate to the topics used for assessment and how these have been applied to this site. Special Landscape Area - Site 128 is given an amber rating for this in Table C and the notes in Table B say that this is to reflect potential the effects on landscape. It is unclear how this can be assessed at this stage as there is no reference as to what is special about the landscape that could be affected and no account is take of the existing redundant nature of the site. It is further noted that the SLA designation is not proposed to be carried forward into the new development plan. It is also noted at Table A that "Limited data is available to inform the appraisal. Work is ongoing to ensure that all site options are categorised in terms of potential for landscape impacts and also the potential to result in loss of functioning Green Belt (i.e. Green Belt that meets the established purposes). This work will be drawn upon in the future." It is apparent, therefore, that this rating will need to be updated when further information is available and we would ask that it also include an assessment that takes into account the existing nature of the site, the potential for landscape enhancement and the removal of the SLA designation. Distances to facilities (criteria 7-9) - It is noted that Department of Transport walking distance guidelines have been used to rate the distance from these facilities. Consideration should be given to departing from these in light of the health benefits of walking and the NHS guidance that specifically encourages walking to maintain a healthy lifestyle. For these reasons it is considered that the walking distances should be extended. Site allocation 128 - we note that this site is described as being a self-contained urban extension with the neighbouring site (site 106). Redrow Homes owns site 128 and is bringing this forward for development. It has no control over site 106 and would not wish the wording of the allocation to be misconstrued as meaning that both sites must come forward together. The proximity of the site to the settlement boundary means that is clearly an urban extension and therefore it is suggested that the reference to site 106 is unnecessary. As such, it is requested that this be deleted from the allocation summary. SO1 - we support the strategic objective to maximise the sustainable growth opportunities of brownfield sites. Redrow Homes has a large brownfield site at Ingatestone Garden Centre that it is bringing forward for development. The use of such sites ensures that greenfield site release can be minimised and that previously developed land can be re-used to meet existing needs. SO3 - we support the strategic objective to support the sustainable growth of existing larger villages to provide improved housing choice and protect services and facilities. This is a welcome recognition of the benefits arising from developments in such locations. Figure 15 - the RAG coding is not explained in the text of the document and we consider that it should be in order to understand the significance of the assessment.

Thank you for allowing Persimmon Homes the opportunity to comment on

1. Brentwood Local Plan: Preferred Site Allocations Local Plan (to 2033)
2. Supporting evidence base

Persimmon Homes are one of the UK's leading builders of new homes with a track record of delivery in the Essex and wider Eastern region. Persimmon Homes are a developer with significant experience of market and planning issues in the area, as well as being a 'user' of the Development Plan.

Persimmon Homes are a Member of the House Builders Federation (HBF), the principal representative body of the house building industry in England and Wales. Persimmon Homes, together with other Members, have inputted into the HBF's representations.

The below comprises Persimmon Homes representation to the Preferred Site Allocations Local Plan.

Duty to Co-operate & London

Despite the Emerging London Plan expectation that London will deliver 65,000 each
year from 2019-2029, there will be a need for LPAs with strong commuting and
migratory links with London, such as Brentwood, to consider how it can address
unmet housing needs arising from the capital. It is considered that further evidence is needed in regard to the exercising of the Duty to Co-operate and the extent to which Brentwood should assist London meet its needs both prior and post 2029.

Essex

Local Authorities comprises Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea, Thurrock and Essex County Council have formed the Association of South Essex Local Authorities (ASELA). We note that as of the end of 2017 ASELA have prepared a Memorandum of Understanding (MOU). Part of the aims of ASELA is to 'Open up spaces for housing, business and leisure development by developing a spatial strategy'.

It is evident from the experience at Castle Point that certain authorities have expressed a desire not to meet their full OAHN. It remains to be seen the establishment of this body will provide effective governance and a mechanism by which to ensure genuine co-operation to meet full OAHN. Many adjoining authorities within the northern part of Essex have not had to factor in meeting housing growth from ASELA Authorities and are significantly more advanced with their development plans than the majority of South Essex Authorities.

Housing Needs

We agree with the HBF that Brentwood should look at the implications of the Governments published draft standard methodology. It is the intention of Government to introduce the standard methodology for housing needs. To advance a sound plan and one that seeks to address the Housing Crisis, the draft Plan should factor in the emerging government advice and policies. We consider it appropriate that given the significant affordability issues that the Council applies an uplift of at least 40%.

