DHGV should be deleted from Settlement Category 2 and separately identified in
both Figures 2.2 and 2.3 of the Plan in order to make plain its current situation.
Paragraph 2.14 should then be modified accordingly to clearly articulate that the
Garden Village does not yet exist and remains an aspiration of the BBLP rather than
a final development scheme.

Representations for and on LaSalle Land Limited Partnership
Settlement Hierarchy - Figures 2.2 and 2.3 and Supporting Text
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with the proposed settlement categorisation and
hierarchy set out in Section 2 and Figures 2.2 and 2.3 and supporting paragraphs.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Overall Settlement Hierarchy
4. LLLP support the overall settlement hierarchy and categorisation of individual
existing towns and villages set out in Figure 2.2 of the BBLP but have concerns with
respect to the categorisation of Dunton Hills Garden Village (DHGV) as falling within
Settlement Category 2.
Settlement Category 1 - Brentwood
5. LLLP support the identification of Brentwood town as forming part of Settlement
Category 1 and agree with the description of such settlements in the Figure 2.3
(table following paragraph 2.10). It is agreed that Brentwood is correctly identified
as a 'Large Town'.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
6. LLLP are however concerned that Figure 2.3 does not provide sufficient emphasis
in the text to the effect that Settlement Category 1 towns provide the most
sustainable locations in the Borough for future development and services. The text
should also be modified, in LLLP's view, to include reference to the need to use
greenfield and Green Belt land in and at the edge of Brentwood town for future
housing and economic development.
Settlement Category 2 - Dunton Hills Garden Village
7. LLLP object to the inclusion of Dunton Hills Garden Village as part of Settlement
Category 2. The Garden Village does not exist and does not relate to the text in
Figure 2.3 that describes Settlement Category 2 as larger villages in a rural setting.
8. DHGV is an untested, future, strategic development proposal using greenfield,
Green Belt land. The development proposals are aspirational and it is not an
existing settlement location.
Conclusions
9. LLLP supports the overall approach to the identification of the Settlement Hierarchy
and categorisation.
10. LLLP does however object to the inclusion and approach to Dunton Hills Garden
Village in Figures 2.2 and 2.3 and the supporting text of paragraph 2.14. The
Settlement Categorisation is not sound as it is not:
* Justified - for the reasons identified in this representation, the inclusion of
DHGV as a Settlement Category 2 location is not justified. The settlement
hierarchy needs to reflect the situation now. Future development proposals
(including the provision of a new settlement such as DHGV), which have yet
to be tested in detail and which have not been found to be the most
appropriate growth strategy fall outside the settlement hierarchy. Their
inclusion as if they already exist (and have received planning approval) is
not justified.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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* Effective - the inclusion of DHGV in Settlement Category 2 fails to reflect the
proposed scheme's status and that its development is an aspiration of the
BBLP rather than forming part of the existing settlement hierarchy.
Modifications Sought
11. DHGV should be deleted from Settlement Category 2 and separately identified in
both Figures 2.2 and 2.3 of the Plan in order to make plain its current situation.
Paragraph 2.14 should then be modified accordingly to clearly articulate that the
Garden Village does not yet exist and remains an aspiration of the BBLP rather than
a final development scheme.

LLLP consider that the Plan requires modification to Policy SP02 to:
* increase the overall housing requirement in order to meet the current Local
Housing Need with a suitable, additional 20% supply buffer;
* extend and increase the housing requirement set out to ensure that there is a
minimum 15 year lifespan for the Plan at the point of adoption;
* remove or significantly modify through the allocation of additional sustainably
located sites the proposed stepped housing delivery trajectory from the policy
so that there is a significant increase in delivery in the early part of the Plan
period; and
* redress the imbalance in housing distribution that over-emphasises the DHGV
site and fails to align with the Plan's stated sequential land use test.

Representations for and on LaSalle Land Limited Partnership
Local Housing Need and Policy SP02: Managing Growth
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Local Housing Need and Policy SP02:
Managing Growth.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Local Housing Need and Planned Requirement
4. The Standard Method assessment for Brentwood Borough published by the
Ministry of Housing, Communities and Local Government (MHCLG) in September
2017 identifies an assessed local housing need of 454 dwellings per annum (dpa).
5. The Brentwood Borough Strategic Housing Market Assessment (January 2018)
was undertaken by consultants PBA in January 2018 and concluded that the
Borough had an Objectively Assessed Housing Need (OAN) of 360 - 380 dpa.
6. The latest The Brentwood Borough Strategic Housing Market Assessment: Part
One (October 2018) was prepared by consultants PBA for the Borough Council.
The latest update considers the housing requirement using the Standard Method
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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updated to a 2019 base date. It concludes at Figure 2.1 that there is an uncapped
need for 365 dpa in the period 2019 - 2029.
7. The updated SHMA's calculation of the Local Housing Need requirement by the
Standard Method uses the 2016-based Sub National Housing Projections (see
paragraph 2.7). These are the latest projections available, however the National
Planning Policy Guidance (February 2019) confirms (Section 2a-005-20190220)
that the 2016-based projection should not be used for the purposes of projecting
the Local Housing Need requirement and that the older 2014-based Household
Projections should be used.
8. If the 2014-based projection is used within the Standard Method and applied with
the appropriate affordability adjustment (based on the latest median workplace
affordability ratio of 11.2) and the increase capped at 40% (as per the NPPG) then
LLLP calculate that the Borough's Local Housing Need is 452 dpa.
9. The Borough's SHMA as a key piece of the Plan's evidence should be updated to
take account of the current NPPG requirements and the stipulated use of the
2014-based household projections in calculating the Local Housing Need. The
latest SHMA (October 2018) identifies the importance of further review prior to the
Plan's submission for Public Examination at paragraph 9.6. LLLP support this
need for further review and update before the Plan is submitted.
10. LLLP are concerned that the Local Plan's Local Housing Need figure (set out at
paragraph 4.13 and in Figure 4.1) of 350 dpa does not represent the appropriate
starting point for establishing the Local Housing Need and must be updated and
revised to 452 dpa in order to accord with the NPPG, particularly the expectation
at Section 2a-003-20190220, that the Standard Method will be used and that any
other method will only be used in exceptional circumstances. LLLP do not
consider that there are exceptional circumstances arising in this case.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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11. The proposed housing requirement of 7, 752 new dwellings over the plan period
set out in Policy SP02 should be increased to at least modified to 9,214 dwellings1
in the 17 year period 2016 - 2033.
12. Furthermore, with regard to LLLP's concern that the Local Plan period will not be
15 years at the date of adoption in accordance with the NPPF (see LLLP's
separate representation regarding paragraph 1.1 of the Local Plan), the Local
Housing Need and the planned housing requirement should be adjusted
accordingly.
Housing Land Supply and Housing Delivery Test
13. Figure 4.1 of the Pre-Submission Local Plan identifies an annual housing supply
buffer of 456 dpa. This figure is understood to be based on the application of a
20% uplift to the 380 dpa annual housing figure set out in the Borough's SHMA
(January 2018 version). The Plan states that the housing supply buffer allows for
additional housing supply to be maintained throughout the plan period.
14. LLLP welcomes the principle of setting a housing land supply position in excess of
the annual housing requirement as a positive and pragmatic approach to meeting
and significantly boosting the Borough's housing supply.
15. As set out above LLLP considers that the Local Housing Need is 452 dpa based
on the application of the Standard Method using 2019 data. It therefore follows
that a 20% uplift to the Local Housing Need (452 dpa + 20% uplift = 542 dpa)
should be applied in order to provide additional flexibility in the supply and delivery
of sites. The additional uplift is also to serve as a safeguard for any further uplift in
the Local Housing Need resulting from future changes to the Standard Method
prior to the Examination and Adoption of the Plan.
16. This additional housing supply is particularly important in Brentwood Borough
given the failure to maintain a five year housing land supply as paragraph 4.18 of
the Pre-Submission Local Plan identifies.
1 The increased figure of 9,214 dwellings is based on the current Local Housing Need of 452 dpa + the 20%
additional supply buffer proposed by the Council which totals 542 dpa. 17 years x 542 dpa = 9,214
dwellings
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
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17. Paragraph 4.18 of the Plan also notes that it is not possible to identify a five year
housing land supply capable of delivering the annualised housing requirement.
18. The Government's recently published Housing Delivery Test (February 2019)
confirms a significant and persistent shortfall in housing delivery (only 51% of the
relevant housing target was delivered in the past three years to 2017/18 - totalling
474 dwellings in total), resulting in the Borough needing to add a further 20%
buffer to its housing land supply.
19. LLLP conclude that the Borough's lack of five year housing land supply represents
a failure to meet the requirements of the NPPF at paragraph 67. The persistent
lack of delivery arises from an inability to bring forward sufficient sites and land in
the immediate period and is due to the Council's failure to identify and allocate
housing sites capable of development in the short term.
20. LLLP's land interest at Honeypot Lane in Brentwood is a sustainable development
location (as earlier versions of the Local Plan identified in allocating the site and as
the Sustainability Appraisal continues to demonstrate) and is capable of making an
immediate contribution to the five year housing land supply. This would represent
a significant positive benefit for the Borough in the context of persistent failures to
deliver sufficient housing or to provide a mix and choice of sites.
Stepped Housing Delivery Trajectory
21. Policy SP02 proposes a stepped housing trajectory with an annual average rate of
delivery of 310 dpa for the period 2016/17 - 2022/23 rising to 584 dpa from
2023/24 to 2033.
22. Paragraphs 4.19 et seq. set out the Council's rationale for a stepped trajectory,
noting that Green Belt covers a large proportion of the Borough making it difficult
to achieve a five year land supply. The issue of land constraint has however been
well understood in Brentwood Borough for many years and the failure to put a new
Local Plan in place with adequate allocations of housing land in sustainable
locations has compounded the acute problems that now result in terms of the lack
of a five year housing land supply. Put simply, too little has been done to
positively address the issue.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
5
23. The Plan's proposed spatial strategy and distribution of growth (which favours
substantial housing delivery in the form of a long-term new settlement at Dunton
Hills Garden Village (DHGV) representing 35% of all the proposed future housing
supply according to Figure 4.2) will not remedy the persistent lack of immediate
and short term housing land supply.
24. There is an inherent risk to longer term delivery and supply of housing as new
settlements and large scale extensions necessarily take many years to be
effectively planned, consented and then to deliver the expected housing. With
such a strategy immediate housing supply shortfalls are not effectively resolved
and the lack of housing supply is compounded in the remainder of the plan period.
25. The NPPF is clear that local authorities should significantly boost the supply of
housing. Brentwood Borough is an area with a persistent record of under-delivery
and housing shortfall. The stepped trajectory represents a failure to plan positively
over many years. It artificially restricts the supply of housing land and continues to
risk a mismatch with meeting housing needs and the wider principles of
sustainable development as well as the Local Plan's own stated strategic driving
forces. It undermines the national policy of significantly boosting the housing
supply.
26. The housing delivery trajectory should take a far more positive and proactive
approach to meeting, in full, the housing needs arising, including the extant
backlog caused by the lack of a five year land supply.
27. The barrier to delivery of sufficient sites in the first five year period is caused by the
lack of an appropriate mix and range of housing allocations in sustainable
locations (including LLLP's land interest at Honeypot Lane, Brentwood) and the
Council's spatial strategy that pursues housing development through Green Belt
release to create a standalone new settlement that will inevitably take far longer to
come forward and be in a position to contribute to the Borough's housing land
supply.
28. The stepped trajectory is not effective in meeting housing needs, is not positive or
sufficiently proactive and essentially pushes back the delivery of adequate levels
of new housing with no guarantee that an increased level of completions will be
secured in the longer term.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
6
The Sequential Approach to Housing Location
29. The distribution of future housing growth is apportioned through a sequential land
use test according to paragraph 4.22. The test priorities growth based on
brownfield and land in urban areas first, followed by brownfield land in the Green
belt.
30. Figure 4.2 sets out the results of the sequential approach to allocating housing
land which indicates inter alia: that 15% of housing is to be allocated on brownfield
land within the Brentwood urban area; 7% on brownfield land elsewhere; and
some 16% of Green Belt land at the edge of Brentwood urban area. 35% (2,700
dwellings) are proposed to be allocated to Dunton Hills Garden Village.
31. LLLP have two principal concerns with the distribution of housing land resulting
from the use of the sequential approach:
* the approach under-values the importance of existing settlements, such as
Brentwood, to provide sustainable locations for future housing growth,
including use of greenfield and Green Belt land within and adjacent to the
urban area. Such locations, including LLLP's land interest at Honeypot Lane
in Brentwood, represent sustainable development locations capable of
comprehensive integration with the existing urban fabric; swift delivery to meet
evident housing needs; and contribution towards community facilities and
services as appropriate. It is evident (as the Sustainability Appraisal identifies
reasonable alternative sites, including Honeypot Lane, Brentwood) that there
is a greater opportunity for development in and adjacent to Brentwood than
the Plan currently makes allowance for.
* having failed to maximise the opportunities for existing higher order existing
settlements like Brentwood (as set out above) the sequential approach then
directs much of the Borough's new residential development to DHGV an
undeveloped, greenfield/Green Belt location that is unconnected to the
existing settlement pattern or transport infrastructure and which would involve
very extensive loss of Green Belt land. The proposed strategic allocation at
DHGV does not align with the sequential approach given the Plan's failure to
maximise development opportunities in or at the edge of existing settlements
first and foremost. In addition, LLLP are concerned that development of
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
7
DHGV will have significant adverse effects including, inter alia, landscape
character and visual impact, flood risk, highways capacity/connectivity and
ecology and that these effects are, at this stage, largely untested or evaluated
in any detail.
Conclusions
32. LLLP conclude that:
* the Local Plan's stated housing need figure does not represent the appropriate
starting point for establishing the Local Housing Need in accordance with the
Standard Method and the NPPG; and is an under-estimate of the housing
required in the Borough;
* the housing requirement should be increased to at least 9,214 dwellings in the
period 2016 - 2033;
* there is a persistent lack of a five year housing land supply contrary to the
NPPF and that the lack of delivery of housing arises from the lack of sufficient
sites and land available now and in the short term;
* the proposed stepped housing delivery trajectory proposed in Policy SP02 at
point A is not consistent with the NPPF; is not justified in terms of meeting an
acute and evident shortfall in housing land supply; and does not represent an
effective or positive strategy;
* the spatial distribution strategy, including a significant reliance upon DHGV to
bring forward 35% of all the future housing will not address the acute shortfall
and lack of five year housing land supply. The barrier to delivery of sufficient
sites in the first five year period is caused by the lack of an appropriate mix
and range of housing allocations in sustainable locations (including LLLP's
land interest at Honeypot Lane, Brentwood).
33. As concluded from the matters set out above, LLLP object to Policy SP02. The
policy is not sound as it is not justified, effective, positively prepared or consistent
with national policies.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
8
Modifications Required
34. LLLP consider that the Plan requires modification to Policy SP02 to:
* increase the overall housing requirement in order to meet the current Local
Housing Need with a suitable, additional 20% supply buffer;
* extend and increase the housing requirement set out to ensure that there is a
minimum 15 year lifespan for the Plan at the point of adoption;
* remove or significantly modify through the allocation of additional sustainably
located sites the proposed stepped housing delivery trajectory from the policy
so that there is a significant increase in delivery in the early part of the Plan
period; and
* redress the imbalance in housing distribution that over-emphasises the DHGV
site and fails to align with the Plan's stated sequential land use test.

. LLLP conclude that amendment of the Vision Statement is required to ensure it
properly reflects the three overarching national planning policy objectives for
sustainable development and in particular makes an explicit reference to meeting in
full the Borough's housing needs

Representations for and on LaSalle Land Limited Partnership
Vision and Spatial Strategy Driving Factors
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with the Plan's Vision and Spatial Strategy Driving
Factors set out in Section 3.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Vision Statement
4. The Plan's Vision statement set out at page 35 is not clear. It refers to a:
"landscape-led development, where new development responds to a 'design and
build with nature' approach...".
5. LLLP does not consider that the Vision represents an effective statement. It is not
clear what is meant by "landscape-led" and "design and build with nature" or how
this is then translated into the proposed allocation of significant housing land in the
Dunton Hills Garden Village, which would involve a very significant intrusion into the
existing countryside landscape and impacts on biodiversity and ecological systems.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
6. It is also unclear from the Vision Statement and supporting text how a landscapeled
approach accords with the definition of sustainable development established in
the NPPF at paragraph 8 which identifies three overarching and inter-dependent
objectives: (a) economic; (b) social; (c) and environmental.
7. It is considered that a "landscape-led" and "design with nature" approach may help
meet (c) the environmental objective of the NPPF but over-emphasises this to the
detriment of meeting objectives (a) and (b) of paragraph 8 which are equally
important.
8. The Vision statement fails to set out the need to meet housing growth requirements
which are described at paragraph 3.1 (c) (within the section Spatial Strategy Driving
Factors), to include meeting the Borough's housing needs.
Conclusions
9. LLLP object to the plan's Vision Statement. The Vision is not sound as it is not:
* Consistent with National Policy - for the reasons identified in this
representation, LLLP does not consider that the Vision statement is
consistent with the NPPF definition of sustainable development which
underpins the approach to plan-making.
Modifications Sought
10. LLLP conclude that amendment of the Vision Statement is required to ensure it
properly reflects the three overarching national planning policy objectives for
sustainable development and in particular makes an explicit reference to meeting in
full the Borough's housing needs

LLLP conclude that Point A of Policy NE13 should be deleted. Paragraph 8.114 should also be deleted or re-drafted to be explicit and entirely clear that the community benefits sought from meeting housing needs on sites released from the Green Belt will only be secured in accordance with the relevant statutory tests and national planning policies.

Representations for and on LaSalle Land Limited Partnership
Policy NE13: Site Allocations in the Green Belt
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Policy NE13: Site Allocations in the Green
Belt.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. Policy NE13 requires, at Point A, that sites allocated to meet housing needs in the
Green Belt will be:
"expected to provide significant community benefits, both for surrounding
existing communities and those moving into new homes on site".
5. LLLP object to NE13 Point A as the policy appears to be entirely aspirational and
unjustified. The benefit of releasing Green Belt land for new housing is to ensure
that the Borough effectively meets its identified Local Housing Need and maintains
a continuous supply of housing land and sites in order to do so.
6. The National Planning Policy Framework identifies the delivery of new housing as
contributing to achieving sustainable development at paragraph 8 (as both an
economic and social objective) and recognises the importance of significantly
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
boosting the supply of housing at paragraph 59. These national objectives are for
the public benefit and represent positive contributions arising.
7. Financial, land or other contributions to new or expanded community, transport or
environmental infrastructure must be made in accordance with the relevant statutory
tests including the Community Infrastructure Levy Regulations, 2010 (as amended).
8. The NPPF is clear at paragraph 55 that planning conditions should be kept to a
minimum and only imposed where they are necessary, relevant to planning and to
the development permitted, enforceable, precise and reasonable in all other
respects.
9. NPPF paragraph 56 confirms that planning obligations must only be sought where
they meet the relevant statutory tests.
10. Paragraph 57 of the NPPF requires that up-to-date policies should set out the
contributions expected of development.
11. In LLLP's view there is nothing set out in planning statute or in the NPPF that
supports the approach described in Policy NE13 (Point A) or at the reasoned
justification in paragraph 8.114, seeking benefits that are in some way additional to
or in excess of those that are wholly necessary, directly related to the development
and fairly and reasonably related in scale and kind.
Conclusions
12. LLLP object to Policy NE13 at Point A. The policy is not sound as it is not justified
in generally seeking "significant community benefits"; is not effective in terms of
specifying what the benefits sought would be or why they comply with the relevant
statutory and national policies; and the policy is not consistent with the NPPF
including at paragraphs 55 - 57.
Modifications Required
13. LLLP conclude that Point A of Policy NE13 should be deleted. Paragraph 8.114
should also be deleted or re-drafted to be explicit and entirely clear that the
community benefits sought from meeting housing needs on sites released from the
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
Green Belt will only be secured in accordance with the relevant statutory tests and
national planning policies.

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

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

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

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

The plan period for the BBLP should be modified to ensure that there is a minimum 15 year period from the date of adoption.

Representations for and on LaSalle Land Limited Partnership
Section 1, Paragraph 1.1 - Plan Period
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Section 1, paragraph 1.1 of the Pre-
Submission Plan.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. At Section 1 in paragraph 1.1 the BBLP establishes that the plan period is from
2016 to 2033 and indicates that the plan sets out how the Borough will develop
over the next 17 years.
5. Paragraph 22 of the National Planning Policy Framework (NPPF) (February 2019)
states that:
"Strategic policies should look ahead over a minimum 15 year period from
adoption, to anticipate and respond to long-term requirements and opportunities,
such as those arising from major improvements in infrastructure". [Our emphasis].
6. The BBLP will not have a minimum 15 year plan period at adoption which is
anticipated to be 2020 at the earliest. As currently drafted the plan period would
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
be 13/14 years which is not sufficient to respond to the long term structural
development and growth of the Borough.
7. As drafted the BBLP is therefore not sound as it is not consistent with national
policy.
Modifications Sought
8. The plan period for the BBLP should be modified to ensure that there is a
minimum 15 year period from the date of adoption.

The deliverability and viability of Policy BE03 at Point (a) is uncertain. Additional testing and evidence is required in order to support and justify this policy measure and to show that the policy would be effective if implemented. This is particularly important if the Building Regulations baseline is increased in future (if the national near zero carbon policy is not finally adopted) as the final limb of Point B(a) states.

Representations for and on LaSalle Land Limited Partnership
Policy BE03: Carbon Reduction, Renewable Energy and Water Efficiency
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Policy BE03: Carbon Reduction, Renewable
Energy and Water Efficiency.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. LLLP understand the UK's commitment to dealing with climate change and
adaptation and support the need to encourage the use of renewable energy and low
carbon developments. There is however a need to ensure that the policy standards
that are proposed are capable of being delivered viably for individual schemes.
5. As drafted Policy BE03 B(a) requires minimum sustainable construction standards
in line with Part L of the Building Regulations both in the period pre and post 2020.
For on-site carbon reduction, the policy also requires, in the period before 2020, at
least 10% reduction in CO2 emissions above Part L, rising to "nearly zero carbon" in
the period from 2020 onwards.
6. LLLP notes that the long term trajectory set out in the Climate Change Act (2008)
and the European Union Energy Performance of Buildings Directive (2012/31/EU)
requires all new buildings to be nearly zero-energy by 2020. It is also noted that the
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
Government's zero-carbon homes policy was withdrawn in 2015 and that the
foundation for this in the UK's Increasing the Number of Zero Energy Buildings:
National Plan (2012) will need revision in light of the removal of the zero-carbon
homes policy.
7. The national zero-carbon housing policy has therefore been abandoned and LLLP
note that the Government's proposed 'Future Homes Standard' announced by the
Chancellor of the Exchequer in his HM Treasury Spring Statement 2019: Written
Ministerial Statement (13th March 2019) identifies that the new standard will be
introduced by 2025, seeking from then to future-proof new build homes with low
carbon heating and leading levels of energy efficiency.
8. LLLP is therefore concerned that Policy BE03 B(a) requirements for on-site carbon
reduction are:
* lacking in clear local evidence of the need to raise on-site carbon reductions
for new developments, relying on national level information;
* out of step with the Government's current position on future homes
standards and zero carbon housing policy;
* likely to be outdated as, at the time of the Local Plan's adoption, all
development proposals and applications would need to conform with the
post 2020 on-site carbon reduction requirements; and
* overly onerous, placing an additional financial cost burden on new residential
development schemes with the potential for adverse effects on scheme
viability.
9. With regard to the financial development cost burden, LLLP are particularly
concerned that the Local Plan's Viability Assessment (October 2018) has not fully
modelled the cost implications of implementing Policy BE03. The Viability
Assessment identifies at paragraph 7.8 that:
"The base assumption in this report is that homes are built to the basic Building
Regulation Part L 2010 Standards but not to higher environmental standards.
This is in line with the Government announcement, made at the time of the
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
Summer 2015 Budget in the Fixing the foundations productivity report, of its
intention not to proceed with the zero carbon buildings policy". [Our emphasis].
10. At paragraph 7.9 it continues:
"As a result, there was no uplift to Part L of the Building Regulations during
2016, and both the 2016 zero carbon homes target and the 2019 target for nondomestic
zero carbon buildings will be dropped, including the Allowable
Solutions programme".
11. The Viability Assessment concludes in paragraph 7.12 that the costs of building to
an "enhanced building standard" are included in the median BCIS costs advice that
forms the basis of the viability assessment.
12. LLLP does not consider that the "enhanced building standard", included within
median BCIS figures used in the Local Plan Viability Assessment, encompasses the
additional construction costs of developing near zero carbon residential dwellings.
13. It is therefore concluded that the deliverability and viability of Policy BE03 at Point
B(a) is uncertain. Additional testing and evidence is required in order to support and
justify this policy measure and to show that the policy would be effective if
implemented. This is particularly important if the Building Regulations baseline is
increased in future (if the national near zero carbon policy is not finally adopted) as
the final limb of Point B(a) states.
Conclusions
14. LLLP object to Policy BE03, particularly Point B(a). The requirements of Point B(a)
are onerous and the effects/implications of this part of the policy are uncertain.
15. The policy is unsound as it is not justified or effective in relation to understanding
the viability implications of the near zero on-site carbon requirements for residential
dwellings constructed post 2020.

Policy R01 (1) should be amended to reduce the overall amount of housing to be delivered at DHGV in the plan period. This needs to be more realistic with commencements of completions no earlier than 2025/2026, with a total delivery of 1950 in this period.
The Housing Trajectory at Appendix 1 also therefore requires modification for DHGV to remove the completion of dwellings in the period 2022/23 - 2025/26 which are considered to be unrealistic given the time necessary to resolve planning, land control and funding matters fully. The overall quantum should be reduced accordingly rather than further backloaded in the DHGV trajectory.
Other reasonable alternative sites (as identified in the Sustainability Appraisal), including LLLP's land interest at Honeypot Lane, Brentwood should be included within the Local Plan allocations to assist in meeting the housing requirements and acute shortage in the early part of the Plan period given the changes needed in total delivery and phasing trajectory for DHGV. Additional technical evidence, testing and evaluation of the DHGV proposals in terms of transport, community and green infrastructure requirements costs and funding, is required to support the Local Plan's proposed allocation of the site and to ensure that this is proposed on a comprehensive and realistic basis. Policy R01 (I) should be modified accordingly.

Policy R01 (I): Dunton Hills Garden Village Strategic Allocation and Appendix
1: Local Plan Housing Trajectory
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Policy R01 (I) Dunton Hills Garden Village
Strategic Allocation and also Appendix 1 Local Development Plan Housing
Trajectory.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
Housing Delivery and Trajectory
4. Point B of Policy R01 (I) establishes that the Dunton Hills Garden Village (DHGV)
will provide 2,700 new homes in the plan period (some 35% of the total planned
housing provision) and an indicative overall capacity of some 4,000 homes in total
(the remainder beyond the current plan period).
5. Point D(a) of the same policy then states that delivery will be "at least" 2,700
dwellings in the plan period.
6. Appendix 1 of the Plan sets out the Local Plan housing trajectory which identifies a
total of 2,700 dwellings to be developed at DHGV in the plan period. The Housing
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
Trajectory proposes that 100 dwellings will be completed in 2022/23 with
development delivery rates ramping up significantly to 150, 250 and then 300
dwellings per annum (dpa) during the period from 2023/24 - 2032/33.
7. Paragraph 9.23 (iii) in establishing development principles, sets out that the
development of DHGV should be flexible to accommodate the likely progression
over a 20 year build-out period.
8. DHGV is a Green Belt, greenfield location. Any development therefore requires an
adopted Development Plan that includes release of the whole site area from Green
Belt as well as all of the necessary land control, funding and planning permissions
(outline and then reserved matters) together with requisite secured planning
obligations and contributions in order to proceed.
9. The development proposed and the community that would be created depends
entirely on new social, community and green infrastructure to be created.
Substantial new and enhanced highways and public transport infrastructure is
required given the chosen location for the Garden Village. There is evidently a
major programme of new infrastructure development necessary to ensure that the
resulting new settlement is in any way sustainable.
10. It is clear to LLLP that the planning and development of DHGV is a long-term
project and not a scheme that can be swiftly mobilised and construction completed
in the short term as the Council's assumptions concerning the delivery trajectory
propose.
11. In this context, LLLP raise significant concerns over the quantum of housing that is
intended to be provided within the plan period and the phasing of such delivery.
The total quantum of residential development proposed does not appear to be
realistic in the plan period with very substantial development rates identified each
year up to 2033.
12. The Housing Trajectory in Appendix 1 signals that there will be 100 residential
completions in 2022/23. To achieve this, the Local Plan will need to be adopted in
order to release the site from Green Belt, the DHGV masterplanning and
infrastructure testing and validation work completed and all necessary outline and
reserved matters permissions secured. Pre-commencement conditions will also
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
need to have been discharged, CIL payments made and relevant planning
obligations completed and implemented, including the negotiation and signing of a
S.106 Agreement.
13. Put simply, LLLP do not believe that there is a realistic prospect of any residential
dwellings being completed by 2022/23 and indeed would not anticipate that DHGV
will be sufficiently advanced to deliver housing in the following years until at least
2025/26.
14. There is therefore no likely or realistic contribution arising from new dwellings at
DHGV towards meeting the Borough's persistent and acute housing needs or in
remedying the lack of a five year housing land supply.
15. LLLP has, in previous representations on the emerging Local Plan, raised the
importance of ensuring that the Local Plan offers a choice and mix of housing sites
to enable delivery in the immediate and shorter term and reduce the risk of nonimplementation
of individual residential schemes while plans and work continues
to secure necessary consents for DHGV.
16. The removal of sites, such as LLLP's land interest at Honeypot Lane, Brentwood,
in favour of a greater quantum of housing growth at DHGV during the plan period
does not help achieve the choice and mix of housing sites necessary. In fact it
positively discriminates against such an outcome.
17. LLLP therefore object to the total proposed quantum and the identified phasing of
new residential development at DHGV as set out in Policy R01 (I) and at Appendix
1.
Infrastructure Dependency and Viability
18. DHGV is predicated on a substantial level of new transport, community, social and
green infrastructure. This is largely necessary because of the site's greenfield
location which is well away from existing settlements and facilities in Brentwood
Borough or in Basildon or Thurrock (with which the proposed site borders).
19. The full costs and infrastructure requirements are not specified in detail in the
Local Plan, but policy R01 (I) and R0 (II) set out a series of proposed development
and design aspirations, objectives and needs. The evidential basis confirming the
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
4
scale, extent and need for many of these requirements is not convincing (see
LLLP's separate representation concerning R01 (II)).
20. Furthermore, LLLP are concerned about the deliverability and viability of DHGV
with the potential infrastructure necessary to make the scheme sustainable.
21. The Local Plan Viability Assessment (October 2018) identifies an infrastructure
contribution cost of some £126m based on modelling of 3,500 dwellings rather
than the 2,700 dwellings proposed in the current Plan, but this assumes no
contribution arising/required from the Borough's Infrastructure Delivery Plan (IDP)
and the viability work was clearly undertaken prior to the Pre-Submission Plan's
specific policy requirements for DHGV. Indeed, the Viability Assessment notes
that further work is likely to be needed as the site specific costs and requirements
for DHGV are derived.
22. As LLLP's separate representation to policy R01 (II) concludes there needs to be
an updated, comprehensive viability analysis of the DHGV proposals including all
costs, site specific infrastructure requirements, CIL, S.106 obligations and
modelling of the effects of all of the proposed design and land use requirements
set out in the Local Plan, including those stated in Policy R01 (I) and R01 (II).
Sustainability
23. The location chosen to site the new settlement comprises greenfield, Green Belt
land that is unconnected to the existing pattern of settlements. It is, at its northern
boundary, adjacent to the A127 strategic road and to the south, adjacent to the
main Basildon rail line, but is not easily connected to either. It is some 1.6+ km
distant from West Horndon railway station and also separated from the centre of
Laindon in the west of Basildon Borough by existing countryside and agricultural
land including Dunton Hall and various farm buildings.
24. LLLP noted that there are no proposals in the emerging Basildon Borough Local
Plan: Revised Publication (October 2018) that includes any development or
proposed vehicular or public transport connection between the eastern edge of
DHGV and the Southfields and Laindon area in the west of Basildon Borough.
The DHGV site's location is therefore clearly unrelated to the existing and
proposed settlement pattern.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
5
25. The Local Plan Sustainability Appraisal (SA) has had to make a number of 'heroic'
assumptions in order to attempt to demonstrate that the DHGV proposals
represent the most appropriate reasonable development alternative.
26. It is suggested in the SA that the opportunity to achieve higher levels of
sustainability at DHGV are greater for a new greenfield settlement than
development in/adjacent to existing settlements because of the 'clean sheet' such
a site would afford.
27. In taking this approach the SA fails to properly consider that the existing settlement
hierarchy represents a sustainable pattern of land uses and activities with
appropriate infrastructure available now and with significant enhancements
capable of being made or indeed already committed during the lifetime of the Local
Plan (for example the opening of the new Queen Elizabeth Line connecting
Brentwood and Shenfield more closely with London and other centres).
28. LLLP concludes that DHGV only performs at a similar level to alternative
development locations in Brentwood, Shenfield or Ingatestone because of a heavy
reliance and emphasis in the SA appraisal on possible positive effects from
implementing aspirational design, environmental and transport ideas/measures
that are not yet adopted plan policies or from uncosted and untested new
infrastructure that seeks low carbon, high design quality, sustainable transport and
other measures.
29. There is no clear reason however why other development locations and sites in
and adjacent to Brentwood, Shenfield or Ingatestone cannot be as sustainable, or
indeed more so, than construction of a new settlement at a greenfield location in
the countryside where all infrastructure will have to be provided from scratch.
30. The SA is flawed in its analysis of the future sustainability performance of DHGV in
comparison with reasonable alternatives (section 9 of the Sustainability Appraisal),
including greater growth at Brentwood and other existing settlements. The SA
skews its assessment based on aspirational design ideas and measures for DHGV
that are not properly or fully evidenced and appears predicated towards
demonstrating that DHGV is a better option than a more balanced distribution of
growth at Brentwood and other settlements.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
6
Conclusions
31. LLLP object to Policy R01 (I) and to the Housing Trajectory set out in Appendix 1
of the Plan. The policy and the Appendix are not sound as they are not:
* Justified - the total quantum of housing propose for DHGV and the delivery
trajectory proposed are not realistic or justified by sufficient evidence to
demonstrate that such housing will be delivered in the plan period.
The Plan's SA does not adequately justify the allocation and development
of DHGV and is reliant upon untested or costed new infrastructure and
upon design principles and other measures that are aspirational but not
sufficiently tested to show that they are realistic and can be viably delivered
during the plan period.
* Effective - the emphasis in Policy R01 (II) and the Appendix 1 housing
trajectory on DHGV to provide 35% of the total planned housing delivery in
the plan period represents an over-reliance on this long term development
project. The Plan is at serious risk in failing to deliver sufficient housing
because of the reliance on the new settlement proposal. This is not an
effective policy or spatial strategy as it fails to ensure that there is a
sufficient choice and mix of housing land sites to meet acute short term
housing needs or redress the persistent shortfall in housing delivery.
The proposals for DHGV are not sufficiently developed to offer adequate
certainty that the new settlement is sustainable, deliverable or viable.
Proposals in Policy R01 (I) and R01 (II) are in many cases aspirational
ideas or measures and require a substantial level of additional evidential
work and testing to prove that they are deliverable in the context of NPPF
paragraph 16.
Modifications Required
32. Policy R01 (I) should be modified to reduce the overall quantum of housing to be
delivered at DHGV in the plan period. The overall reduction in quantum need to
reflect a more realistic development trajectory with commencement of completions
not earlier than 2025/26. A total delivery figure of some 1,950 dwellings for DHGV
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
7
in the later part of the plan period is a more realistic target (removing the 750
dwellings proposed to be completed in the period 2022/23 - 2025/26 as set out in
Appendix 1).
33. The Housing Trajectory at Appendix 1 also therefore requires modification for
DHGV to remove the completion of dwellings in the period 2022/23 - 2025/26
which are considered to be unrealistic given the time necessary to resolve
planning, land control and funding matters fully. The overall quantum should be
reduced accordingly rather than further backloaded in the DHGV trajectory.
34. Other reasonable alternative sites (as identified in the Sustainability Appraisal),
including LLLP's land interest at Honeypot Lane, Brentwood should be included
within the Local Plan allocations to assist in meeting the housing requirements and
acute shortage in the early part of the Plan period given the changes needed in
total delivery and phasing trajectory for DHGV.
35. Additional technical evidence, testing and evaluation of the DHGV proposals in
terms of transport, community and green infrastructure requirements costs and
funding, is required to support the Local Plan's proposed allocation of the site and
to ensure that this is proposed on a comprehensive and realistic basis. Policy R01
(I) should be modified accordingly.

There needs to be prepared an updated, comprehensive viability analysis
of the DHGV proposals including all costs, site specific infrastructure requirements,
CIL and modelling of the effects of all of the proposed design and land use
requirements set out in the Local Plan, including those stated in Policy R01 (I) and
R01 (II), policy needs redrafting in light of evidence.

Representations for and on LaSalle Land Limited Partnership
Policy R01 (II): Spatial Design of Dunton Hills Garden Village
March 2019
Introduction
1. Chilmark Consulting Ltd. (CCL) are instructed by and write for and on behalf of
LaSalle Land Limited Partnership (LLLP) with respect to the Brentwood Borough
Local Plan: Pre-Submission Plan (BBLP) published for consultation by Brentwood
Borough Council (BBC) in January 2019.
2. This representation is concerned with Policy R01 (II): Spatial Design of Dunton Hills
Garden Village.
3. This representation must be read in conjunction with the other representations
submitted by LLLP dealing with related matters.
Nature of Representation
4. Policy R01 (II) is concerned with establishing design principles and requirements for
the proposed Dunton Hills Garden Village (DHGV).
Overall Consideration
5. Much of Policy R01 (II) appears, in LLLP's view, to be aspirational rather than well
founded policy direction based on clear testing and evidence of the needs and
impacts arising from the proposed development of DHGV.
6. It is appreciated that DHGV represents a major new settlement for the Borough,
however the scale and nature of the proposed scheme, even in outline, means that
there needs to be a greater level of precision and evidence set out to support the
design principles, land use mix and proposed infrastructure contained in draft policy
R01 (II).
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
2
Green Infrastructure Buffer/Wedge
7. Policy R01 (II) includes a requirement at Point C (f) for the creation of a:
"green infrastructure buffer/wedge on the eastern boundary with Basildon
Borough to achieve visual separation to help significantly improve the
landscape and habitat value thus reinforcing the beneficial purpose and use
of the Green Belt in that zone".
8. The purpose of the proposed green infrastructure buffer/wedge is unclear and the
justification for such infrastructure is not established in the Plan. LLLP are unclear
what the reinforcement of the "beneficial purpose and use of the Green Belt in that
zone" means or is intended.
9. In LLLP's view, it appears to be simply an attempt to maintain some separation of
DHGV from Laindon in Basildon Borough and thereby avoid, unsuccessfully, the
perceptual and physical coalescence of DHGV with an existing settlement contrary
to the purposes of the Green Belt.
10. The development of DHGV would include a very significant and adverse impact on
the existing landscape character and visual amenity of the area (including land
within Basildon Borough to the east and Thurrock to the south) due to the scales
and nature of the development proposed.
11. No evidence is presented in the draft Local Plan offering a comprehensive
understanding, evaluation or testing of the landscape or visual effects of the
development of DHGV.
12. The presence of a green wedge/buffer to the eastern boundary appears to be more
to screen and separate the proposed new settlement development from Basildon
Borough than as an integral component in a wider landscape strategy. Such a buffer
would not, of itself, serve to mitigate the potential landscape and visual harm arising
from such a substantial scale of new development in the countryside and on land in
the Green Belt.
13. The green infrastructure buffer/wedge therefore appears to be an unjustified
aspirational measure rather than a well-founded, evidenced requirement.
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
3
14. LLLP is concerned that the proposed development of DHGV will give rise to very
substantial changes to landscape character and visual amenity and that the Plan
has not offered sufficient analysis or substantive evidence to justify why this is
appropriate or whether it is the most suitable choice to support the Borough's future
housing growth requirements.
Transport Impact Mitigations
15. Policy R01 (II) sets out at Point H that development of DHGV will be required to
mitigate any predicted transport impacts and that these should be monitored and reevaluated
throughout the lifespan of the build out.
16. The policy proposes various transport mitigations, which includes, new junctions to
access the site H(a); at H(b) the creation of a dedicated bus route connecting the
development with West Horndon Station, nearby employment locations and other
key social infrastructure; contributions to school bus services (H(c)); improvements
to West Horndon Station (H(d)) and plans for key connections to surrounding green
infrastructure destinations (H(e)).
17. LLLP are concerned that the transport impacts and proposed mitigations set out in
the policy, including the proposed dedicated bus route have not been effectively
tested and their delivery is uncertain.
18. The policy is not sufficiently clear as to whether a dedicated bus route would be
needed, although the lack of an on-site rail station or public transport hub is obvious
and the relatively remote and poorly connected location, some 1.6+ km distance
from DHGV to West Horndon Station (as the published West Horndon Interchange
& Southern Development Sites Plan (June 2018) shows) is a distinct limitation and
disincentive to the use of public transport.
19. Indeed, the need to contrive new dedicated bus and cycle links to West Horndon
Station indicates how poorly situated and remote the DHGV proposal is in relation
to existing settlements, employment centres and services/facilities.
20. Furthermore, LLLP are concerned that the costs of such transport infrastructure
development have not been properly identified and that there is no certainty of
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
4
securing the requisite land necessary to create a dedicated bus and cycle route from
DHGV to West Horndon.
21. As set out in policy R01 (II) the transport impact mitigation requirements are not, in
LLLP's view, sufficiently substantiated and do not appear to form part of a coherent,
tested transport strategy (including all of the necessary highways capacity and
impact modelling) in order to demonstrate that the DHGV will not have unreasonable
impacts in transport and highways terms.
Viability of Design Principles
22. There does not appear to be current viability assessment evidence available that
shows that DHGV will be a viable development incorporating all of the requirements
set out in Policy R01 (II) and including the requirements of the Council's published
Infrastructure Delivery Plan (IDP).
23. It is noted that a headline viability assessment of DHGV was undertaken as part of
the Local Plan Viability Assessment (October 2018) but this identifies that the IDP
was assumed to have a zero cost (paragraph 12.51) and the scheme size modelled
for DHGV was 3,500 dwellings rather larger than the 2,700 dwellings now proposed
in the Local Plan.
24. Indeed, the Local Plan Viability Assessment confirms at paragraph 12.75 that it is:
"premature to provide definitive advice as to the deliverability of the strategic
sites" (which include DHGV).
25. It continues, noting that:
"when the Council has completed the work assessing the strategic
infrastructure and mitigation requirements, it may be necessary to revisit the
analysis".
26. Put simply, there needs to be prepared an updated, comprehensive viability analysis
of the DHGV proposals including all costs, site specific infrastructure requirements,
CIL and modelling of the effects of all of the proposed design and land use
requirements set out in the Local Plan, including those stated in Policy R01 (I) and
R01 (II).
Brentwood Borough Local Plan: Pre-Submission, January 2019
Representation for and on behalf of LaSalle Land Limited Partnership
5
27. LLLP reserve the right to make further submissions with respect to viability of the
development and its design principles in due course.
Conclusions
28. LLLP object to policy R01 (II) for the reasons set out above. The design
requirements appear to be a mixture of aspiration and emerging ideas rather than a
set of tested, evidenced measures and policies to firmly guide the proposed Garden
Village. The result is a collection of thoughts and expectations for DHGV and LLLP
are concerned that the design proposals are not realistic and it cannot be
demonstrated that they are deliverable.
29. The policy as drafted is unsound as it is not:
* Justified - in terms of representing the most appropriate strategy and
underlying rationale for the design principles and development requirements
set out;
* Effective - in terms of clearly demonstrating that the design principles and
requirements for DHGV are needed, deliverable and viable.