Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 24077

Received: 20/05/2019

Respondent: LaSalle Land Limited Partnership

Agent: Chilmark Consulting Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to the omission of Honeypot Lane from the Brnetwood Pre-Submission Local Plan. Honeypot Lane is a sustainable development location in close proximity and easy access and integration with new jobs, community facilities, services and greenspace as a principal tier 1 category settlement; it would contribute to the five year housing supply; it has already been tested by the Sustainability Appraisal. Removal is not justified.

Change suggested by respondent:

LLLP conclude that the Plan needs to be modified to identify and allocate Land at Honeypot Lane, Brentwood (ref: 022) for residential development of up to 250 new dwellings with associated transport, community and green infrastructure. The Brentwood Borough Local Plan: Pre-Submission, January 2019. Allocation of Honeypot Lane must include its removal from the Green Belt and the appropriate revision of the boundaries of that designated area. The Plan's proposed Housing Trajectory (Appendix 1), the Key Diagram and the list of proposed allocation sites should be updated to include Land at Honeypot Lane accordingly.

Full text:

Representations for and on LaSalle Land Limited Partnership
Omission Site - Land at Honeypot Lane, Brentwood
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with the omission of LLLP's land interest Land at
Honeypot Lane, Brentwood (ref: 022) from the list of proposed housing allocations
and the Plan Proposals Map in the Pre-Submission Local Plan.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Overview
4. The Honeypot Lane site was included as a proposed residential allocation at the
earlier stages of the plan-making process, including the Draft Local Plan (February
2016). The site was previously allocated for up to 250 new dwellings and LLLP
had supported its inclusion and designation in the Plan as an available, suitable
and achievable residential site.
5. LLLP object to the omission of the site now and its exclusion from the Pre-
Submission Local Plan and set out the grounds for this in greater detail below.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
Honeypot Lane, Brentwood: A Sustainable Development Location
6. Land at Honeypot Lane extends to some 10.9 hectares and is situated to the
west/south-west of Brentwood adjacent to the existing built-edge of residential
properties on Honeypot Lane and on Hill Road and South Weald Road to the
south. To the west, the site is bounded by the A12 (with Weald Park beyond) and
Weald Road to the north. Honeypot Lane provides a link between the A1023
London Road to the south and Weald Road to the north.
7. The site is enveloped on three sides by the existing built-form of Brentwood. It is
also contained within the existing landscape and topographical structure of the
western part of Brentwood, the A12 and Weald Lane. The site is situated below
the hill crestlines of Brentwood and South Weald (to the west of the A12).
8. The site is not currently actively used, comprising pasture land and is largely clear
of significant vegetation other than at its boundary edges.
9. The Brentwood Local Plan needs to positively address national policies to boost
housing delivery, economic growth and sustainable development. This should
include supporting the role and function of Brentwood as the highest order
settlement in the Borough and be the focus for future growth through the release of
sites because:
* it is the settlement with the largest existing population in the Borough;
* it contains the main employment areas (Brentwood Town Centre, Brentwood
Station and Warley Business Park);
* it contains the main retail areas (focused on the High Street);
* it has excellent rail accessibility and connectivity (that will be further enhanced
with the Queen Elizabeth rail line development); and
* it is the focus of the main identified public transport routes and services within
the Borough.
10. Given the extensive Green Belt designation covering much of the Borough, new
dwellings have historically been provided by increasingly scarce opportunities from
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
the redevelopment of larger brownfield sites, with the remainder comprising
contributions from a sizeable number of small infill developments within defined
settlement boundaries. For the future, these development opportunities are either
limited (i.e. an increasing shortage in available brownfield sites or under-used
employment land), or have site specific challenges such as being too small to
make a significant contribution to sustainability objectives, particularly where their
development would result in an over-intensive land use pattern.
11. The Plan must, in LLLP's view, support greater levels of development in
sustainable locations in Brentwood where:
* there is close proximity between jobs, homes and open spaces, capable of
being accessed by public transport, on foot or by bicycle;
* sites are readily deliverable;
* development would not damage the distinctive character of Brentwood, or the
overriding contribution of the Green Belt to Brentwood's quality of life,
biodiversity and environment, which are highly valued by the local community,
and which give it its character and distinctiveness;
* the Green Belt boundary can be reviewed and re-aligned using physical
features that are readily recognisable would continue to form a logical longterm
and defensible boundary for the urban extent of the Borough.
12. Land at Honeypot Lane (022) offers a significant opportunity to secure new homes
early in the plan period and to achieve a wholly sustainable form of development
that aligns with the spatial strategy and enhances the role and function of
Brentwood as a Category 1 Settlement with the highest order role and function in
the Borough.
13. Failure to include the site in the Local Plan now represents a failure to plan
positively and is not justified.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
4
Contribution to Five Year Housing Land Supply
14. LLLP has set out its concerns with regard to the failure of the Pre-Submission
Local Plan to effectively identify or meet the Local Housing Need of the Borough
(see LLLP's separate representation for Policy SP02: Managing Growth).
15. A choice and mix of housing sites of different characters, locations and sizes is
critical to enable the Borough to meet identified housing requirements, secure a
continuous five year land supply and to support the Plan's stated Strategic
Objectives (including SO1 in particular).
16. The continued lack of a five year housing land supply in Brentwood has, and will
continue, to lead to acute shortfalls in new housing provision with a very significant
risk that the Borough will continue to fail to meet the requirements of the NPPF at
paragraph 67 and also to fail to meet the Government's Housing Delivery Test
measures.
17. The Borough Council's decision to remove Land at Honeypot Lane as a residential
development allocation in the Local Plan was taken at the Council's Extraordinary
Committee Meeting on 8th November 2019 (purportedly on highway access
grounds despite not being based on any clear, properly presented, tested and
considered transport and highways evidence). Furthermore Officers were
prevented by the Council's standing orders relating to the management of
Extraordinary Full Council Meetings from speaking at the Meeting. If they had they
would have been able to advise Members that the Local Highway Authority (Essex
County Council) had raised no highways objections relating to the site's allocation
for housing development within the Plan at that time.
18. The removal of Honeypot Lane and the re-allocation of the dwellings into the
Dunton Hills Garden Village site (by increasing the quantum of that allocation)
serves to seriously and materially erode the Plan's ability to deliver necessary new
housing, offer a choice and mix of sites in the early part of the plan period, or to
make best use of available, sustainable sites in existing settlements.
19. Land at Honeypot Lane, Brentwood offers a significant opportunity deliver homes
now, contributing to the five year housing land supply position and to do so in a
sustainable urban location.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
5
20. The Borough Council has, in previous iterations of the Local Plan, clearly and
explicitly supported the site for release from Green Belt and recognised it as a
suitable, available and achievable location for housing to be delivered in the short
term contributing significantly to the five year land supply position
21. Indeed, the Honeypot Lane was assessed through the Borough's Strategic
Housing Land Availability Assessment (SHLAA) as a clear example of a site that
fulfils all of the criteria for release from Green Belt and has the ability to make a
significant, positive contribution to sustainable development and growth of
Brentwood early in the plan period.
22. Furthermore, the Plan's Sustainability Appraisal (including earlier iterations of the
SA) has identified Honeypot Lane as a preferred development site and a
sustainable location for new residential development. Nothing has changed in this
respect and the site remains a wholly sustainable location for residential
development with wide and positive benefits for Brentwood town and the Borough.
Sustainability Appraisal
23. The Local Plan's Sustainability Appraisal (January 2019) includes a site options
appraisal at Appendix 3.
24. Table C, from page 97) sets out detailed site options appraisal testing for each site
in the Pre-Submission Local Plan. Details of the methodology for appraising
individual sites is set out from page 92 onwards with 17 distinct criteria used in the
assessment using a RAG (Red, Amber Green) scoring model to "aid
differentiation, i.e. to highlight instances of site options performing well/poorly. The
intention is not to indicate whether a 'significant' effect is predicted" according to
footnote 70 on page 93.
25. Page 99 sets out the SA assessment of 022, Honeypot Lane, Brentwood. LLLP
has reviewed the SA assessment of the site and concludes the following:
* 8 criteria are scored as Green or are not covered in the scoring, indicating that
the site performs well against those criteria;
* 9 criteria scored as Amber; and
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
6
* 0 criteria scored Red.
26. The site has no red criterion scores and performs well in comparison with all other
proposed allocations.
27. LLLP has reviewed in more detail those criteria for Honeypot Lane that are scored
Amber in the assessment and comment as follows in relation to the SA findings
and the criteria and their thresholds set out in Table B:
* Air Quality Management Area - the SA notes for this criterion that the impact
thresholds are unknown. The Amber score is for sites that are <1km from an
AQMA. In this case the AQMA is the Town Centre of Brentwood. However
