We wish to object to the inclusion of Honeypot Lane site 022 for proposed development on the following grounds: 1. The proposed site currently forms a transition between the semi rural northern end of Homesteads Estate and Honeypot Lane and the greenbelt area around Weald Road and is bounded by trees and hedgerows that form a natural buffer to the busy A12. 2. Access to and from this part of Honeypot Lane is already restricted by the narrow width of the road by the allotments and the curved middle section of Honeypot Lane where a 20mph speed limit applies. The additional traffic generated by this proposal would add significantly to congestion within the road and surrounding area. 3. Access to Brentwood is already restricted by the busy London Road junction and single width section in Weald Road close to the junction with the High Street and the new development causing more problems at the points. 4. The traffic in Honeypot Lane is already heavy, particularly in rush hours, as it is used as a rat run between London Road and Weald Road, creating queues at the London Road. The development would exacerbate this problem and spread the problem into Homestead Estate. 5. Much of the through traffic ignore the 20mph speed limit and an increase in traffic generated by the proposed development will only increase the danger to residents. 6. The site itself has physical issues which make it unsuitable for development: 6.1 Abutment to the A12 with noise pollution issues for future residents. 6.2 A watercourse that dissects the site that already creates drainage problems. 7. The creation of further demand on local doctor's surgeries and schools. In conclusion the overwhelming reason to remove this site from consideration are highway/traffic issues and to maintain a transition from the semi-rural fringe of the part of Brentwood. There are other suggested sites that are far more suitable and in particular Dunton Garden Village provides significant additional housing with the benefit of new essential amenities for residents.

I am writing to vehemently object to the proposed development near Honeypot Road. This development is NOT sustainable:-new home owners WILL be dependent on the car for journeys to work, school, shops, leisure activities and other services and amenities. Clearly the infrastructure in West Brentwood cannot cope with 200 houses & a 40 bed retirement home. The traffic created by such a development will be horrendous for the local homes, roads & junctions & create a massive dispiriting nature. Residents will not be able to walk or cycle on Weald Road, forcing cars on the already busy roads. Buses would struggle to use this route. The distance to the station, shopping & doctors would be too far to walk- again forcing more traffic. Accessibility to public transport is poor. The local lanes are narrow & dangerous. The noise of construction & residents & overlooking would lead to a loss of privacy and will certainly impact on the peaceful enjoyment of our home and garden. 'The proposed siting of the development is particularly ill-considered: it is on a Greenfield site. The National Planning policy states that the development of Green Belt is by definition inappropriate and harmful'. The current usage as submitted in the nomination form is a wildlife area that edges allotments and is part of the historic area of South Weald. The green open space provides wellbeing of everyone in the community.' Safeguard the Green Belt from inappropriate development and enhance its beneficial use. Green Belt land should only be considered after all sustainably located, suitable, available and deliverable brownfield sites have been identified as allocations'. This green area creates an important break in the view across West Brentwood. It also protects the residents from noise and traffic pollution from the A12, as well as drainage for rainfall, the area is known for its flooding. The land is also home to bats, birds, badgers and deer. What will be the impact is the usage ceases? "If the land was not there the water from the runoff from the gardens would have nowhere to go and may cause flooding. The wildlife would be forced to go somewhere else and the houses would no longer have the special outlook which we value". Sadly it seems to be once developers have placed an option on land it becomes less desirable for the local council to fight for it. This land was dismissed under the spatial strategy but this has been reversed, where is the evidence for this reversal? It was also placed under Community Asset Transfer, again this was overturned. We would also experience light pollution & the density of this proposed development will not be in keeping with the local community. It does state in the NPPF that 'planning should take in to account different characters of different area'. There is sadly very little evidence of how such a development is meant to be proposed. Where is the access to be? How is the pinch in Honeypot Lane to be dealt with? Enormous increase in local traffic? The already busy Honeypot Lane & A1023 junction-coupled with the new development at the former police station site. Local amenities are at breaking point at the moment with doctor's surgeries taking weeks for appointments. St Peters School has very little room for development (although expansion has been turned down, sadly this will probably be reversed). As for the residents of the proposed development, there will be noise factors due to the proximately to the A12, especially with the proposed widening of this. I appreciate the pressure to build new dwellings but feel that other sites are more suitable & we can not see ANY BENEFIT TO THIS PROPOSED DEVELOPMENT except to appease developers. PLEASE think about the future of Brentwood and the need for this precious green space. ANY units here will be a travesty, coupled with the greed of developers -eventually all the space will be used as planning will no doubt always be sort again & again until this is done. Rather you use more appropriate sites to the full capacity than place random units everywhere in the hope of appeasing all.

