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Specific objection is made against the inclusion of sites 44 and 178 (Priests Lane sites) for the following reasons: Draft Plan Page 3 Para.5, Page 4 Para.7, Page 4 Para. 8, Page 4/5 Para.9 Reference is made to historic consultations and the comments made therein. The representations made during the 2016 consultation period were summarised by the Council into one document with the actual comments made curtailed to such an extent that rendered them nonsensical. There have been many submissions to the Council of a technical nature expressing a number of concerns over the development of the Priests Lane sites, robustly backed up by technical argument. Despite the draft plan indicating that evidence has been reviewed there is no real indication that these technical representations have even been acknowledged let alone given real consideration. While the Priests Lane sites, which are protected urban spaces, received one of the highest number of objections, this is not mentioned within the draft plan even though other sites, which received less representations, are. It is hard to see how much notice, if any, has been taken of the very valid reasons against development of these sites. Draft Plan Page 6 Para 14. This states that in arriving at preferred sites a site assessment process has been followed. It also indicates that this process is robust and much emphasis in the actual process itself (page 23) is based on the sustainability appraisal. This is further detailed in the site selection methodology document which calls on support from the National Planning Policy Framework (NPPF) and again relies on the sustainability appraisal for site assessment. Since both these documents are fundamentally flawed (see comments below) the inclusion of sites 44 and 178 and the robustness of the actual process itself must be called into question.
Site Selection Methodology Document 3.1 This quotes paragraph 157 of the NPPF specifying that it is crucial, amongst other things, that the local plan should provide detail on access. The Priests Lane Neighbourhood Residents Association provided a very detailed technical analysis of the problems with access to the Priests Lane sites. To date, no response to this document has been received from the Council. This is extremely concerning as the traffic along Priests Lane and the visibility for cars entering onto and exiting off the Lane is extremely limited, to the extent that at some points the addition of any access point is highly dangerous. It is concerning that despite this being a critical requirement of the NPPF, no specific reference or any robust argument has been made that a viable access point is possible. 3.3 This refers to paragraph 182 of the NPPF which indicates that the Local Plan must be justified as the most appropriate when considered against reasonable alternatives. The paragraph also states that not only development, but infrastructure requirements must be met. The positioning of the Priests Lane sites means that there is no room for mitigation of the problematic traffic situation which occurs at peak times of the day. Invariably, at peak hours traffic is queuing from the junction of Middleton Hall Lane back down Priests Lane for a distance which regularly exceeds 1,000m. Indeed, one of the traffic surveys has noted that the junction of Middleton Hall Lane and Ingrave Road is already at capacity at peak times and it is within 50m of this junction into which Priests Lane filters. Any additional traffic using Priests Lane from such a development can only exacerbate this situation. Other infrastructure problems to be considered are those of accessibility to transport links. Shenfield Station is over a mile walk away and the nearest bus service is located on Brentwood High Street, again a walk of just under a mile. The doctors' surgeries are already at capacity and there is a doubt as to whether any can handle more patients, with it already being more than a 2 week wait for an appointment to see a specific doctor. The nearby schools are also close to capacity. Indeed, Hogarth Primary School, which would be the nearest primary school, has already been extended to meet existing need and further extension would be required to meet a new unaccounted-for number of children. There is nowhere in the local plan that allows for an enhancement to these services as a result of any local development, despite it being a requirement listed in the NPPF. 3.20 This mentions the sustainability appraisal and that sites have been specifically assessed against certain criteria. Unfortunately, the sustainability appraisal has not done this qualitatively and has instead relied solely on quantitative analysis using location/distance criteria. The sustainability appraisal also specifically states that it has not included any information regarding traffic as this was 'outside the scope' nor has it been able to draw on information from other required policies (e.g. the site-specific policy) as these have yet to be completed. The evidence supplied to the council indicates that Priests Lane already has a significant traffic problem proved by the 'at capacity' junction at Middleton Hall Lane. It should also be pointed out at this stage that the junction has been judged to be at capacity by reference solely to those cars using Middleton Hall Lane and Ingrave Road, without reference to Priests Lane itself which joins Middleton Hall Lane close to the traffic lights. Additional cars using this route because of any development on the Lane can only cause more problems at this junction at peak times. For this reason and that there is no evidence to support an acceptable