Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 22341
Received: 17/03/2019
Respondent: Mr Carl Fiddimore
Legally compliant? No
Sound? No
Duty to co-operate? No
Reasons are:
o Detailed technical evidence demonstrating the access from Priests Lane to the site doesn't meet road design guidelines and is unsafe, has been ignored.
o Traffic analysis is insufficient and based upon non-representative and flawed datasets.
o The site has drainage and flooding issues, previous development was rejected on this basis.
o Failure to preserve a Protected Open Urban Space, previously a school playing field.
o Brentwood Council's consultation and decisions are inconsistent, and not evidence based.
o No technical basis to support the housing number, proposals for a care home is flawed, and Amount/Type cannot be enforced.
The land at Priests Lane should be removed from the Local Development Plan.
I support the request by the Priests Lane Residents Neighbours association to participate in the oral part of the EiP.
Unsound - the evidence base is flawed:
o The Transport Assessment is inaccurate as it excluded traffic along Priests Lane and was taken at times that excluded the large and usual proportion of school traffic.
o Brentwood Council did not conduct a Traffic Assessment along Priests Lane.
o The Transport Assessment does not account for the increased usage of Priests Lane from the proposed development of 1000 houses in Shenfield travelling to the A127 or generated traffic with respect to the Elizabeth Line.
o Fails to address safety of residents: technical submissions of residents that new road access points along Priests Lane are hazardous has not been addressed nor concerns that the existing road layout and pedestrian facilities would become unacceptably dangerous through increased traffic volumes.
o The site does not meet sustainability conditions, notably access, transport networks, mitigation of impact on local services, and unacceptable effect on health due to increased pollution.
o The Priests Lane sites have been previously rejected because the land is deemed a valuable urban space.
- No account has been taken of the increased pollution along Middleton Hall Lane sand Priests Lane, the junction of which is a pollution hotspot.
- Priests Lane was never intended to be a main distributary road which it has now become. Residents have pointed out that as such it does not comply with Essex design guides for road and pavement width and provision.
NPPF Compliance issues: Local Plans should address not only housing but traffic concerns, healthcare and education needs.
- The Sustainability Review refers to traffic as a concern but no mitigation options have been identified.
- no specific or robust argument has been made that a viable access point is possible.
- When considered against reasonable alternative, these sites can not be deemed justified and there is nowhere in the plan which allows for enhancement of infrastructure as a result of development.
- There is no additional provision for increased educational and health facilities, the expansion of Hogarth School is to meet current demand and there is already a low level of Ps per head. Schools further afield which may have space will require a car journey to attend, exacerbating the traffic volume issue.
I support the request by the Priests Lane Residents Neighbours association to participate in the oral part of the EiP.