Both I together with my husband and family would like to raise our objections regarding the development at Honeypot Lane. 1) the infrastructure to carry the additional traffic cannot be sustained on the privately maintained roads within the vicinity. 2) the increase in traffic to an already over populated area. 3) Insufficient school places for the proposed families. 4) Insufficient G.P. surgeries as my recent experience confirmed when I struggled to get registered locally after living in the borough for over 20 years. 5) A loss of green space 6) Pollution 7) Congestion.

I have been a resident of Honeypot Lane for XX years and I strongly object to the proposed housing development at site 022 of the Local Development Plan for the following reasons. Honeypot Lane is dangerous at peak times and more traffic would seriously add to congestion and delay. On an average weekday I drive backwards and forwards twice daily to my children's school, (name of school and location). I also drive into Brentwood for shopping and leisure activities 2 or 3 times daily, and to after school clubs 4 or 5 times a week. If you multiply all these journeys by another 250 families you can imagine the adverse effect on local traffic. Access to the new housing development would undoubtedly be restricted to Honeypot Lane only. An entrance onto a new housing development in Honeypot Lane would cause severe congestion at peak times with the extra traffic, and the nature of the lane would be spoiled forever. Access at the junction of Honeypot Lane/Weald Road, and between the bridge across the A12, would be inaccessible due to the extremely steep incline from the existing road down to the fields. The only other possible access road to the new housing development would be by compulsory purchasing the two end houses in the Selwood Road cul de sac, and this would cause further traffic congestion and distress to local residents. Local infrastructure cannot sustain this housing development. It is already extremely difficult to get places at both St Peter's, the catchment primary school, and also at the nearest Secondary school, Becket Keys. Both of these schools are already massively oversubscribed. If families with children move into the proposed housing development they will have to travel by car to other schools in the area, creating a bigger carbon footprint. This will also add to the congestion at both the London Road and Weald Road junctions of Honeypot Lane. Extra traffic would impact on residents living in Park Road, and also in Weald Road, particularly at the pinch point at Bardeswell Close. Sandpit Lane is another access road which is already dangerous and cannot take more traffic from this area. The local Doctors surgery has a waiting time of three weeks for an appointment. A new housing development of this size would not be large enough to qualify to have its own Doctors surgery and amenities (unlike Clements Park which has its own Doctors surgery, pharmacy and community hall). The proposed housing development would therefore have an adverse effect on the health service providers in this area. Extra pressure would be made on Doctors surgeries, Dental practices and the community hospital. There are existing drainage problems in the field that has been proposed for the new housing development. We already have flooding in our back gardens during the winter months because the land naturally slopes downwards from the London Road. Historically there also used to be a natural pond behind our homes where all this water collected. Wildlife habitat would be permanently destroyed. We have deer, badgers, foxes, bats and squirrels living in the fields behind our homes not to mention many different species of birdlife. The green belt is constantly being eroded and we should protect the few green spaces that we have left for everyone else to enjoy and not cram more houses onto every available space. Brentwood is unique for being a green and pleasant suburb and should remain so. It would therefore make much more sense to create a purpose built housing development at the proposed site 200 of the LDP at Dunton Garden Village where facilities such as Schools, Doctor's surgeries, pharmacies and community meeting places could all be included in the new build.

