Cycling through central Brentwood is inhibited by the narrowness of Shenfield Road/Brentwood High St. and adjoining roads. The above major route is often congested at peak times and due to road works. I cannot see how this can be improved to encourage cycling; many of the current cyclists use the pavements, as the road is considered too dangerous. Any measures that can be adopted to encourage cycling would be welcome.

Crossrail will have a significant effect upon sustainable transport in Shenfield and the site is ideally located to benefit from this and to help maximise sustainable development in the Borough.

Current infrstructure needs improving - not just related to new develpments

You cn encourage me to walk/cycle all you like but my side affects from illness treatment means my lungs are permanently damage. Cycling or walking would likely kill me so don't condemn me to never being able to leave my house please.

Lack of Road Infrastructure
One of the major issues posed by the Dunton Hills Garden Village and other proposed developments along the A127 corridor is its impact on the local road infrastructure. With 3000 new homes we could see and additional 6,000 cars being placed on the road network in the area. It is likely that large numbers of residents of the new developments would need to travel outside to access work, schools, and shops because there will be only very limited provision for such amenities within the development itself.
The roads that would bear the brunt of the extra traffic would be the A127, A128 and the lower Dunton Road leading South via the B1007 to the A13.
The A127 is already a major arterial highway running from Southend into London. It has been seriously neglected in recent years as new housing development has increased its load far beyond its capacity (see A127 - Corridor for Growth, An economic Plan by R.L. Bass and A Cox March 2014). Although it is a dual carriageway it has many small roads that join it at minor junctions as well as retail shops such as garden centres that open directly onto the road without slip lanes in many cases. The traffic on the road is now far too heavy and fast for such junctions.
The estimated cost to rectify some of its faults to cope with existing traffic is estimated at 70 million pounds. The road is currently blocked down to slow moving traffic along parts of its length during morning commuter traffic lasting for several hours along some stretches such as between the Dunton roundabout and the M25 junction. Since there is no verge or hard shoulder any minor accident or breakdown brings the entire road to a standstill at almost any hour. Junction upgrades will not be sufficient to change this. If Dunton Garden Suburb is to be viable the road will need a major upgrade to three lanes with a hard shoulder. This would entail expense measured in hundreds of millions of pounds. This money could not be raised through community infrastructure levys since any such money will be needed for onsite infrastructure such as schools and health centres and would never be sufficient for large scale road improvements. Unless another source of funding on a large scale is found the A127 is likely to remain as it is turning the area into a road traffic nightmare. Since we are entering an era of increased austerity it is hard to imagine where such money could come from. With the A127 blocked other roads will increasingly become rat-runs for cars trying to find alternative routes. This will be the case for the A128 and roads through West Horndon.
Other roads will also suffer from the impact of the development. Since half the residents will belong to the Brentwood Borough they will often wish to travel to Brentwood along the A128. That is already a road that suffers traffic problems of its own. If the suburb is given direct access to the A128 so that traffic does not need to use the A127 to get there then the suburb itself will become a rat-run for through traffic trying to avoid the A127.
Another alternative route will be the A13 but it is also at a high capacity and the Lower Dunton Road/B1007 route is also a minor road which would therefore need upgrading
In conclusion the traffic implications of the proposed development will be catastrophic for the area unless outside funding in the order of a billion pounds is found to upgrade road networks before the suburb is built. In the present economic climate their is no possibility of funding on anything like that scale so the project must be taken no further.
In contrast, the A12 corridor is benefiting from huge investment in Crossrail and widening of the A12 over the next few years. Relatively little new housing development has been proposed for the A12 corridor in the Borough of Brentwood. It would make much more sense to plan for new development along the A12 corridor where infrastructure is already being improved than the A127 corridor where there is little hope of much funding for road or rail improvements over the term of the plan.

We note in paragraph 10.6 that this policy aims to ensure that development reduces the need to travel, and to give priority to pedestrians and cyclists to reach facilities including recreational facilities and open space. We request that equestrians are included within this policy to ensure that this vulnerable user group is not ignored. We would also like to make the comment that there appear to be no plans within this document to incorporate any strategic trunk road or railway crossings as part of new developments. Just recently a young boy was killed on the A127 where the bridleway is severed by this extremely busy road and this sad episode brings to the fore the need to plan ahead how residents are going to access jobs, schools and other facilities if they lie across either of these barriers. We therefore request that at the Masterplan planning stage of new developments that multi-user crossings for the A127/A12 and the railway line are incorporated into the scheme at an early stage and developer contribution is obtained to enable this to happen. It seems ludicrous to encourage walking and cycling, reducing dependence on the use of cars, when people are unable to safely access those areas across what are effectively major barriers, unless they are travelling in a car.

The emphasis on sustainable transport is very important for the future.

Crossrail is almost irrelevant, since it will not shorten journey times to Stratford, central London, and beyond. It will continue to be quickest to get the fast trains from Shenfield (even if starting at Brentwood station) and then change at Stratford/Liverpool Street. The main benefit would be for journeys to Harold Wood to Maryland inclusive, destinations of lower relevance to most Brentwood residents.

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Summary
It is considered that Brentwood Council has not thoroughly tested all the available options to accommodate the housing requirement within Brentwood. The National Planning Policy Guidance and earlier advice from the Planning Advisory Service recommend that local authorities should be required to thoroughly test all reasonable options before requiring other authorities to accommodate some of their need.
Thurrock Council at this stage does not consider that all reasonable options to accommodate Brentwood's dwelling requirement within Brentwood have been fully examined by the Council and tested in accordance with government policy and guidance. Therefore the approach to preparation of the local plan is unsound.
Thurrock Council requests that more detail is provided as to how such Green Belt release is to be undertaken and how alternative locations have been considered before a further draft Local Plan consultation. It is considered the role and development of the A12 corridor and in particular Brentwood/Shenfield Broad Area should be thoroughly investigated and its potential role to accommodate further growth over the period of the local plan and beyond. The implications of the potential to accommodate more growth and associated infrastructure requirements need to be considered with some weight as a way of meeting the housing requirement currently identified in the Brentwood Local Plan Growth Options and supporting evidence.
Thurrock Council has a fundamental objection to a strategic Green Belt release at Dunton Hill Garden Village or at West Horndon due to the impact on the Green Belt. In addition limited new or updated evidence has been made available to demonstrate the deliverability and viability of such schemes.
Thurrock Council has also highlighted various aspects of concern with the evidence base in connection with the preparation of the draft local Plan.
Thurrock Council wished to clarify that its objections to the earlier consultations to the Brentwood Local Plan and Dunton Garden Suburb stage still stand. Due to the issues highlighted in this response and to the earlier documents there are several fundamental concerns to the strategy approach and detail development proposals it is considered that Brentwood Council needs to carefully consider how it proceeds with the preparation of the Local Plan and the timetable for its production.
Thurrock Council request to be kept informed of the preparation and publication of the Brentwood Local Plan and technical evidence base as part of the Duty to cooperate process.

These are my comments to the Draft Council Planning document.

* Use of Car Parks to develop

My main concern is that it would appear wherever there is a council owned car park, it is proposed to convert these into dwellings. This includes the car parks in Westbury Road, Chatham Way and William Hunter Way.

Where are the current users of these car parks to park? There is nowhere near the centre of Brentwood for people to park. This reduces significantly the attraction for visitors and shoppers and workers.

The Brentwood Council car park should also be included in these plans. If you are to build on most car parks, why not build on the main council car park too.

* Use of existing empty shop units

There are a number of empty shopping units in Brentwood. I counted over 20 empty and there is a very high percentage of empty units in the BayTree centre.
These units should be considered first before building new units to supply the niche shopping towards the vision.

* Cycle Paths

Brentwood still does not have a dedicated cycle route or markings along the main route towards London. If you are to encourage cycling and reduce the vehicle road use, you need to have purpose built paths and markings.
There are road markings and dedicated cycle paths from the M25 into central London. The paths/markings stop abruptly at the M25 towards Brentwood.

* Westbury Road Car Park and St Charles Napier Pub Land

I note that there are dwellings planned for Westbury Road car park. The surrounding Victorian houses have been affected by flooding in the past. This needs to be considered when building new properties.
What is to happen to the land where the St Charles Napier Pub once stood. This is unsightly and needs developing.

* Cinema

The best place to build a cinema complex for Brentwood is at the Brentwood Leisure Centre. There is already ample parking there. This would avoid building at the William Hunter Way car park. So the town centre would avoid the vehicle traffic from cinema goers.

I have read the Local Plan with interest. I am concerned that some of the proposals for additional housing are inappropriate and they will contribute further to the terrible traffic congestion at peak times and other issues that we face in the Brentwood and Shenfield areas.

Over-development of the area will destroy the quality of life that existing residents enjoy. Any encroachment on existing Green Belt land should be prohibited.

The night-time entertainment facilities in Brentwood are already adequate and further development of them should not be encouraged otherwise they will lead to further social issues, damage to the reputation of the town and destroy the attractive character of the town centre and surrounding areas.

Extra housing will bring extra traffic and there is no attempt in the Plan to address this increasing problem. Brentwood already comes close to total gridlock on occasions and building so many new properties will simply increase the problems.