Honeypot Lane is well situated in relation to the town centre to offer access by
cycling and walking rather than use of the private motor vehicle and the site is
not known, from any analysis or evidence available to LLLP, to have any
problematic air quality issue.
* Site of Special Scientific Interest (SSSI) - the Amber score is for sites that
are >800m but <2km from an SSSI. While Honeypot Lane falls within 2km of
a defined SSSI and is therefore within the SSSI Impact Risk Zone, the SSSI in
question is to the south of Brentwood town centre at Thorndon Park (a public
amenity and open space area of Woodland) and well away from Honeypot
Lane. The Opportunity for impact on the SSSI in this area arising from the
site's development is unclear from the SA and there is, in reality, unlikely to be
any material adverse impact arising from development of Honeypot Lane on a
SSSI located some 2.9 km away from the site by road. Any identified adverse
effects arising from Honeypot Lane's development could of course be subject
to appropriate mitigation measures and would not preclude development.
LLLP do not consider that Honeypot Lane should be scored Amber in relation
to the Thorndon Park SSSI on this basis.
* Local Wildlife Site - this criterion scores Amber if the site is <400m from a
designated Local Wildlife Site (LWS). Such sites are considered to have a
relatively low sensitivity according to the SA. In the case of Honeypot Lane,
the LWS in question is located to the north of the A12 at Weald Country Park
an established public country park location intended specifically to
accommodate and provide informal open space and recreation opportunities
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
7
for the local community. It is not clear to LLLP why Honeypot Lane is scored
Amber in this regard as the site is neither within 400m of the Park entrance (it
is some 2.2km by road) nor does residential development of the site
necessarily adversely affect the Park. Any identified adverse effects could of
course be subject to appropriate mitigation measures and would not preclude
development. LLLP do not consider that Honeypot Lane should be scored
Amber in relation to a designated LWS on this basis.
* Woodland - an Amber score is recorded for sites that 'intersect' with
woodland (i.e. have the feature on-site). Such non-designated woodland sites
are of low sensitivity. In this case, Honeypot Lane has some existing trees at
its boundaries but there is not an area of Woodland on-site or adjacent to it. It
is not clear to LLLP why the site is scored Amber in this situation. In any
event, the development of Honeypot Lane would include appropriate survey
and protection for existing trees where possible as well as a landscape
strategy to support the provision and enhancement of trees and other
vegetation offering a positive benefit. The Amber score is not supported for
Honeypot Lane.
* Green Belt - sites score Amber where they intersect with the Green Belt. It is
noted that there is no Red or Green score for this criterion set out in Table B.
Honeypot Lane is within the Green Belt, but extensive analysis of the role and
function of the Green Belt in this location has been undertaken by LLLP which
supported the Borough Council's positive support for release of the site from
the Green Belt to assist with meeting evident housing needs as well as
providing a new, long-term, defensible boundary for the Green Belt along the
A12 road corridor in this location. The Amber score is correct but should not
be viewed as a significant determinative factor in the ability of the site to be
sustainably developed.
* Special Landscape Area - the criterion is listed as scoring Amber if the site
intersects with such areas. It is noted that there is no Red or Green score for
this criterion set out in Table B. It is not clear to LLLP what landscape
designation is considered under this criterion. There is no defined landscape
quality designation applicable to Honeypot Lane. Change to the existing
landscape character is a factor of development and Honeypot Lane's
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
8
development would be subject to a detailed masterplan and landscape
strategy and supported by a Landscape and Visual Impact Assessment setting
out any residual effects and a mitigation strategy. LLLP do not agree that
Honeypot Lane should be scored Amber in relation to the Special Landscape
Area criteria.
* Agricultural Land - the SA classifies Grade 2 Agricultural Land (the Best and
Most Versatile) as Red, while Grade 3 land is scored Amber. Honeypot Lane
is a large site but has no agricultural land of Grade 1 or 2. The site is Grade
3b or below and it is noted that the SA criterion makes no distinction between
Grade 3a and Grade 3b, with the deficiency that Grade 3b is not usually
considered to be good quality agricultural land. The criterion is considered to
be crude in its assessment and fails to allow, for larger sites in particular, such
as Honeypot Lane, that there may be distinct areas of better and poorer
quality agricultural land. Agricultural land classification is not, in LLLP's view a
significant determinative factor in whether a site is capable of sustainable
development.
* General Practice Surgery, Primary School and Secondary School - these
three criteria are all based on walkable distances for those accessing
schooling or general practice surgery healthcare. Amber scores for GP
Surgery and Primary School are given for sites between 800m and 1.5km
walking distance to the nearest facility. For Secondary schools, the Amber