It is with a heavy heart that I am sending this email I have lived in Honeypot Lane for nearly 40 years things have changed over the years one is the increase in traffic in the road it is now a major rat run for everybody trying to avoid getting caught in a grid locked brentwood .Huge lorries are constant reminder of how things have changed and roads certainly don't support such large vehicles but the council is not interested in this.To people I now refer to honeypot as the inner Brentwood bypass because of the amount of traffic on a daily basis.The same arguments still apply for which we have been trying to get the council to understand the impact on the whole community not just westBrentwood but the whole of the town.Doctors surgeries already full ,schools,pollution,the fact its a green belt area.
The council will put us through at least 5 years of misery and while I appreciate the need for housing I do believe that the council is blinkered to a development on this site as an easy alternative without really looking into alternatives
So finally NO DEVELOPMENT IN HONEYPOT LANE

I am writing to object to the above proposed development being included in the Local Development Plan for the following reasons:

1. Honeypot lane already has an issue with dangerous speeding traffic. 20mph limit signs were erected a few years ago, but it has not been policed despite repeated requests. It is reasonable therefore, to assume that speeding will continue for the foreseeable future.
2. Much of developed part of Honeypot lane only has a pedestrian path on one side of the road because it is so narrow.
3. The lane narrows down still further before reaching the proposed development site.
4. Development of this proposed area has been turned down by the council before, as it did not meet the government's "Spacial Strategy" requirements. It is clear from the government's guidelines, this site still does not meet these requirements.
5. This development is proposed on green belt land. The government still stresses the importance of protecting green belt land. National planning guidelines state that only in exceptional circumstances can development take place on greenbelt land, and housing is not considered exceptional circumstances.
6. There are 2 significant developments planned, which are within ¼ mile of Honeypot Lane.
One is on the site of the Police station (70 units), and a large office block in Hubert Road which is being converted to flats. Both developments will have access to London Road. I'm pretty sure nobody in Planning has considered the extra traffic flow that these new developments will create in addition to any as a result of a development in Honeypot lane.
7. The proposed development is a mile from the town centre. There is no bus service in Honeypot Lane, and it wouldn't be practical (see points 1-3). Residents at the proposed development would have no alternative other than to use their cars. This does not meet the governments sustainability targets. If there are infrastructure solutions suggested, I for one no nothing about them.

In Summary, the council has failed to give the development plan the careful consideration it is duty bound to do. The proposed site is wholly unsuitable for development anyway. It has severe flooding issues, and has a stream running through it. This council is used to getting its own way and it is clear it has become lazy in its approach. I wholeheartedly object to the proposed Honeypot Lane development.

I am writing to object to the above proposed development being included in the Local Development Plan for the following reasons:

1. Honeypot lane already has an issue with dangerous speeding traffic. 20mph limit signs were erected a few years ago, but it has not been policed despite repeated requests. It is reasonable therefore, to assume that speeding will continue for the foreseeable future.
2. Much of developed part of Honeypot lane only has a pedestrian path on one side of the road because it is so narrow.
3. The lane narrows down still further before reaching the proposed development site.
4. Development of this proposed area has been turned down by the council before, as it did not meet the government's "Spacial Strategy" requirements. It is clear from the government's guidelines, this site still does not meet these requirements.
5. This development is proposed on green belt land. The government still stresses the importance of protecting green belt land. National planning guidelines state that only in exceptional circumstances can development take place on greenbelt land, and housing is not considered exceptional circumstances.
6. There are 2 significant developments planned, which are within ¼ mile of Honeypot Lane.
One is on the site of the Police station (70 units), and a large office block in Hubert Road which is being converted to flats. Both developments will have access to London Road. I'm pretty sure nobody in Planning has considered the extra traffic flow that these new developments will create in addition to any as a result of a development in Honeypot lane.
7. The proposed development is a mile from the town centre. There is no bus service in Honeypot Lane, and it wouldn't be practical (see points 1-3). Residents at the proposed development would have no alternative other than to use their cars. This does not meet the governments sustainability targets. If there are infrastructure solutions suggested, I for one no nothing about them.

In Summary, the council has failed to give the development plan the careful consideration it is duty bound to do. The proposed site is wholly unsuitable for development anyway. It has severe flooding issues, and has a stream running through it. This council is used to getting its own way and it is clear it has become lazy in its approach. I wholeheartedly object to the proposed Honeypot Lane development.

I would like to register my objections to the inclusion of land at Honeypot Lane, Brentwood, on the preferred list of sites for housing development in the Local Development Plan which is currently being considered. Honeypot Lane is a completely unsuitable location for the planned 200 homes plus a 40 bed care home and would destroy an important piece of protected Green Belt land, ripping apart the rural character of this part of Brentwood and destroying wildlife habitats. My reasons for objecting are as follows: I have been a resident of (name of street) for XX years and traffic issues in the locality have been a constant concern. Access to the potential development site would have to be off Honeypot Lane or Weald Road and all these points suffer from considerable traffic problems as they are already used as rat-runs to local schools, London Road, the M25 and station etc. The lower section is a country lane and has a narrow chicane section near the housing. This is already dangerous with vehicles frequently mounting the pavement to avoid giving way to oncoming vehicles. Honeypot Lane now has resident parking bays but there are still sections of double parking which makes it difficult for motorists to negotiate. There is only one narrow footpath for pedestrians. Any development would mean years of major disruption such as noise, traffic congestions and pollution in all the surrounding roads with the heavy construction lorries and plant machinery. In the longer term the additional traffic movements from the proposed development - potentially 2,000 a day if you take into account journeys for work, shopping school runs etc. All this would would seriously exacerbate the existing congestion and hazards. It's not just private car movements that are my concern - hundreds of new homes mean hundreds of lorry and van movements from postal, online shopping, supermarkets etc. The roads simply could not cope and there are both health and safety risks with the resulting increase in traffic pollution. There are chicane or "pinch points" on all other potential approach roads - i.e. Weald Road at High House, Weald Road near St Peter's Church, Park Road and surrounding roads, Western Road, Sandpit Lane etc. There would be a knock on effect for Ongar Road, Brentwood High Street. This proposal has wide issues for Brentwood Town Centre and South Weald. The Homesteads Estate (Hill Road, Hillside Walk and Weald Road) are private roads for which the residents pay the upkeep. These roads already suffer from very heavy use by drivers who do not live on the estate. Any further development of housing in this locality would cause even more serious damage to the road surfaces as there would be a massive increase in rat-running traffic. Traffic volume considerations aside, there is not the infrastructure to support the potential Honeypot Lane development. As well as highway infrastructure issues, there are not sufficient doctors' surgeries for more than 1,000 new residents. I attend Beechwood Surgery and it is already difficult to get a non-emergency appointment. Schools are also at full capacity and St Peter's Primary is oversubscribed and cannot expand. I object to this deeply flawed proposal as it will destroy the green belt. There is a great deal of wildlife on the land in question including bats etc. The green fields are part of a very precious green lung and allow uninterrupted views of South Weald and St Peter's Church. There are mature trees, hedgerows and a stream. It is an important source of drainage as the land slopes down from Hill Road. Flooding and drainage is already a problem on the land in question and development would exacerbate these issues for residents whose properties adjoin the land. The Honeypot Lane site was previously rejected as it did not meet the Council's Spatial Strategy Metropolitan Green Belt Lane. The site is completely inappropriate for housing development and I would urge that it is removed from the list of preferred sites in the Draft Local Plan

Dear Sir / Madam,

I popped into one of the drop in sessions in a dilapidated shop near the Baytree Centre and I had a good chat with one of your staff.

It was quite informal but I still have quite a lot of questions that have not been addressed despite my many queries in my 20 years of living in Brentwood as follows:

Why is there not 2 hours parking in Brentwood like Shenfield residents enjoy?

why are there no fast trains from Brentwood station despite it being the may residential area in the borough?

why no lift to platform 4 at Brentwood station?

why no foitpath to weald and throndon country parks?

why £5 to park in the above 2 parks?

why no benchmarking on parking charges compared to nearby towns like Upminster, Harold Hill, Hornchurch, Romford, Billericay, Basiodon, Grays, Epping, Lakeside for a start. For example Basildon and Romford have free parking on a Sunday so why doesn't Brentwood?

Why do you still charge to park in the evening when most towns nearby don't?

Why are you building houses on the car park in William Hunter Way, the car park is always full?

why are you building on Brentwood station car park, this will lose spaces and discourage use of the train station?

why is a green belt side at Honeypot Lane being built on? When the road is narrow and there is no bus route or doctor's surgery for these 250 new houses?

Why can't we have more Sunday bus routes in the district? There is no way of getting to Basildon, Lakeside or Southend and Chelmsford bus is only every 2 hours, Bishops Hall Estate every 2 hours and Hutton Circular every 2 hours, the only decent bus is the 498 to Romford still only every 30 minutes though!