The Government's proposed standardised objectively assessed housing needs methodology indicates a need for Brentwood to deliver a capped figure of 454 dwellings per annum. It is considered that the plan should seek to address this figure. This would give rise to an extra 1,480 homes during the plan period.

Housing delivery

There is presently a distinct lack of published supporting technical studies in relation to the Dunton Hills Garden Village as proposed in the Local Plan. Furthermore, there is insufficient evidence of co-operation with and a joint vision Basildon & Thurrock Council's with regards the Garden Village, how it will be delivered having regards to the neighbouring authorities aspirations for growth in this area.

It is noted that the Council are exploring whether Dunton Hills Garden Village could increase delivery from 2500 to 2033 to c4,000. It is considered that this work should have been undertaken in advance of the consultation and the findings inform the Preferred Options.

The draft plan is heavily reliant upon sites that currently have beneficial uses,
including;
* Ford Offices 117A / 117B,
* Railway Station car park ref: 002,
* William Hunter Way car park ref 102,
* West Horndon Industrial Estate 020, 021 152.

Whilst Local Plans need to be aspirational, they also need to be realistic. To be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available and could be viably developed at the point envisaged. Sites with current beneficial uses, if deliverable, are likely to be more difficult and therefore slower to deliver. They will have established use values that will influence whether they are brought forward for residential development. In addition, brownfield site are likely to be subject to additional costs in terms of relocating businesses, demolition, and remediation that may impact viability. The Council need to robustly assess its assumptions with regard the extent to which sites with current beneficial uses will be deliverable and can viably contribute towards meeting housing need, including that for affordable housing.

We are concerned that the Local Plan is too heavily reliant upon sites that may not deliver and if they do, may not assist in terms of boosting housing land supply or deliver the levels of affordable housing needed.

We hope these representations are of assistance in taking the plan forward to the
next stage of plan preparation.