and safe access point to the sites, both sites should be withdrawn from the plan. Sustainability Appraisal: It should be noted that this appraisal is littered with comments indicating that further policies need to be completed before final comments can be made. Perhaps most importantly it states that many issues/impacts such as traffic have not been assessed as they were outside the scope. This casts doubt on the validity of the report itself and the reasoning behind the site selection. It does state that it must, itself, be considered along with consultation responses, something which is not mentioned within the local plan. The fact that the consultation of residents is to be considered is welcomed as many have submitted robust and evidence-based criteria against the proposed developments at Priests Lane. Table 3.2 Objectives of the sustainability appraisal include protecting and enhancing valuable landscapes...... and establishing a rich connected network of green infrastructure across the Borough and beyond. This is further supported at 10.3 which states that 'the network of green infrastructure and natural assets should be protected, enhanced and strategically expanded to deliver benefits for people and wildlife.' It is hard to see how this can be achieved by removing the only green open space (which is currently protected) between Brentwood and Shenfield. Table 6.2 From this table it appears that removal of the Priests Lane sites from all options would still allow Brentwood to comfortably meet their Objectively Assessed Housing Need (OAHN) of 7600 dwellings (up from 7240 following UK Government Intervention). From 7865 dwellings in Option 1 through to 9865 dwellings in Option 10). 9.3.1 This indicates that assessments have been undertaken and conclusions made without the site-specific policy which is yet to be drafted. In addition, it also notes that the thematic policy may require updating. This results in the following statement at 9.3.5 'In many instances, given reasonable assumptions, it is not possible to predict 'significant effects', but it is nonetheless possible and helpful to comment on merits (or otherwise) of preferred applications / the emerging plan in more general terms. This is not helpful and again calls into question the validity of the site selections as the apparently 'robust' site assessment process is based on an appraisal which has no specific evidence base and in places resorts to assumptions.
10.2.4 When reviewing the focus of growth in Brentwood/Shenfield, the appraisal indicated that the focus should be in maximising the number of homes 'least likely to worsen traffic congestion and that robust policy is established covering air quality and sustainable transport.' As previously mentioned, any development along Priests Lane can only cause an increase in the traffic congestion and, as a result, a deterioration in the air quality. Indeed, air quality is mentioned at 10.2.2 calling for a reduction in the previously proposed number of homes at Priests Lane as an increase in traffic because of development of the Priests Lane sites would cause an increase in traffic movement through the Air Quality Management Area (AQMA.) The minimal reduction offered in the plan means that the resulting proposal of 95 homes on the Priests Lane sites is still unacceptable from an air quality and transport point of view and does nothing to mitigate an issue which has already been highlighted as a concern. 10.5.4 This mentions that the Priests Lane sites are protected urban space and as such thought must be given to the well-being of the local community. Also mentioned here is a proposal for the expansion to Endeavour School but unfortunately no reference to the possible further expansion of Hogarth School and the loss of open area which has previously been used as playing fields (see later for comment from Sport England.) Appendix III While this is supposed to be the appraisal of the sites themselves it is rendered largely irrelevant by the fact that actual robust data is not available to assess the actual sustainability of any site. Analysis is made simply by using Geographical Information Systems Software which assesses the criteria based solely on distance, this is not an acceptable evidence base on which to include sites within the local development plan as issues such as traffic constraints are not accounted for. Equally there is no evidence as to how environmental, social and economic conditions will be improved on Priests Lane, nor how the impact of any development will be mitigated. Draft Plan Page 7 Para. 18d Commits to enhancing green infrastructure by improving the quality range and connectiveness of the Boroughs natural green assets. This is also similarly stated in the sustainability review and the same question applies as to how this can be achieved by developing the only green open space between Brentwood and Shenfield. Draft Plan Page 11 inset This similarly commits to a network of green infrastructure with brownfield development and well planned urban extensions. It is difficult to see how development of the Priests Lane sites will fit with this proposal since their development means the loss of an open space and the increased traffic along Priests Lane will render it unavailable for cycling and will become merely a rat run between Brentwood and Shenfield. Draft Plan Para. 28 SO16 and SO 17, The development of the sites at Priests Lane is contrary to both these proposals which again profess to protect and enhance valuable landscapes and establish a rich connected network of green infrastructure. Draft Plan Page 13 Para. 28 SO 19, SO 21 and SO22, all these commit to delivering infrastructure of