The %age measures used in this hierarchy are inappropriate as they do not highlight the impact on each settlement in isolation. In particular, it downplays the effect on smaller settlements by not properly highlighting the very significant changes which would result from the proposed developments, compared to their existing size. For example, the reported increase in Blackmore's %age of Total Dwellings from 1.05% to 1.13% sounds insignificant when presented in this manner and fails to highlight what actually represents a 28.6% increase in the proposed number of dwellings in that settlement.

It is unreleastic to expect the central brentwood area which currents accomdates 28% of the towns residential units to accomadet a further 26%. The existing infrastructure is already at capacity and no consideration has been given to supporting utilities in the area .

Hermes Investment Management supports Figure 14 as it relates to West Horndon. 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 represents as desired minimum number of new dwellings the Council would like to see the site yield.

Whilst I understand the need to plan for inevitable future development, the plan outlines a disproportionate impact on Shenfield area and further consideration is needed for the various infrastructure challenges which currently exist today. Figure 14 (Settlement Hierarchy) of the current local plan understates the impact as the 95 dwellings under consideration off of Priests Lane is not included, despite being in Shenfield. Therefore, whilst other areas, excluding Dunton Hills and West Horndon, generally are expected to have increase in dwellings around 10-20%, Shenfield is outlined to have an increase in dwellings of just under 50%, from 2,053 to 3,048, once corrected for suggested allocation of 95 dwellings off Priests Lane, Shenfield (044 & 178). The main concerns are school accessibility and impact on local traffic, which is already under pressure currently without an additional 50% in capacity to consider. The suggested plan doesn't appear to consider the impact on school accessibility adequately. From primary school perspective, a new primary school is considered to take the burden from sites 034, 087, 235, 276, 158 and 263, Hogarth School is listed as potential candidate to take the uplift from other "Old Shenfield" sites, under 311 (Crescent Drive), 044 and 178 (Priests Lane). These sites have combined dwelling allocation of 55 + 95 = 150, yet the forecast excess capacity for Hogarth School is 61 places across all school years. This doesn't appear adequate. From a secondary school perspective, the plan doesn't outline a material impact. The majority of increase in capacity is expected to come from Shenfield High, from across a number of sites, not only those in the close vicinity. The total number of dwellings allocated to Shenfield High is 1,003 but doesn't include Site 263, which would be in the close vicinity of Shenfield High. This site has an allocated dwelling of 215. This site hasn't been assigned to any of the secondary schools so appears to be an omission which also needs to be considered. The total number of dwellings allocated to Shenfield High including Site 263 is therefore 1,218 plus % share from nearby villages. Excess capacity of 545 spaces doesn't seem adequate compared to the suggested increase in dwellings to be associated with Shenfield High. Linked to the school accessibility is the physical access routes and impact on local traffic. Starting with the primary school aspect in Shenfield, as mentioned above, any associated requirement for primary school places from sites 311 / 044 / 178 (Crescent Drive and Priests Lane) are expected to be allocated from capacity in Hogarth School. Access to Hogarth School from these sites is likely to be via Priest Lane into Shenfield Crescent. The local traffic in this area is already excessive and severe at peak times, as this area combines with a main route into Brentwood via Middleton Hall Road / Ingrave Road, as well as already being an access to route to Hogarth School and Brentwood School. An additional 150 dwellings in this vicinity would further exacerbate the existing severe traffic issues in this area. Moreover, Priest Lane, having expanded from being a country lane, is not well equipped for excessive traffic, being very narrow in places and without adequate pedestrian walkways in certain places and therefore doesn't seem appropriate to continue to increase traffic pressure here. From a secondary school perspective, as suggested by the number of sites which would be linked to secondary places at Shenfield High, it would appear that there is an expectation for further traffic coming from further afield, not just from those sites in the close vicinity to the school. Aside from increased traffic to and from Shenfield High, the vast number of suggested dwellings across Shenfield would no doubt have an impact on local traffic across Shenfield. Already, at peak times there are traffic challenges at a number of places across Shenfield: * Priests Lane junction with Middleton Hall Lane, as previously outlined. * Friars Avenue junction with Hutton Road * Hutton Road generally, by Shenfield Station * Hutton Road junction with Chelmsford Road * Chelmsford Road going into Brentwood. The above are main routes into / from Brentwood and would no doubt be impacted by the near 50% increase in dwellings outlined for Shenfield. From a personal perspective, living on Friars Avenue, I see the amount of vehicles which use Friars Avenue / Priests Lane as alternative route into / from Brentwood. I have concerns on the amount of increased traffic and the potential for further accidents as a result of increased local congestion. Overall I don't support the disproportional impact outlined for Shenfield.

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.