This representation is made on behalf of our client, Barwood Land and Estates Ltd.
Barwood Land and Estates (BLEL) support the proposed allocation of Land at Honeypot Lane, Brentwood (reference 022) as a Brentwood Urban Area, A12 Corridor Urban Extension as set out at page 77 of the Local Plan. The proposed allocation follows the settlement hierarchy and proposed spatial distribution of housing set out in other plan policies and objectives. BLEL support the proposed housing allocation of Land at Honeypot Lane but raise a number of more specific comments as follows: BLEL consider that Land at Honeypot Lane has an indicative development capacity for >200 dwellings based on masterplanning and detailed site analysis/testing undertaken to date by BLEL and shared with the Borough Council. The proposed allocation information should therefore be updated accordingly for up to 250 dwellings total. The next iteration of the Local Plan Sustainability Appraisal should also take this quantum into account. BLEL note that the Honeypot Lane site is also identified as a potential location for a C2 Use Class care home and query where this indicative land use proposal originates as it has not been proposed to the Borough Council or discussed with BLEL as the development promoter to date. The reference to C2 Care Home appears to refer to paragraph 9.2.5 of the Interim Sustainability Appraisal Report that notes that there is a potential for some 40 bed space C2 Use Class provision for the site and itself purports to draw this from the latest version of the Borough's Strategic Housing Market Assessment. Land at Honeypot Lane is described as a 'self-contained urban extension' but clearly the development would be integrated with Brentwood and particularly with surrounding areas including St Faiths Country Park. Indeed, the site's location supports the potential for a high degree of integration rather than self-containment. BLEL suggest that the wording of the Local Plan text be modified accordingly in this respect. With respect to housing delivery, BLEL consider that Land at Honeypot Lane is capable of delivery within the five year period rather than in the longer 5-10 year period. The site is suitable, available and achievable and has a willing landowner, developer and investor. The potential for early delivery in the plan period has been discussed with the Borough Council and BLEL suggest that the Local Plan text be updated to reflect the ability to bring this site forward early in the plan period. Barwood Land and Estates support the Spatial Strategy shown in Figure 5 (page 17). The Spatial Strategy shows a realistic overall distribution of growth. It focuses on sustainable urban locations and the best opportunities for Green Belt release in/adjacent to existing higher order settlements in order to meet identified housing and economic growth objectives of the Local Plan. Barwood Land and Estates (BLEL) support the proposed Housing-led Allocation set out in Figure 9 (pages 26 - 27). In particular, BLEL supports the proposed allocation of Land at Honeypot Lane, Brentwood (reference no. 022) as a housing site allocation. Land at Honeypot Lane is a sustainable location and a deliverable housing site within the urban area of Brentwood. The site can come forward early in the Plan period without the need for extensive new infrastructure. Release of the site from the Green Belt will ensure development can be achieved in a timely manner and that this site can contribute to supplying much needed new housing in Brentwood. BLEL has undertaken an extensive and detailed technical and design analysis of the Honeypot Lane site and has concluded that the site is capable of delivering more than 200 dwellings without causing adverse effects on highways, landscape, amenity or other matters. BLEL has previously shared this analysis with the Borough Council. On this basis BLEL consider that the site is capable of sustainably accommodating up to 250 dwellings and the Local Plan should be updated accordingly at Figure 9 (and elsewhere where the Plan identifies a proposed allocation quantum for the site) to reflect this. Barwood Land and Estates (BLEL) support the proposed Settlement Hierarchy set out in Figure 14 (page 35). In particular, BLEL supports the proposed allocation of Land at Honeypot Lane, Brentwood (reference no. 022) as a housing site allocation. The proposed settlement hierarchy represents the current pattern of activity and forms a realistic approach to guiding future sustainable development patterns of activity and land use in the Borough. The hierarchy clearly and appropriately identifies Brentwood, Shenfield, Hutton, Warley, Brook Street and Pilgrims Hatch as 'Category 1 - Main Towns'. Barwood Land and Estates (BLEL) has reviewed the Interim Sustainability Appraisal Report (SA)
that supports the Local Plan Site Allocations and has the following comments with respect to paragraphs 10.5.4 (page 44); 10.10.2 (page 52); and the Site Appraisal of BLEL's site and Honeypot Lane, Brentwood (022) on page 81. Paragraph 10.5.4 (page 44) BLEL note that the Honeypot Lane site is proposed for a reduced level of housing (200 dwellings compared to 250 dwellings) when comparing the current Site Allocations Plan with the previous 2016 draft Local Plan. BLEL are not aware of any site specific reason why there should be a reduction and have considers (based on extensive technical assessments and site masterplanning that the site should be allocated for up to 250 dwellings. The SA should therefore be updated and revised accordingly in this respect. BLEL agree with the SA at 10.5.4 that the Land at Honeypot Lane site is associated with an opportunity to support enhanced pedestrian links through St Faiths Country Park. The SA notes at 10.5.4 that the potential for noise and potentially air pollution on the Honeypot Lane site arising from the A12 road. BLEL considers that the site's design and specific technical measures respond to the context of the site, including proximity to the A12 road and that the emerging scheme design includes appropriate buffers and mitigations for noise and air pollution amenity accordingly. The SA text should therefore be updated accordingly in this respect. A small watercourse running through the Honeypot Lane site is noted in the SA at 10.5.4 and the text highlights this as an example of the factors that will need to be taken into account in developing the site. BLEL has undertaken extensive technical analysis including physical surveys and assessments of the site and can confirm that site and surrounding area physical characteristics have been taken fully into account in concluding that the site can deliver up to 250 dwellings. Paragraph 10.10.2 (page 52) Paragraph 10.10.2 of the SA Interim Report identifies a lower level of housing delivery at Land at Honeypot Lane (and other Green Belt sites in Brentwood) as potentially having a lower landscape effect than earlier proposals and also potential for more green space on the site. BLEL's conclusion, following extensive technical analysis including landscape and visual impact assessment work is that Land at Honeypot Lane can deliver more than the 200 dwellings set out in the Site Allocations Plan and it can do so without adverse landscape effects. The site can achieve this while supporting levels of new amenity and green infrastructure to high degree. Honeypot Lane can therefore deliver more housing than the current version of the Plan identifies and can do so without adverse landscape effects given sensitive site design and the effective use of the site's natural topography and natural boundary vegetation as appropriate. Honeypot Lane Site Appraisal (page 81) BLEL note that the SA Interim Report has provided a high level sustainability appraisal of the Honeypot Lane site (page 81). BLEL concur with the analysis and note that the Site performs well in relation the analytical criterion. BLEL notes that the SA site assessment criteria covering issues such as access to primary and secondary schools and GP's surgeries is based on existing local provision and does not consider the potential future provision arising from new development as the Local Plan is implemented. I.e. the SA site assessment does not consider the potential for an enhanced level of site sustainability where development has supported the provision of new or expanded facilities. It is also important, in BLEL's view that that the SA site assessments consider factors such as the quality or capacity of facilities and services as well as a site's distance from such facilities. Quality and capacity are equally important sustainability factors. The Red Amber Green (RAG) scoring system used for the SA's site sustainability appraisals has no green scores in relation to a number of criteria. For example, Air Quality Management Areas and proximity to SSSI designations. This means that all sites are either scored red or amber for such criteria. Similarly, the distance from a Local Nature Reserve criteria is scored as either Red or Green (there is no amber). The RAG scoring system is, in BLEL's view, helpful but rather confusing overall as it mixes two and three RAG scoring codes depending on the criterion in question. BLEL is of the view that the assessment criteria and RAG scoring should be used consistently in respect of each criteria in the next version of the Sustainability Appraisal of the Local Plan. Barwood Land and Estates (BLEL) support the Local Plan at paragraph 43 (page 19) concerning objectively assessed housing need. BLEL support the higher OAN figure (380 dpa) calculated in the latest version of the Strategic Housing Market Assessment, but consider it is realistic and appropriate to now plan on basis of the Government's standardised methodology as set out in the new consultation draft NPPF and in revisions to the NPPG. It is clear that Government intends to adopt the standardised methodology in future and the Local Plan should reflect this now. Therefore, the Plan should set out opportunities and sites to deliver the 454 dpa (+74 dpa over the OAN). This supports and emphasises the need for a choice and mix of sites to ensure delivery and focuses the Plan into ensuring release of sufficient brownfield land and Green Belt sites at sustainable locations in order to deliver. Barwood Land and Estates (BLEL) support paragraph 54 (page 22) of the Local Plan that is concerned with the supply of housing sites. BLEL agree that it is appropriate to review, test and evaluate (and discount where necessary) a wide range of housing sites through the HELAA process. The process undertaken has been thorough in identifying potential sites and in evidencing those selected for allocation in the Plan. The Vision (page 11) supports sustainable growth and makes best use of brownfield and greenfield
land. This represents a realistic approach to the need to release Green Belt land to fully support housing and economic delivery objectives of the Local Plan.

See attached.

HGH Consulting has been instructed by Clearview Residential Ltd to submit representations to the Brentwood Local Plan Preferred Site Allocations 2018 consultation in order to promote the inclusion of a strategic development site at London Road in Brentwood known as St Faith's. A Development Framework Document has been produced which demonstrates the site's ability to deliver a sustainable urban extension of at least 750 new homes alongside other community and employment uses, as well as significant enhancements to the existing open space. The site will therefore assist the Council in meeting its objectively assessed needs as detailed in Figure 8. It is proposed that the site be removed from the Green Belt (comprising just 0.1% of Brentwood's overall Green Belt) and identified as a preferred site allocation within Figure 9 with the following information: Site Name: St Faith's, London Road, Brentwood Site Reference: NEW SITE Proposed Use(s): Housing and commercial (offices) with ancillary leisure and community use(s) Gross Area (ha): 21. Developable Area (ha): 16 Indicative dwelling yield (net): min. 750. Other Indicative Uses: B1 - Offices, Parkland (sport and recreational uses), and ancillary retail, leisure and community uses (Classes A1 - A4, D1 / D2) Location and Background Information: Forming part of the existing BT Campus, One London Road, and the land to the north bounded by Honeypot Lane and Weald Road. Residential properties adjoin the northeast, east and south eastern boundaries. Housing Site Allocation Ref: 022 lies on the opposite side of Honeypot Lane. Site Access: London Road (via existing access to BT) with secondary vehicular access points on Weald Road and/or Honeypot Lane. Site Opportunities: Self-contained sustainable urban extension to Brentwood. Extensive area of Previously Developed Land (26%). Mixed-use sustainable form of development. Excellent linkages to Brentwood Town Centre and public transport connections. Opportunity to significantly enhance recreational activity in new parkland setting and pedestrian / cycle links through St Faiths Park. Site Constraints: Trees, Watercourses, sewer and cycle routes through the middle of the site will need to be considered. Delivery Forecast: Years 5-10. An edge red boundary is included within the Development Framework Document. (Please see attached document for details on the site).

See attached.