education, health, transport and cycling and walking facilities. There is no specific indication within the plan that education and health facilities will be delivered if the Priests Lane sites were developed. Additionally, the lane is too narrow for public transport and the distance to the nearest bus stop will not reduce the reliance on the use of cars. The Lane does not have pavements along both sides and the road itself is narrow in parts, indeed if the road were to be built now it would not meet recommended guidelines. Due to the nature of the road cycling is very dangerous and those who do cycle tend to use the pavement rather than the road causing problems for pedestrians and cyclists alike. Any development of the Priests Lane sites will only exacerbate these problems. Page 14 Para.31 The Priests Lane sites are designated as protected open urban space and are listed as greenfield in the local plan. There is no evidence to suggest they are sustainable site or deliverable sites and this begs the question as to why they are even included in the local plan. Page 22 Para 55. As previously stated the methodology assessment and the sustainability review are fundamentally flawed providing no evidence base to include the Priests Lane sites within this plan. There has been no site-specific report carried out with respect to flooding, landscape, highways, ecology or utilities and while there have been many technical based submissions to the Council against the development of these sites, no response has been received, from which the conclusion must be that there are no evidence-based grounds to include these sites within the local plan. Page 29 Para.64d This suggests work is progressing regarding design, layout and use of the sites at Priests Lane but is meaningless as no detail is provided. Page 48 Paras 103 and 104 These address the need for an increase in places at doctors' surgeries for patients. The current need is only just being met and an increase in the number of homes in the area can only exacerbate that need, further aggravated by the local age profile. It is unclear how the needs required by a development on the Priests Lane sites will be met. Page 52 Para. 110 Priests Lane is a major route connecting Brentwood to Shenfield and a conduit for traffic wishing to access the M25, A127, A12 and A128. The already proposed increase in housing in Shenfield with the development of business along the A127 is likely to cause additional traffic to use Priests Lane as a thoroughfare between the two. If the Priests Lane sites were to also be developed the level of traffic using the lane would become unbearable and unsustainable, causing longer queues to the junction of Middleton hall Lane with the problematic knock on effects at the junction itself and heavier flow of traffic through the AQMA.
General Comments: 1. Traffic: The Plan released for consultation does not include any planning for traffic concerns and the Highways evidence will not be available until well after the consultation is closed. The sustainability reports refer to traffic as a concern, however it is silent on plans for managing increased traffic through the town centre; 2. Housing Density: The amount of housing proposed for the Priests Lane sites has been reduced from 130 houses to 95 houses, although this still exceeds the average housing density for the neighbourhood, and the adjacent developments of Bishop Walk and St. Andrew's Place. Also, as the Council does not really control the level of houses applied for, should planning permission of the site be granted, it is possible that the number of houses ultimately could be higher than the 95 stated; 3. Open Space: The Open Spaces Strategy report noted that Shenfield is not well served by easy access (within walking distance) to green spaces and play areas, and that the Council should seek to gain access to open spaces when they may come available. The 2016 LDP recommended keeping part of the land at Priests Lane for open space/sports facilities and available for the community, but this was removed at the request for the land owner, despite objections to developing the site being received by the Council from Sport England and the Essex Playing Fields Association. It seems reasonable, and in line with available evidence, that the Council should seek to obtain some retention of open space for the benefit of the community in the event the land is released for residential development; 4. Sport England: I am aware that Sport England made comment during the previous consultation period and is likely to do so again during the current one. Particularly as there is a possibility of extending The Endeavour school and perhaps Hogarth. They will surely have an input in the increased loss of land previously used as a playing field. It is understood that their previous comments were that the site may offer potential for meeting community playing field needs and should more land be required; the loss of the site would be contrary to Sport England's playing fields policy and Government planning policy on playing fields set out in paragraph 74 of the NPPF. Conclusion: My reading of the local plan and supporting documents has provided no evidence base to support the development of the sites at Priests Lane. Indeed, the technical submissions already sent to the council discounting development of these sites are superior in their technicality and evidence base than that within the plan. The comments I made during the previous consultation period have not been addressed by the new draft plan and for this reason these also stand. I am therefore attaching these as further evidences against the development of the sites at Priests Lane.