score is for sites of between 1.5km and 3km walking distance. This analysis is
far too simplistic as it fails to recognise: the potential for sites to bring forward
contributions to the development of school or GP surgery facilities either on or
near to the site; the level of capacity now and in future for existing nearby
facilities; or the ability of such existing facilities to expand in future. For
Honeypot Lane, there is an evident opportunity to contribute to the provision of
expanded school or GP surgery facilities to be located off-site as appropriate
in accordance with the CIL Regulations. In this respect, LLLP conclude that
the Site should be scored Green rather than Amber to the extent that this
criterion is capable of offering a meaningful assessment of sustainability in
relation to primary healthcare or schooling. A simplistic distance measure is
insufficient and it is LLLP's view that this indicator should not be weighed as
having the same importance as others in the SA site assessment.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
9
28. In conclusion, LLLP recognise that the SA sites assessment testing is intended to
offer a relatively high level analysis of the potential sustainability of individual sites.
However, from closer and more detailed review it is clear that there are significant
flaws in the individual scoring criteria and obvious mis-application of the scoring
methodology to LLLP's Honeypot Lane site such that the scoring is misleading.
29. As demonstrated throughout this representation, Honeypot Lane is a sustainable
site and compares well, if not better than other potential and proposed housing
allocation sites including the long term development of Dunton Hills Garden
Village.
30. Indeed, the SA itself concludes in Appendix IV (page 114) that Honeypot Lane
makes only a "low-moderate contribution to the Green Belt purposes" which was "a
key reason why this site was a preferred allocation".
31. Setting aside the fundamental problems identified with the SA's site assessment, it
is clear that LLLP's land at Honeypot Lane, is a sustainable site for development
and that this position is further enhanced when full regard is had to the identified
Local Housing Needs of the Borough and the ability to bring forward new sites to
support residential development in the short term.
Conclusions
32. Land at Honeypot Lane, Brentwood (022) should be included once again within the
Local Plan as a residential allocation as it offers, inter alia:
* a sustainable site that is readily deliverable for high quality new homes now
and which can contribute significantly early in the plan (within the immediate
five year period) offering an improved choice of residential development sites;
* the ability to deliver a significant level of new homes for Brentwood in order to
help meet housing needs and is not reliant on the provision of extensive new
transport or other infrastructure;
* close proximity and easy access and integration of the new homes with jobs,
community facilities, services and greenspaces in Brentwood as a principal
Tier 1 Category settlement;
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
10
* support for the distinctive character of Brentwood and the contribution of the
wider Green Belt to Brentwood's quality of life, biodiversity and environment;
* a contribution to community and green infrastructure proposals for Brentwood
town in keeping with the landscape character of the area;
* capability to be easily accessed by a range of means including by bus, foot,
cycle as well as by road as supported by discussions with Essex County
Council as the Highway who have raised no objection as to the transport
sustainability of the site or any highway effects arising;
* easy connection to utilities and site services;
* a development opportunity that will support and contribute to Brentwood's
quality of life, biodiversity and environmental character;
* the opportunity to refine and re-align the Green Belt boundary forming a long
term, logical and defensible Belt boundary for Brentwood's urban area that is
contiguous with the A12 road and relates to recognisable physical features.
33. LLLP object to Pre-Submission Local Plan because of the omission of the
Honeypot Lane site. The Plan is unsound as it is not positively prepared. The
removal of Honeypot Lane as an allocated site is not justified in the context of the
Borough's pressing housing needs and the sustainable pattern of development
sought.
34. The Plan is not effective due to its failure to maintain the allocation of Honeypot
Lane and to exclude it from the proposed residential development allocations. It
does not represent the most effective or sustainable use of land and fails to reflect
the site's inherent sustainability and ability to contribute significantly to the acute
and persistent lack of housing land supply.
Modifications Required
35. LLLP conclude that the Plan needs to be modified to identify and allocate Land at
Honeypot Lane, Brentwood (ref: 022) for residential development of up to 250 new
dwellings with associated transport, community and green infrastructure. The
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
11
allocation of Honeypot Lane must include its removal from the Green Belt and the
appropriate revision of the boundaries of that designated area.
36. The Plan's proposed Housing Trajectory (Appendix 1), the Key Diagram and the
list of proposed allocation sites should be updated to include Land at Honeypot
Lane accordingly.

Attachments: