brentwood.gov.uk

I am opposed to the inclusion of sites 044 and 178 as sites considered suitable for development in the Draft Local Plan for the following reasons:
1. The Local Plan has failed to support the selection of sites for potential development with a clear evidence base, most notably when it comes to highways. The absence of an evidence base means that development policies, which would frame the selection of sites, are vague and unsubstantiated. The inclusion or exclusion of sites, and the nature and amount of development on them, lacks transparency and appears random and inconsistent.
2. The cumulative effect of development is not considered in the Draft Local Plan, and no solutions are proposed to the impact on congestion which proposed development will undoubtedly cause within the borough. Congestion is already a serious issue for the roads leading to and from Brentwood town centre, and additional traffic levels will make moving around the town at peak times (rush hours and school runs) unsustainable.
3. Priests Lane is already used as a cut-through between Brentwood and Shenfield due to the congestion along the Shenfield Road. Long traffic queues form at peak times and these often back up to Bishop Walk, one of the proposed access points for sites 044 and 178. Increased traffic will not only cause even longer delays, but will worsen air quality and could cause safety issues for the many parents and schoolchildren who walk along Priests Lane to get to the several schools nearby.
4. One of the main criteria for including a site within a Draft Local Plan is deliverability, and a site cannot be considered deliverable unless there is a clear means of access. There is no such access to sites 044 and 178. Proposals have been suggested including St Andrews Place, Bishop Walk and the strip of land adjacent to No 61 Priests Lane. For various reasons, none of these proposed points of access is suitable (there are ownership issues with St Andrews Place and Bishop Walk, Bishop Walk is not wide enough to accommodate the additional volume of traffic and the land adjacent to 61 Priests Lane is also not wide enough and is located too close to the junction of Priests Lane and Glanthams Road and so is dangerous). Without a clear means of access sites 044 and 178 should not be considered deliverable and should not be included in the Draft Local Plan.
5. The land comprising sites 044 and 178 is designated as a Protected Open Urban Space. No justification has been given for removing this designation, therefore in the absence of development policies to the contrary the land should continue to be protected and so cannot be included as a development site in the Draft Local Plan.
6. Previous Open Space audits have identified a lack of open space in West Shenfield and this land has previously been identified as having value to the community as open space, despite it being in privately owned. Previous Council reports have recommended acquiring land in this area if it becomes available to address this lack. Both Sport England and the Essex Playing Fields Association objected to the development, concluding that this would contravene Paragraph 79 of the National Planning Policy Framework.

In conclusion, the lack of a clear means of access and the designation as a Protected Open Urban Space means that in policy terms sites 044 and 178 off Priests Lane cannot be included as development sites within the Draft Local Plan.
Development of these sites would also cause unacceptable congestion in the area and will lead to issues of road safety, particularly for pedestrians, and air quality from queuing traffic.
A more comprehensive discussion of the reasons why these sites are not eligible or suitable for development has been submitted by the Priests Lane Neighbourhood Residents Association.