The main roads in the area covered by the Plan are the A12 and the A127. Both are woefully inadequate for the demands being placed on them already and further development of housing or employment infrastructure (such as the ports at Harwich and Felixstowe and the London Gateway terminal) unleash huge numbers of trucks on to our local reads every day. The stretches of the A12 and the A127 that run through the area should be widened to 3 or 4 lanes in either direction and be upgraded to motorway standard with hard shoulders along their entire length for safety and to help avoid traffic delays in the event of a breakdown or accident.

The Plan mentions the need for housing suited for older and disabled residents yet Brentwood Council allows the existing stock of suitable homes to be depleted - I am referring to the ongoing demolition of bungalows in Shenfield and their inevitable replacement by huge 'executive homes'. Just because it is possible to demolish an existing property and squeeze on a much bigger one does not mean it should be done. Demolition of sound properties simply to make a quick buck for the developer is a very un-green practice and one the Council should strongly discourage. It is going to be impossible for older residents to stay in this area if this practice is allowed to continue.

The proposal to develop a huge number of houses on Officers Meadow in Shenfield (site refs 034,087 & 235) will not only destroy a valuable piece of Green belt land but will inevitably lead to more traffic joining the jams that already clog up the roads in to Brentwood at peak times and will reinforce the existing overlaod on the A12 Brentwood by-pass. This is a very large development and is out of all proportion to the surrounding area.

The proposal to build houses and other facilities off Priests Lane (site refs 044 & 178) will destroy a valuable piece of open land and will add to the terrible traffic jams that currently clog Priests Lane at peak periods. Priests Lane is too narrow for the amount of traffic that already uses it and the narrow pavement along only one side makes it very dangerous for pedestrians who walk along it in fear of being mown down by passing traffic attempting to negotiate its narrow carriageway.

The plan to build Dunton Hills Garden Village is going to destroy one of the atrractive corners of the borough. It is an enormous housing estate development and calling it a 'village' cannot disguise that.

Whilst the Crossrail development is to be welcomed I wonder how much capacity it will ad because there will be no additional tracks laid towards London and I suspect that some existing services may end up being cancelled to make capacity for the Crossrail trains on the already congested lines. Increasing goods trains as a result of the London Gateway and other ports around the Essex coast mean further risk of delays and disruption to passenger services.

What we really need is the development of new rail routes - connecting from Shenfield directly to Stansted (not via Liverpool Street) and across the Thames to Gatwick as these would do a lot to reduce congestion and stimulate development in the outer London area. This is in addition to the proposed additional road development and tunnels across the Thames at Tilbury linking the A2 to the M25.

I believe that my proposals would result in a more sustainable set of developments. I hope these comments will be noted and the Plan will be reconsidered.

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Overall the Brentwood Draft Local Plan is well thought through and, given the challenges, makes a good plan for the provision of new homes in the Borough.

I have two main concerns:

1. Policy 5.2 Housing Growth: There remain 928 dwellings to be provided under the "windfall" allowance, which in comparison the historic growth rates add up to a very large number of new sites of up to 10 homes to be allocated in the future and a very long list of sites in the current non-allocated housing sites. Will this not create a potential planning blight in these areas if it isn't made clear where the 928 houses are to go? Can the status of the non-allocated sites be made clearer? Will there be a pause in development for windfall sites whist the main plan areas for development are progressed to ease the period of uncertainty?

2. Policy 10.1 Sustainable Transport Policy: Some development is proposed in Pilgrims Hatch along the Doddinghurst Road where it intersects with the A12 - site ref 023 for 250 homes. The majority of the traffic generated from these homes will go south into Brentwood along the Ongar Road and perhaps along the Doddinghurst Road. The traffic from the intersection of Doddinghurst Road and the Ongar Road moving towards Wilsons Corner is already at gridlock in the mornings and evenings, not helped by lorries off-loading outside the shops at the top of the Ongar Road and the roundabout at the William Hunter way giving automatic priority to cars emerging from William Hunter way to turn right towards Wilsons Corner - not good when the car parks empty in the evening with home goers. Similarly, Western Avenue traffic moving towards the London Road/ Kings Road traffic lights, bound for either the railway station or London Road offices or the M25, is very heavy with delays at the traffic lights backing up to William Hunter Way roundabout. More houses and hence more traffic in this area will be unacceptable unless major improvements to the traffic management are made in some way that has not been defined.

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Thank you for giving the Mayor of London the opportunity to comment on your Draft Local Plan.
The Council's most recent evidence is focusing on the tightly defined area of the Borough despite significant interrelationships with its neighbours including London. These are demonstrated in particular through the significant proportion of commuting into the capital (almost 15,000 per day). This underscores the importance of collaboration and the Duty to Co-operate.
The Mayor welcomes the Borough's approach to meeting its housing need and agrees with its conclusion for further work related to London. The Council may also wish to assure itself that proposals for a garden village are congruent with national policy on Green Belt development.
In terms of employment, the Brentwood Enterprise Park is expected to make a significant contribution towards meeting the Borough's need. In the light of its proximity to London, close cooperation with the relevant neighbouring authorities is required. Also, given the Borough's good access to the strategic road network (via M25/A12/A127), it would also be useful to understand better your thoughts on the future consideration of land specifically for industry and logistics, and related opportunities that could potentially arise from the promotion of growth and development across London and its Opportunity Areas in particular.
With regards to retail we would support a town centre first approach and the need to work closely with neighbouring authorities including London on the potential impact of new larger-scale retail development on the vitality and viability of neighbouring centres.
From a transport perspective Brentwood has a very high level of car ownership compared to the national average. Without alternative means of transport the use of cars will continue to be an essential factor in access to services, employment and leisure. Therefore the delivery and encouragement of sustainable transport alternatives is essential.
The Mayor welcomes the Council's corridor-based approach and the consideration of transport implications beyond its boundaries. The arrival of the Elizabeth Line (formely Crossrail) in 2019 at Brentwood and Shenfield will improve the existing metro service and connectivity to Stratford as well as Central London, although the potential longer-term capacity is still under consideration (please see Transport for London's response for further details). Within this context, the Councils may wish to look at growth options close to these train stations and their catchment areas. The Mayor also supports the principle of improvements to the Greater Eastern Mainline between London and Norwich through Brentwood and would welcome policy support for it.

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FOR THE ATTENTION OF: The Planning Team
Brentwood Local Plan Response
Dear sirs,
Thank you for giving Highways England (HE) the opportunity to comment upon the Draft Local Development Plan setting out your development needs, policies and strategies over the next 15 years. Highways England has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the strategic road network (SRN). The SRN is a critical national asset and as such Highways England works to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.
In the case of the Draft Local Development Plan, Highways England is interested in the potential impact that the development might have upon the M25 Junctions 28 and 29 and the A12. We would be concerned as to whether there would be any adverse safety implications or material increase in queues and delays on the strategic road network as a result of your Local Plan developments.
We have reviewed the Draft Development Plan and have the following comments
Policy 6.3 C covering general development criteria states that development proposals will need to be accompanied by transport assessments to ensure that the transport network can accommodate the generated traffic. We would caution against examining development impacts on a site by site basis only as this may overlook the impacts of Local Plan development as a whole. Looking at the Housing Land Allocations in Figure 7.2 there are numerous small sites that would have no impact upon the A12 or M25 although the aggregate impact for the smaller sites fully built out could add to queueing and delays on the two SRN roads within the Borough. There should be a transport assessment of the overall Local Plan developments and the need for any mitigation identified. We would need to be assured by evidence that the overall Local Plan development has been considered if we are to support the Local Plan.
We are pleased to see in Policy 6.3 C that you stipulate a requirement to consider safety as part of a transport assessment. Given the high speed nature of the M25 and A12 safety is a primary concern to Highways England and we would object to any safety implications of development, development traffic or highway mitigation.
As you know, in 2014 we were consulted by you and made comments on your suggested approach to the transport assessment for your Local Plan at that time. We have not heard further to this time any more details of an assessment but assume that you will still be undertaking such an assessment. We look forward to receiving your full Local Plan transport assessment in due course. Should you require further advice on transport related issues please do not hesitate to contact us.
Policy 8.8 relates to retail and commercial development. The policy calls for mitigation to the transport network where travel demand cannot be accommodated satisfactorily. Again, this approach suggests that any impacts are examined on an individual development basis. There is a risk in adopting this approach downstream for two reasons. Firstly, the full impacts of the local plan will not be considered, rather assessment of the larger developments only. Secondly, full impacts should be assessed within the Local Plan rather than at planning application stage, otherwise mitigation may be required that for whatever reason may be undeliverable.
Policy 10.1 covers sustainable transport. We are pleased to see a dedicated policy covering sustainable transport measures in addition to Policy 8.3 stating the need to locate development in accessible areas close to the arterial corridors M25, A12 and A127. To marry the two policies there will be a need to develop sustainable transport measures that manage down the private vehicle demand to and from these accessible developments. Policy 8.3 also states the need for employment development to be accessible by walking and cycling. Therefore, we will be keen to see what measures are to be adopted under your Local Plan to ensure that these policies are compatible.
We hope that you find these comments useful and we look forward to further correspondence in due course.
Sent on behalf of Janice Burgess (Spatial Planning Manager)

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