Why can't Brentwoid folk use oyster cards on all the buses like you can on the train?

why is there a 4 zone difference between Brentwood and Harold Wood? It is only 3 miles and not worth a £1,000 a year for such a short journey, equally why is the fare from Brentwood to Shenfiekd for 1.5 miles £600 a year and to Harold Wood for 4.5 miles £1,600 a year, why do you allow TfL and the DfT to milk Brentwood residents to subsidise London people?

why don't the new crossrail trains have softer seats and loos on them?

why are there hardly any buses to get to Shenfield to access the 14 trains per hour? All the buses go to Brentwood station where there is only 6 an hour which are all slow and don't even go beyond Shenfield, annoyingly? !?!

why are 20 mph speed limits not enforced on residential roads?

why is there no parking enforcement on law breakers who park on double yellow lines after 6pm or all day Sunday, yet you choose to send out peaked cap people to put tickets on cars in the town centre car park, double standard or what?

i cannot access my garage due to inconsiderate oiks in the flats behing my house obstructing my garage, and the peaked cap gestapo say they are unable to do anything why?

Why no buses on the weald road to access weald country park and old macdonalds farm, and why no hail and ride bus between ongar road and weald road for non drivers and disabled?

why has the council done nothing to stop the re routing of 37 bus and cutting of other routes i.e, to Harlow, Lakeside, Stanstead Airport and Epping?

That is all folks!

Many thanks

I am writing to object to the above development being included in the Local Development Plan.

The traffic caused by 200 extra houses plus a care home would cause a dramatic increase in traffic in all local roads and it is likely that the Homesteads Estate would close their gates to traffic further adding to the problem. Honeypot Lane is already a cut through from London Road to Weald Road and traffic already ignores the 20mph limit. There would be a major problem with traffic wherever the main entrance to the site was located. Initially this traffic would be heavy plant which the local roads cannot cope with in terms of size and structure.

There is also currently an issue with parked cars in the area as a lot of office workers park their vehicles in Spital Lane, Selwood Road and Brook Road during the week which has caused traffic congestion. Our local councillor is already aware of this.

This is important Metropolitan Green Belt land which is already prone to flooding and drainage issues. Current properties backing onto the site already experience problems.

Local school and doctor surgeries have no capacity for additional residents. Essex County Council school admissions have been oversubscribed for the last 2 years and have had to make arrangements with local schools to take extra pupils - a situation that cannot go on.

The site was previously rejected as it did not meet the Council's Spatial Strategy - noting has changed.

Please take my views into consideration.

I am writing to object to the above development being included in the Local Development Plan.

The traffic caused by 200 extra houses plus a care home would cause a dramatic increase in traffic in all local roads and it is likely that the Homesteads Estate would close their gates to traffic further adding to the problem. Honeypot Lane is already a cut through from London Road to Weald Road and traffic already ignores the 20mph limit. There would be a major problem with traffic wherever the main entrance to the site was located. Initially this traffic would be heavy plant which the local roads cannot cope with in terms of size and structure.

There is also currently an issue with parked cars in the area as a lot of office workers park their vehicles in Spital Lane, Selwood Road and Brook Road during the week which has caused traffic congestion. Our local councillor is already aware of this.

This is important Metropolitan Green Belt land which is already prone to flooding and drainage issues. Current properties backing onto the site already experience problems.

Local school and doctor surgeries have no capacity for additional residents. Essex County Council school admissions have been oversubscribed for the last 2 years and have had to make arrangements with local schools to take extra pupils - a situation that cannot go on.

The site was previously rejected as it did not meet the Council's Spatial Strategy - noting has changed.

Please take my views into consideration.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

I am writing to object to the Honeypot lane development being included in the local development plan :The traffic caused by 200 extra houses plus a care home would cause a dramatic increase in traffic in all local roads.Traffic at peak times is already very heavy and causes long tail backs at all junctions leading onto London road. Honeypot lane is already a cut - through from London Road to Weald Road and traffic still speeds through the road ignoring the 20 mph speed limit. There would be a major problems wherever the entrance to the site was located. All adjacent roads and Homesteads Estate would become a traffic 'rat run'. There are also many safety risks and extra pollution .
: This is important Metropolitan Green Belt land and I feel strongly that such land should be protected .
:Local schools and doctors surgeries have no capacity to support the additional residents.
:Site was previously rejected as it did not meet Council's Spatial Strategy -nothing has changed.
:The development would cause flooding and drainage problems in the area. The gardens in some houses backing onto the site already experience problems.
: This is not a good choice for such a development. A deeply flawed plan.
: Please take my views into consideration.

