brentwood.gov.uk

Removal of the Priests Lane sites from the plan.

Specific objection is made against Policy R19, inclusion of the Priests Lane sites on the grounds that the evidence base is flawed, and the inclusion of these sites does not comply with the NPPF as traffic concerns, healthcare and education needs, and other infrastructure requirements are not met. Consequently, for these reasons, outlined in more detail below, the plan is deemed unsound.
There have been many submissions to the Council of a highly technical nature expressing several concerns over the development of the Priests Lane sites, robustly backed up by technical argument. 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 it is hard to see how much notice, if any, has been taken of the very valid reasons against development of these sites.
The plan is supposedly evidenced based yet some of the supporting documentation contain fundamental flaws. (Most notably the Transport Assessment, see below.) This being the case, the inclusion of the sites at policy R19, the robustness of the actual process itself and the overall soundness of the plan 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. Further comment is made as follows: 'The route proposed for access into the site is wide enough to achieve a road with footpaths either side. Visibility splays would need to be created and may involve the loss of some hedgerows and crown lifting of the oak tree on right hand side of entrance. Proximity to Glanthams Road access will need to be considered carefully.' The Priests Lane Neighbourhood Residents Association provided a very detailed technical analysis of the problems with access to the Priests Lane sites suggesting that such an access would not comply to Essex Design Guide specifications. Additionally, a brief review of the Manual for Streets would indicate that the minimum visibility requirements are unlikely to be met due to the positioning of lampposts, telegraph poles and BT boxes, so it should not be assumed an access at this point would be safe. To date, no response to these comments has been received from the Council. This is extremely concerning as 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. Any additional traffic using Priests Lane from such a development can only exacerbate this situation and any additional traffic movements would prove to be hazardous.
Transport Assessment.
There has been no specific assessment of the junction of Priests Lane and Middleton Hall Lane to access whether this junction is already operating at capacity. The nearest junction was assessed at a time which is not actually the busiest time of day. Most notably between 3.30 and 5pm when Brentwood School finishes and there are regular queues across the junction and along Priests Lane due to cars attempting to enter and exit the school car park. Additionally, there has been no traffic assessment specific to Priests Lane itself. Moreover, the Transport Assessment was undertaken at a time when many children were off school on study leave.
The proposed number of houses was based on no evidence whatsoever and, although the residents have requested on numerous occasions for a traffic survey to be undertaken, one has not been carried out despite Council assurances that a traffic assessment would be done for Priests Lane. 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. The transport Assessment does not take account of this additional traffic, nor that associated with the Elizabeth Line.
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.
The 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 75 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.
The Priests Lane sites are protected urban space and as such thought must be given to the well-being of the local community. While there is a proposal for the expansion to Endeavour School there is 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.)
It is difficult to see how development of the Priests Lane sites will fit with the preservation of green infrastructure 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.
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.
The Priests Lane sites are designated as protected open urban space and are listed as greenfield in the local plan. Previous development has been refused on the basis that the area had the potential to flood and as such building on the sites would pose a flood risk for the immediate area. Indeed, even now residents backing onto the sites regularly find standing water in their gardens after heavy downpours. There is no substantial hard evidence to suggest the sites are sustainable or deliverable and this begs the question as to why they are even included in the local plan.
As previously stated, some supporting documentation is 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 and the decision to do so must be unsound.
General Comments
1. Traffic: The Plan 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 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 75 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.
4. Flooding: development of the sites has previously been rejected on the grounds that this would pose a flood risk.
5. 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 sound 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. For these reasons and those stated above the soundness of the plan must be called into question.