Object

Preferred Site Allocations 2018

Representation ID: 18588

Received: 03/03/2018

Respondent: Mr Mike Kenyon

Representation Summary:

The Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this site causing a further deterioration in the air quality. The site has previously been designated as a protected open urban space and has been recognised as having value to the community. Current infrastructure and services are not sufficient and unable to support further development.

Full text:

Objection against the inclusion of sites 44 and 178 (the Priests Lane sites) in the draft Local Development Plan. Page 3 Para.5, Page 4 Paras. 7,8,9 All these paragraphs indicate that the previous consultation comments have been reviewed and the appropriate adjustments made. Unfortunately, it does not appear that many of the technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan. Page 6, Para 14. The wording of the plan documents makes it seem that rigorous testing has been carried out to achieve a list of preferred sites. On reviewing the sustainability appraisal this appears not to be the case since many comments and conclusions formed are covered with caveats stating that further reports are required and, significantly, the appraisal has been completed without reference to the effects of some issues such as traffic, as these were 'outside the scope'. The site-specific review has relied solely on quantitative analysis based on distance. No qualitative review of any site has been undertaken. My comments relevant to the sustainability appraisal criteria of the site options as regards the Priests Lane sites are as follows: Air Quality: At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is in the top three 'hot spots' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this site causing a further deterioration in the air quality. The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost. Biodiversity: The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenbelt sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic. The sustainability appraisal and the plan indicate there is a need to keep green sites to prevent Brentwood becoming one conurbation and maintaining its 'village' feel. Development of these sites completely opposes these objectives.The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare. Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss. Community and Well-being: The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 95 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset at this time does not appear to be a sensible decision. While the sites appear to be close to transport facilities they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side. Priests Lane is already well known for its traffic problems including (but not limited to): Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further; Speeding traffic at off-peak times; Poor visibility for residents trying to access the roadway from junctions or side roads; Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'; Health and safety issues for pedestrians crossing attempting to cross the road, often on bends where the pedestrian path swaps from one side to another; Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road; Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road. It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, this is not considered anywhere in the plan document, which is surprising considering it is such a health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult. The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, in particular with relation to safety and air quality. Flooding, Waste and General Infrastructure: The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens. With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities. The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site. General: I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost. For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites I wish to register my very strong objection.