Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 25803

Received: 19/03/2019

Respondent: Claire Hamer

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Duty to Cooperate; The technical submissions of residents have not been addressed.
* Submissions have been made regarding the safety issues surrounding the potential access routes and that they do not conform to Essex Highways requirements. These have not been addressed.
* No traffic assessment has been carried out along Priests Lane to support any additional houses despite requests from residents.
* The land is currently designated greenfield and was previously protected open urban space. There has been no proof that there is enough open space within the area, indeed it has been removed from previous plans for this reason.
* No account has been made of the increased pollution resulting from the
increase in car journeys from this and the proposed Shenfield development at a junction which is already a pollution hotspot.
* The Lane was never meant to be a main distributary road which it has now become. Residents have pointed out that as such it does not comply with the Essex design guide with respect to road and pavement width.
NPPF Compliant: Local plans should address not only housing but traffic concerns, healthcare and education needs.
* The plan does not include any planning for traffic concerns.
* The sustainability review refers to traffic as a concern but is silent on plans to manage increased traffic flow through the town centre and Brentwood has historically had significant traffic problems with limited mitigation options.
* The failure to address these issues will result in poor future planning and is clearly the reason why the NPPF requires then to be included in local plans.
* There is no additional provision for increased educational needs, the expansion of Hogarth School is to meet current demands. Schools further afield which may have space will require a car journey to attend, exacerbating the already dire traffic situation.
* No thought has been given to health provision in a town where the population is of increasing old age. There is already a low level of GPs per head.

Change suggested by respondent:

* The needs of the current population need to be assessed regarding traffic flow, GP and school availability.
* Accurate traffic assessments should be carried out BEFORE any site is decided on for development and a sensible debate had regarding its viability and housing delivery.
* The safety and health of current residents should be considered before increasing traffic and therefore pollution in an already congested area.
* The plan must address the requirement for open space in the area and special consideration must be given to the requirements of the two schools bordering the sites as they will inevitably be requiring additional space, be it playing fields ( due to the loss of their current areas) or future expansion of the schools (in the light of the extra demand from the rapid increase in population as a result of the proposed plan).
* The site is not justified given the amount of technical evidence against development.

Full text:

Priests lane standard text - for information. March 2019

Priests Lane site R19
Unsound: The evidence base is flawed. The Transport Assessment is inaccurate:
* Data for the junction at Middleton Hall Lane was taken during a period of exam study leave meaning a reduction of approximately 1 /3 of students and therefore a significant reduction in car journeys.
* The Transport Assessment does not account for the transfer of pupils to and from Brentwood School which accounts for a large proportion of the congestion along Priests Lane.
* The Transport Assessment does not account for the increased traffic usage of Priests Lane as a result of cars travelling from the proposed development of 1,000 houses in Shenfield to the A127, nor the increase in other journeys as a result of this development.
* The Transport Assessment does not account for any impact of the Elizabeth Line.
* No specific assessment has been carried out to determine whether the Lane can support any additional vehicles at peak times.
* No assessment has been carried out of the potential access routes. These are either unsighted or not intended to withstand such volumes of traffic so pose a safety hazard to motorists and pedestrians alike.
* The site does not meet relevant sustainability conditions, notably access, transport network, mitigation of impact on local services, and unacceptable effect on health due to increased pollution.

Duty to Cooperate; The technical submissions of residents have not been addressed.
* Submissions have been made regarding the safety issues surrounding the potential access routes and that they do not conform to Essex Highways requirements. These have not been addressed.
* No traffic assessment has been carried out along Priests Lane to support any additional houses despite requests from residents.
* The land is currently designated greenfield and was previously protected open urban space. There has been no proof that there is enough open space within the area, indeed it has been removed from previous plans for this reason.
* No account has been made of the increased pollution resulting from the
increase in car journeys from this and the proposed Shenfield development at a junction which is already a pollution hotspot.
* The Lane was never meant to be a main distributary road which it has now become. Residents have pointed out that as such it does not comply with the Essex design guide with respect to road and pavement width.
NPPF Compliant: Local plans should address not only housing but traffic concerns, healthcare and education needs.
* The plan does not include any planning for traffic concerns.
* The sustainability review refers to traffic as a concern but is silent on plans to manage increased traffic flow through the town centre and Brentwood has historically had significant traffic problems with limited mitigation options.
* The failure to address these issues will result in poor future planning and is clearly the reason why the NPPF requires then to be included in local plans.
* There is no additional provision for increased educational needs, the expansion of Hogarth School is to meet current demands. Schools further afield which may have space will require a car journey to attend, exacerbating the already dire traffic situation.
* No thought has been given to health provision in a town where the population is of increasing old age. There is already a low level of GPs per head.

* The needs of the current population need to be assessed regarding traffic flow, GP and school availability.
* Accurate traffic assessments should be carried out BEFORE any site is decided on for development and a sensible debate had regarding its viability and housing delivery.
* The safety and health of current residents should be considered before increasing traffic and therefore pollution in an already congested area.
* The plan must address the requirement for open space in the area and special consideration must be given to the requirements of the two schools bordering the sites as they will inevitably be requiring additional space, be it playing fields ( due to the loss of their current areas) or future expansion of the schools (in the light of the extra demand from the rapid increase in population as a result of the proposed plan).
* The site is not justified given the amount of technical evidence against development.

Attachments: