brentwood.gov.uk

Site ref 022 (Honeypot Lane)
We object to the allocation of this site because it is not suitable for housing and say that it should be removed from the list of proposed housing sites.
We do not agree that the site assessment for site ref 022 has been "robust, balanced and wide ranging in terms of technical evidence material for each allocated site" (paragraph 14 of Preferred Site Allocations 2018).
Its allocation is contrary to objective Strategic Objective 013 - "Safeguard the Green Belt from inappropriate development and enhance its beneficial use".The site constraints noted at Page 77 of the Preferred Sites Allocations 2018 are a gross simplification of the drawbacks of this site and are dealt with below.
Paragraph 7.30 of the 2016 Draft Local Plan indicates that this site has been assessed against criteria including infrastructure provision; impact on . . . flood risk, air and water pollution.; impact on highways. Further, paragraph 7.31 indicates a sustainability appraisal has enabled the Council to reach an informed judgment on the above. We argue that this site has so many serious drawbacks under several criteria in paragraph 7.30 that it should be withdrawn from the list of housing sites. The updated Sustainability Appraisal 2018 does not demonstrate that these drawbacks have been dealt with.
It does not comply with policy 9.12 (Green Belt). Policy 9.12 states that sites allocated to meet housing needs in Green Belt will be expected to provide significant community benefit both for surrounding existing communities and those moving into new homes on site. There is no indication that 200 houses in this area will provide any significant community benefit given the adverse effect on current local residents and the poor residential amenity for new residents. The proposal to build a care home has been added since the 2016 consultation and would meet the needs of the local population, however, this does not override our objections to the use of this site for housing.
1. Impact on highways:
The Preferred Site Allocation document (Page 77) states as a constraint: "Local highway considerations". This is a bland understatement of the access issues. It has extremely poor accessibility as the only existing access is onto Honeypot Lane. Honeypot Lane connects to London Road via a narrow hedged lane which is effectively one way in parts and is unsuitable for construction traffic or increased residential traffic.
In Honeypot Lane currently cars may take it in turns to wait for oncoming vehicles, at the narrow part of the lane. However, more impatient drivers use the pavement outside the houses (the kerb is dropped) at considerable risk to pedestrians and the site is well known to local residents as a 'near miss' hotspot.. The highway issues were acknowledged in the July 2013 Draft Site Assessment in which Essex CC noted that the road is narrow with visibility problems.
The alternative route to the town centre via Weald Road goes through a one way pinch point edged with houses, which is likewise unsuitable for construction traffic or increased residential traffic. The third existing route via Weald Way would require construction traffic to use a narrow winding lane with a tight turn opposite the entrance to Weald Country Park (the 'Cricket Field' entrance).
All of these routes would cause considerable disruption to local residents (walking, cycling, horse riding and driving) and visitors to Weald CP, if used by construction traffic and increased residential traffic.
An alternative suggested access via Selwood Road is along currently quiet residential streets, which are narrow in parts, totally unsuitable for construction traffic or as an access road to 200 residences, plus a care home, and in addition would require the wasteful demolition of expensive residential property adding to the cost of developing this site.
Although the site is in a sustainable location in terms of walking distance to facilities such as bus stops, railway station and one primary school (Holly Trees), the increase in traffic will require significant expensive changes to the junction of Honeypot Lane with London Road and the junction of Kavanaghs Road with London Road, including traffic lights and pedestrian controlled crossings. This should be funded at an early stage by developer contribution if the site is allocated. The route towards London Road would be the main walking, cycling and vehicle route to London Road for buses to shopping areas in Brentwood and Romford and to secondary schools, as well as to Holly Trees Primary School and to Brentwood Station. We have lived in this area for over 20 years and are aware from personal experience that this junction is already dangerous both for vehicles and for pedestrians. There is no pavement on the west side of Honeypot Lane, which makes walking to and from the nearest bus stops hazardous, as it requires avoiding the traffic stacking back onto Honeypot Lane whilst at the same time avoiding traffic turning into Honeypot Lane from London Road. Visibility of traffic turning left is poor and traffic turning right often does so at speed whilst cutting the corner. Although there is a 30mph speed limit on London Road, this is neither observed nor enforced and crossing the road is currently hazardous for cyclists and pedestrians and also makes turning out of Honeypot Lane in a vehicle dangerous. Traffic waiting for drivers to turn right into Honeypot Lane regularly mount the pavement to 'undertake' and avoid waiting which puts pedestrians at risk. There are currently numerous near misses and instances of dangerous driving at this junction.
If the site is allocated, there will be an increase in traffic seeking to turn right out of Honeypot Lane and then immediately left into Kavanaghs Road (the direct route to the railway station) adding to the risks. Likewise trying to turn right out of Kavanaghs Road across the flow down London Road is currently both dangerous and frustrating and the increase in traffic will add to drivers taking risks as can be seen throughout the Borough on any school day.
Junction improvements will also be necessary at the junction of Honeypot Lane with Weald Road. The 30mph limit ends just at Honeypot Lane and traffic from Weald Village travels fast towards the town centre. There is a dip in the road (looking left towards the A12 bridge) which makes turning right hazardous. The speed limit will have to be moved further towards Weald Village, however, as with London Road the speed limit is not observed, nor is it enforced.
There is no safe direct walking or safe cycling route from Honeypot Lane to Weald Village where the site allocation document allocates the nearest primary school. Whenever this matter is raised we are advised that there is no money to provide such a route. St Peter's school is not in a sustainable location currently and an increase in pupils will add considerably to the school run traffic.

If this site is developed, a significant contribution from the developer must be obtained to provide a safe walking/cycling route to Weald Village. Failure to provide this route is contrary to the policy of supporting sustainable transport and encouraging walking and cycling as opposed to the use of cars. In addition, having no safe route to St Peters school discriminates against residents who are unable to drive their children to school.
The Sustainability Appraisal 2018 paragraph 10.5.4. tries to demonstrate the sustainability of this site by saying "(Honeypot Lane) is potentially associated with an opportunity to support enhanced pedestrian links through St Faith's Park, which links the site to Brentwood Town Centre". This is meaningless - there are already footpaths and a cycleway through St Faith's, as well as walking routes via pavements, which are used by local residents and local employees.
The Sustainability Appraisal on the other hand makes no mention of supporting safe pedestrian and cycling links to St Peter's School in South Weald village.
2. Flooding.
The Preferred Sites Allocation 2018 (Page 77) states only "Watercourse runs through the middle of the site and will need to be considered" and the Sustainability Appraisal 2018 paragraph 10.5.4 bullet point 3 states:
"Land at Honeypot Lane is associated with a small watercourse running through its centre, which serves to highlight that there will be factors other than a desire to maintain a buffer to the A12 that must be taken into account when arriving at a layout". This is a gross simplification of the issues on this site. We have been advised the developers intend to spend up to 18 months carrying out major drainage works to the site; the disruption to local residents from noise, and disruption on the local roads from lorry movements as well as the cost of this work all indicate that the site is not a sustainable one for development on this scale.
The site is not in an identified Flood Risk Zone (FRZ), however it is immediately upstream of an identified FRZ in the Selwood Road area and therefore provides an important water catchment area for this zone.
The Environment Agency does recognize that the site itself is prone to surface water flooding which would require mitigation measures, thus further adversely affecting the financial viability and the density of the site.
The July 2013 site assessment correctly says that the site is not in a Flood Zone, but under the topic "surface water flooding" it incorrectly states there is none - so the flood risk was not factored in at that time. The current Environment Agency website shows maps of the risk of surface water flooding. The public map clearly shows that a significant part of this site is at medium or high risk from flooding as water drains down from St Faiths Park.