My family would like to make clear our objection to the above proposal for the reasons highlighted below: We live in (name of Road) and we already experience excess traffic (which is usually above the 20mph limit) cutting through from the Weald Road or London Road direction. 200 extra properties in our area would put a dramatic increase on traffic around our home and this would greatly inconvenience us, encouraging further cut-throughs and making our road more dangerous for our children. Furthermore, we presume that there will be an entry point to the new site on or close to Selwood Road, which would have a direct impact on us, being situated at one end of this road. Currently we live in an environment where we would be happy for the children to play in our front garden and we feel that it's unfair to entirely change this, meaning that this could no longer be possible. This will therefore have a detrimental effect on our enjoyment of our home and ultimately our lives in Brentwood. Our children attend St Peter's School in South Weald and we walk to/from school most days. This is a popular school and is always over-subscribed. Some years, no children from within the catchment area are accepted due to siblings and allocation of church places. There is no capacity for extra spaces at this school and the residents of your proposed housing will almost certainly be expecting to attend. In 2016, St Peter's gained funding in order to accept an extra 15 children. Even these extra families have added unnecessary pressure onto the school and its resources - particularly the roads around the school and in the church car park. On a daily basis, people park inconsiderately either on the road or in the car park, and each morning the road is gridlocked around school drop-off and collection times. We have witnessed accidents, road rage and pedestrian near misses (including children), all because of the pressures on Wigley Bush Lane and Weald Road. Even if the school were to increase in size to accommodate further local families, the infrastructure around South Weald is just not set up for the impact this new housing would have. It's a rural area and in our opinion, that's how it should stay. A proposal such as this will increase these traffic issues further and eventually Essex Highways or Brentwood Borough Council will have to take action to resolve this, or they may have a serious accident to deal with. From Honeypot Lane it's not possible to walk to school directly as there is no path, and walking via the Homesteads and Brook Road/Spital Lane would be too far for the majority of people. Therefore, anyone travelling to school from this new area would have to drive and this would be worse for our environment, result in more traffic on the roads, more cars in the car park, and more potential for accidents. This is not a risk we would be willing to take, particularly as there are children involved. This area simply can't cope with 200 more families who may potentially wish to attend St Peter's, or 200 extra cars driving around our roads. We believe that this site was previously rejected as it did not meet your own Spatial Strategy. In your recently published documentation, you state that there is "an emphasis upon protecting and enhancing local character". The residents of the precise location in which you are proposing to place this development will be directly affected by this housing. We presume that currently the residents of these homes in the private Hill Road look out onto fields. We would imagine that their view of green belt was a key factor in these people choosing to live in these homes. It's not like someone taking down a tree which exposes an ugly building - it's the difference between having an uninterrupted view of the countryside and someone being able to look into your bathroom. We always enjoy walking around the Homesteads and this experience and that of the residents living there will almost certainly be spoilt by the proposed housing. This totally contradicts your claim that you wish to protect and enhance local character. In addition, one of your published strategic objectives regarding Environmental Protection & Enhancement is to "Safeguard the Green Belt from inappropriate development and enhance its beneficial use." Extra housing in an area such as this does not safeguard the green belt, it entirely ruins it. You mention also that the watercourse is one of your considerations, and this must surely present many problems which could greatly affect the proposal. Many roads around that area (including Honeypot Lane and part of Weald Road) regularly flood after heavy rain and presumably this is not helped by the close proximity to the brook and other water sources around this. Not only would this proposal ruin the aesthetics of the area, it would also require interference in a natural source of water which is currently just fine as it is, running through an uninhabited area and around existing properties. Seven years ago we chose to move to Brook Road as this was a quiet area and the garden is relatively unaffected by the noise pollution of traffic. With the proposed increase in residents in our area, and therefore traffic, this will almost certainly change and our enjoyment of our much loved home will change with it. This area appealed to us as it's a perfect combination of a rural environment (close to Metropolitan Green Belt and unspoilt areas), yet accessible to the town centre (and our children's school). You are proposing to take this beauty away from us and we all feel that this is extremely selfish and will totally change our way of life. In conclusion, we feel that this is an ill-considered proposal which will have a detrimental effect on the existing residents of this area. We have not spoken to a single person who lives in this area who is in agreement with the proposal and we find it impossible to believe that there are not more suitable options under consideration.