Local residents and allotment plot holders are well aware that Honeypot Lane floods when it rains and that the allotments and St Faiths Country Park are waterlogged in the winter (the vigorous growth of horsetail indicates how permanently damp the land is).
Selwood Road is prone to flooding. (the Honeypot Lane site is immediately North and East of Selwood Road)
The Surface Water Management Plan for Brentwood Final Report January 2015 (Page 104 Table 5.19 refers to 'The Brook Street area' - this includes Selwood Road) notes that flooding at this area originates from fluvial sources, the first is from the watercourse to the north of Talbrook (we note that this watercourse runs first through the Honeypot Lane site) There is a list of measures which should be taken to protect properties in proximity of the flood plain, including Property Level Protection for 75 properties at a cost of £356,250.
House building on the Honeypot Lane site would require expensive sustainable drainage solutions to prevent water flooding off the site and on to both Selwood Road and on to the A12 which is below the ground level of this site. The importance of the A12 is highlighted in The Surface Water Management Plan where Table 5.25 refers to flooding from the River Wid further along the A12 and notes ". . . . key infrastructure is the A12 which is a critical transport link for the region. The most important mitigation options at this site will relate to ensure that the A12 does not flood and is safe to travel on in times of flooding".
The Surface Water Management report was written before the Honeypot Lane site was included in the Development Plan and therefore an updated flood risk assessment is required taking into account both the risk to potential future residents and any knock on effect the development of the site would have on the risk of flooding on the A12 and the Selwood Road area. Updated estimated costs of mitigation measures will also be required - the above figures for Property Level Protection indicate that these costs could be very high to protect 200 houses and the proposed 40 bed care facility. These measures could affect the financial viability of the Honeypot Lane site.
3. Infrastructure: Both of the nearest primary schools are full to capacity. The 2013 Preferred Options report page 15 stated that St Peters School (in Weald Village) did not have the capacity to accept pupils from the proposed Honeypot Lane site. An expansion proposal in recent years for that school was turned down on Green Belt grounds. The table at Page 39 of the Preferred Site report indicates that primary schoolchildren from this site, and 032 (Nags Head Lane) would be in the St Peters School, Weald Village catchment area. The estimate is an additional 87 pupils. Even if the school is permitted to expand and with a safe walking or cycling plan in place it is likely that the majority of parents will choose to drive their children to and from school. And if children who are unable to get a place at St Peter's are allocated to more distant schools this will add to the dramatic increase in the number of school run journeys to and from this site, in turn adding to junction congestion and reducing the quality of life of local residents.
The Sustainability Appraisal 2018 makes it clear that there would be no national funding for infrastructure such as a new primary school.
4. Housing density and mix of dwellings
Paragraph 7.17 of the 2016 Plan states that future need in the Borough is for 65% 1-2 bedroom dwellings. We also note that Policy 7.5 states that 35% affordable housing would apply to this site.
The Sustainability Appraisal 2018 (page 70) states that "One and two bedroom properties make up a relatively small proportion of the total of the existing housing stock in Brentwood. In the context of longer life expectancy, more household break ups and a growing proportion of young people choosing to live alone, the lack of one and two bedroom properties affects affordability and choice of housing. This can result in the loss of young, economically active, elements of the population and an imbalance in the population structure over the long term. The SHMA recommends that 70% of social rented housing should be one and two bedroom properties, while for intermediate market housing 95% should be one and two bedroom properties".
The SA also states (4.1) that "new houses must be of an appropriate size, tenure and design so as to meet the needs of existing and future residents. Housing affordability . . . demand will continue to rise".
There is high and increasing demand from older residents who wish to downsize locally to good quality smaller properties, which would free up existing large family homes for younger families who wish to stay in the Borough and there is also a growing demand for good quality sheltered housing and care home facilities. We note that the proposed care home has been added to the site allocation since we commented on this need in 2016, which does go some way towards reassuring residents that their needs are being considered. However, this does not cancel out the objections to the use of this Green Belt site for housing.
As the site would need extensive costly drainage works, as well as the costs of obtaining road access and a high contribution towards road junction improvements we are concerned that the developer will seek to avoid providing a high percentage of small and affordable housing and apply to build large detached houses on this site. If our precious and highly valued Green Belt land is to be released for housing, against the wishes of residents, then the best use should be made of it to meet the housing needs of local people. There are indications that the developer is seeking to assuage concerns from local residents about the development of this site by proposing housing which fits in with the local type of property such as the nearby private estate, the Homesteads. Such housing may be very profitable for a developer, and attractive to people seeking to move into the Borough, but it is not what is needed by people who already live in the Borough.
5. Poor residential amenity due to air and noise pollution: The Preferred Sites Allocation 2018 (page 77) under the heading constraints for this site states only "Consideration of proximity of A12". This site is not a peaceful, rural greenfield site. It is immediately adjacent to the A12 and the constant flow of lorries is both loud and highly visible - and will be the view that future residents will have from their upstairs windows. When standing on Honeypot Lane next to the entrance to the site (several hundred metres from the A12) the noise of traffic is intrusive, persistent and, as local residents are well aware, it continues 24/7 without abatement. Should this site be developed the Council must be prepared to deal with future complaints about road noise and air pollution. The existing houses adjacent to the A12 in Selwood Road have large gardens with mature trees, which provide a buffer against some of the noise, but in order to make best use of this greenfield site, houses would be denser, gardens smaller and the road noise will be very evident.
The site will require the building (and maintenance) of a strong barrier to protect residents (in particular children) from vehicles on the A12 and also expensive measures to abate the noise. It is very likely that the A12 will be widened in the future and this would have an adverse effect on future residents during construction work and afterwards and further expensive mitigation measures will be needed to deal with noise, light pollution and air quality.
Air pollution has been noted at the Brook Street/M25/A12 roundabout. Recent reports by medical experts indicate concerns about ill health caused by proximity to roads. When the A12 becomes congested currently, there are lorries stationary with their engines running all the way along the road adjacent to the site. This is likely to increase as traffic increases on the A12. Therefore, the Honeypot Lane site offers very poor residential amenity compared with other sites on the allocated housing sites list.
We note with concern that the Sustainability Appraisal 2018 deals only briefly with this important issue of Air Quality which will affect the daily lives and health and well-being of hundreds of future residents, although it does flag up some concern about noise and air pollution. The Sustainability Appraisal notes as follows;" options for upgrading the A12 north of Brentwood are being discussed, however discussions are at an early stage and it is not clear what the implications might be for A12 junctions in Brentwood".
10.5.4 Bullet point 3 states that "Three sites - Land north of Chelmsford Road (which is the northern-most part of the linked proposed extension north of Shenfield), Land off Doddinghurst Road and Land at Honeypot Lane - are adjacent to the A12, which gives rise to concerns in respect of noise and potentially air pollution. Land north of Chelmsford Road is a new site, whilst the other two were proposals at the Draft Plan stage, with the latest proposal being to deliver a reduced number of homes onsite, which may help to ensure that a suitable buffer to the A12 can be achieved".
We note with interest the reference to the reduced number of homes, (with no explanation offered for the specific reasons for this reduction), and the weak and unconvincing statement that this "may" help achieve a buffer from the A12.
Conclusion
The Honeypot Lane site is not an easy housing site to develop because it has significant problems with inadequate highways access, surface water flooding risk and no primary school infrastructure capacity. Even if these problems could be overcome it is still a poor site because its proximity to the A12 dual carriage means it will always suffer noise disturbance and air pollution resulting in poor residential amenity. The A12 is likely to get busier and so the residential amenity will get worse. For these reasons we object to its inclusion in the Preferred Sites list and argue that the site should be deleted from the list of housing site allocations.