See Attached

I am writing to protest about the inclusion of land in Honeypot Lane on the Proposed Local Development Plan. This plot is classed as Metropolitan Green Belt and we feel very strongly about the loss of such sites as once it is built on it will set a precedent for other developments of such land in Brentwood, and we will end up living in a totally built up area with no green space. I am sure most people who live in these areas on the edge of Brentwood backing Green Belt land will have chosen to do so and will have paid a premium price for their property. A development of this kind would totally ruin the rural character of the area. If we wanted to live in a house in the middle of a built up area we would have done so and bought a house at a much lower cost. The land attracts much wildlife, such as deer, badgers, bats, squirrels and many species of birds. The hedgerows near the site are also very old and I believe that the reason the pedestrian pathway goes into behind the road into the BT land was to prevent disturbance of historical hedgerow. The main objection, however, is the traffic that a development of around 200 houses plus a care home will cause in such a small lane which is not even wide enough for two cars to pass in some parts. It is already used as a cut through from London Road to the Ongar Road and there are regularly queues of traffic at the junction of Honeypot Lane and London Road. I am sure that many of the people living in these houses of this planned development will need to drive to work or drive children to school in the busy morning and evening periods which will cause chaos on already congested roads such as London Road, Ongar Road and Weald Road, and will force traffic down the smaller back roads. An average household doing a school run and a work run will amount to six extra journeys a day, and realistically this could amount to over 1000 journeys a day even if only a proportion of the residents make the daily runs. Additionally there would also be the normal mail and household deliveries. Honeypot Lane is a lane, not a major road, and the traffic speeds along it, even though it has been changed to a 20 mile an hour speed limit, and this has been reported to the police. We live on the bend near Hill Road and since we have lived there, a number of cars have lost control and ended up in our hedge damaging the trees and fence, and previous to that cars have actually skidded down the grass verge onto the drive of the houses below. Extra traffic along this road would increase the chances of such incidents happening again. In icy weather the road is treacherous and with more traffic would be even more dangerous. The excessive parking in Honeypot Lane from commuters and people working in Brentwood made the road difficult to drive along safely and this was the reason the parking restrictions were implemented. Extra housing would just exacerbate all the problems, wherever the entrance to the site is built. The proposed development site is at the bottom of the hill and is very wet as the water runs down Honeypot Lane and also off the road down our gardens and into the fields and Honeypot Lane itself floods regularly. Building on this land makes a mockery of the Council's planning rules. We explored the possibility of extending our driveway but were told we would need planning permission to cover the extra two metres of undeveloped land with impermeable material, but it seems that the Council are quite happy to consider building a whole housing estate on undeveloped land. Before any building could begin 18 months of drainage work will need to be carried out on the site. The traffic from this work alone will be intolerable and cause major problems. The schools in this area are all at capacity and although I believe plans have been discussed for another school to support this development it would not be in the immediate vicinity which would mean longer car journeys to travel further afield to get children to school. The local doctors' surgeries are full and even now many people have to wait weeks to see their doctor. An increased population in the area would have a further impact on this. This land has been considered in the past, but it was deemed unsuitable as it did not meet the Council's Spatial Strategy and was taken off the Proposed Plan back in 2012. Nothing has changed and therefore I cannot understand why it has been included again. I do realise that more houses need to be built in the country, but I do expect some common sense to be given as to where they should be built. I am sure there must still be Brownfield sites that could be put forward for development before using the Green Belt land that should be protected. Extra development should be made in an area where the infrastructure can be put in place to support it and this is not in Honeypot Lane. Why can't more houses be built on the Dunton Garden Village site, where infrastructure is already being planned. I would be grateful if these objections could be considered before the inclusion of the site on the Local Development Plan.

It is common local knowledge Honeypot Lane is a small narrow road with single lane passing. It would not support a heavier work load that this development would bring for the coming 5 years of build time and later to support 4/500 cars plus services and emergency traffic adding to an already heavy polluted area. Apart from the general infrastructure being totally inadequate there would be no support for schooling the potential 200/400 extra school children in the area, no local school could accommodate them, no doctor would able able to enlist such an increase in population, there is no transport system in place to cope with such an increase in children and residents. It will create a larger Rat Run than what already exists through Honeypot Lane, Hill Road, South Weald Road, Hillside Walk on homestead estates. An area unique to Brentwood, which should be preserved, treasured and enjoyed by everyone, not be destroyed, sadly areas such as these are becoming a rarity. Kindly consider and prioritise our neighbourhood and prevent this unacceptable development from progressing becoming a reality, preserve what little is left of the Green Belt, this proposal will only set a president for the future.

PART 2 | HOUSING SITES | Brentwood Urban Area - A12 Corridor - Urban Extensions Site ref 022 Land at Honeypot Lane page 77. This site is adjacent to the allotment site on Honeypot Lane. Brentwood Horticultural Society, as managing agents, are responsible for maintaining the amenity of this site for current and future plotholders. BHS urges that housing and the care home on site 022 should be situated to ensure that there is no shading of the allotments which would be detrimental to their main purpose of growing crops and that overlooking should be minimised to preserve the peaceful amenity of users of the allotment site. Before any work starts on 022, including preliminary surveying or groundwork, the allotment site must be protected by a secure, permanent perimeter fence (material etc to be agreed with BHS) with a surrounding buffer zone, preferably preserving or replacing the existing hedging in order to protect both plotholders and local wildlife. Site 022 will inevitably be the target of vandalism and theft and a secure fence is essential round the allotment site to deter entry to 022 via the allotments and to ensure the safety and security of the plotholders. Once work commences on site 022, no entry onto the allotment site must be made by construction staff without the prior agreement of BHS. No vehicles, equipment, materials or waste from site 022 must be parked, placed or dumped on the allotment site at any time. Drainage and waste water from site 022 must be managed and no waste water must be dumped or allowed to run onto the allotment site; any facilities such as Portaloos or rest rooms must be placed well away from the allotment site to ensure that they do not adversely affect the allotment users or the site. These conditions are sought by BHS in order to protect the health and safety of current and future plotholders, as well as to preserve as far as possible the continuing peaceful amenity use of the site for allotment use. Sow and Grow, Ongar Road, Pilgrims Hatch Site ref 010 page 73. This site is adjacent to the allotment site on Ongar Road. Brentwood Horticultural Society, as managing agents, are responsible for maintaining the amenity of this site for current and future plotholders. BHS urges that housing on site 010 should be designed to ensure that there is minimal shading of the allotments which would be detrimental to their main purpose of growing crops and that overlooking should be minimised to preserve the peaceful amenity of users of the allotment site. Before any work starts on 010, including preliminary surveying or groundwork, the allotment site must be protected by a secure, permanent perimeter fence (material etc to be agreed with BHS). Site 010 will inevitably be the target of vandalism and theft and a secure fence is essential round the allotment site to deter entry to 010 via the allotments and to ensure the safety and security of the plotholders. Once work commences on site 010, no entry onto the allotment site must be made by construction staff without the prior agreement of BHS. No vehicles, equipment, materials or waste from site 010 must be parked, placed or dumped on the allotment site at any time. The road access to the allotment site must not be obstructed and any damage to its surface must be repaired immediately. Drainage and waste water from site 010 must be managed and no waste water must be dumped or allowed to run onto the allotment site; any facilities such as Portaloos or rest rooms must be placed well away from the perimeter of the allotment site to ensure that they do not adversely affect the allotment users or the site. These conditions are sought by BHS in order to protect the health and safety of current and future plotholders, as well as to preserve as far as possible the continuing peaceful amenity use of the site for allotment use

Please find attached objections from the South Hill Residents Association Limited (SHRAL) (two documents).
This proposed site will have an extremely detrimental effect on our private roads.