The land at Priests Lane should be removed from the local development plan.

The transport assessment is flawed.
The plan fails to address safety.
healthcare and education needs are not addressed by the plan

The land at Priests Lane should be removed from the Local Development Plan.

The evidence base is flawed and unsound:

Priests 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.

The Transport Assessment does not account for the increased usage of Priests Lane from the proposed development of 1,000 houses in Shenfield travelling to the A127, nor does it account for the impact of the Elizabeth Line.

The Transport Assessment is inaccurate as it has excluded traffic along Priests Lane and was taken at a time which excluded a large proportion of school traffic, despite Council assurances that a traffic assessment would be done for Priests Lane.

No account has been made of the increased pollution along Middleton Hall Lane and Priests Lane, the junction of which is a pollution hot spot.

The plan fails to address safety of residents : the technical submissions of residents that new road accesses along Priests Lane are hazardous have not been addressed, nor concerns that the road design is dangerous for increased traffic movements.

NPPF Non-compliant: :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 alternatives, these sites cannot be deemed justified and there is nowhere in the plan which allows for enhanced infrastructure as a result of development.

There is no additional provision for increased educational and health needs, the expansion of Hogarth School is to meet current demands and there is already a low of GPs per head. Schools further afield which may have space will require a car journey to attend, exacerbating the already dire situation.

Review road conditions and what changes can be made to make priests Lane a safe area to walk or drive along.

The area proposed should be removed from the Local Development Plan.

The evidence does not take into account increased local traffic that uses the narrow road that is Priests Lane. The traffic fumes and congestion will affect the local area. Local services will be affected - schools, parking, doctors. The pavement width is either narrow or does not exist along the section where the proposed development is planned.

Local plans should address not only housing but traffic concerns, healthcare and education needs.
Traffic concerns: Priests Lane is not suitable for higher volumes of traffic and certainly unable to support a bus route which the plans appear to rely on to provide more public transport to avoid increased car usage. Priests Lane already does not comply with Essex design guide with respect to road and pavement width.
Please note in below questions I would have selected N/A for legally compliant and duty to co-operate as I do not feel I have enough information to comment

Local plans should address not only housing but traffic concerns, healthcare and education needs.
Traffic concerns: Priests Lane is not suitable for higher volumes of traffic and certainly unable to support a bus route which the plans appear to rely on to provide more public transport to avoid increased car usage. Priests Lane already does not comply with Essex design guide with respect to road and pavement width.

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.

remove from Plan

Object to land at Priests Lane being in the plan

Priests Lane site should be removed from The Local Development Plan

Unsound
Traffic Assessment did not take into account Priests Lane therefore did not address concerns regarding school and work traffic, which is very bad both ends of the day. The transport assessment did not include projections of increased traffic from A127 on to Priests Lane due to new local pain housing allocations or the arrival of the Elizabethan Line.
Priests Lane was not designed to be a main distributary road however it has become so and this will only get worse with this development.
The junction of Middleton Hall Lane and Priests Lane is a pollution hotspot, provision for how to deal with increased pollution has not been considered.
The road design is dangerous for increased traffic flow as the pavements are not wide enough bearing in mind many children walk up and down priests lane to school.
The development adds traffic to an already traffic and pollution heavy area. This has not been mitigated in the policy set out by the council.
Access points to the site from Priests Lane are dangerous.
Of great concern is the fact that the site of in a Critical Drainage Area and yet there is no independent report on solutions regarding drainage of the site before or after construction.
For all the reasons above the site does not meet conditions of sustainability particularly with concern to transport and traffic or its affect on health due to increased pollution.

The land at Priests Lane should be removed from the Local Development Plan and maintained as an open urban space.

Transport assessment subjective, inaccurate, flawed. Increased traffic usage would impact dangerously upon the Lane.
The proposed Priests Lane access does not comply with national guidelines and would be very dangerous.
Pollution would increase in an already over-polluted area. Priests Lane already does not comply with national
requirements regarding widths and markings of both the roadway and pavements (which are not provided on both sides of the road).
The plan omits any reference to additional infrastructure, educational and health facilities.
The Plan contradicts every General Development Criteria laid down by the Council in its own Policy 6.3.
The sites at Priests Lane lie in a flood zone and no mitigating reference is included in the Plan other than the problem will be addressed.
This corresponds with every other reference to the need for mitigation of a problem.
The Council agrees access to the sites is a serious problem but has swept that aside.
The sites have been rejected on several occasions previously and there has been no change in the nature of the sites other than traffic usage of the Lane has increased considerably.
Finally, despite dozens/hundreds of responses, technical and otherwise, the Council has never responded directly to these local resident concerns, nor has it explained the continued inclusion of these sites and the inconsistent removal of other sites.

The land at Priests lane should be removed from the LDP.

Main objections to this new housing estate is the extra traffic it will create in an already congested area, together with the increase in traffic related pollution this will create for the local residents.
Will Priests lane and Friars Ave be able to safely cope with this extra traffic, from this and the many other new houses being built in the local area?

I also understand that the site was considered and rejected for development once before. Why does it keep coming back for consideration if its been rejected once already?

Remove site R19 from plan

The evidence base is flawed:
The transport Assessment is inaccurate as it has excluded traffic along Priests Lane, and was taken at times which excluded a large proportion of school traffic, despite Council assurances that a traffic assessment would be done for Priests Lane.
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, nor does it account for the impact of the Elizabeth Line.
The Plan fails to address safety of residents : the technical submissions residents that new road accesses along Priests Lane are hazardous have not been addressed, nor concerns that the road design is dangerous for increased traffic movements.
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.
The Priests Lane sites have been rejected previously because the land was deemed a valuable open urban space.
No account has been made of the increased pollution along Middleton Hall Lane and Priests Lane, the junction of which is 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.
Local Plans should address not only housing but traffic concerns, health care 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 alternatives these sites cannot be deemed justified and there is nowhere in the plan which allows for the enhancement of infrastructure as a result of development.
There is no additional provision for increased educational and health needs, the expansion of Hogarth School is to meet current demands and there is already a low level of GPs per head. Schools further afield which may have space will require a car journey to attend, exacerbating the already dire traffic situation.

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 alternatives these sites cannot be deemed to be justified and there is nowhere in the plan that allows for the enhancement of infrastructure as a result of development.
There is no additional provision for increased educational and health needs, the expansion of Hogarth School is to meet current demands and there is already a low level of GP's per head. Schools further afield which may have space will require a car journey to attend, exacerbating the already dire traffic situation.

A traffic assessment should be done for Priests Lane. The Transport Assessment is not accurate as it has excluded traffic along Priests Lane and was taken at times that excluded a large proportion of school traffic. It also does not take account of the increased usage of Priests Lane from the proposed development of 1,000 new houses in Shenfield travelling to the A127 and it does not take account of the extra traffic created by the Elizabeth Line. Resident safety is not properly considered regarding the new access roads into Priests Lane and the heavier traffic that will impact them. Sustainability is not addressed, again regarding access, transport network, impact on local services, and unacceptable health effects due to increased pollution. Sites on Priests Lane have been rejected in the past because they have been deemed to be valuable urban spaces. Are they no longer considered valuable? Priests Lane was never designed to be a major distributary road for Shenfield and its size and that of its pavements do not comply with the Essex design guide.

The land at Priests Lane should be removed from the Local Development Plan.

Priests Lane is a very narrow residential lane with only one pavement side at many places and increased houses and traffic will have a detrimental effect - it will be busier and more dangerous. The site doesn't meet relevant sustainability conditions such as access, transport network, impact on local services as well as increased pollution. This plan has previously been rejected due to being valuable open urban space which is still the case.

Significantly reduce the number of proposed dwellings or remove site from Local Development Plan

- Transport assessment is inaccurate as it has excluded traffic along priests lane and was taken at times which excluded a large proportion of school traffic.
- Site does not meet sustainability conditions, notably access, transport network and mitigation of impact on local services.

land from local development plan

- Transport assessment is inaccurate as it has excluded traffic along priests lane and was taken at times which excluded a large proportion of school traffic.
- Site does not meet sustainability conditions, notably access, transport network and mitigation of impact on local services.

Exclude this site from development as exit road from the site will not support the extra traffic.

The local roads from this site cannot cope with the additional traffic.

Remove site R19

Local plans should address not only housing but traffic concerns, healthcare and education needs.
1. The sustainability review refers to traffic as a concern but no mitigation options have been identified.
2. No specific or robust argument has been made that a viable access point is possible.
3. When considered against reasonable alternatives these sites cannot be deemed justified and there is nowhere in the plan which allows for the enhancement of infrastructure as a result of development.
4. There is no provision for increased educational need. 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
There is no provision for increased health needs. There is already a low level of GPs per head.

the land at Priests Lane should be removed from the Local Development plan.

Unsound The transport assessment is inaccurate as it was taken at a time that excluded a large proportion of regular school traffic along Priests Lane. The transport assessment does not account for increase usage of Priests Lane from other proposed local developments and impact of new Elizabeth train Line.
The plan fails to address safety of residents as current proposed road accesses design may give rise to hazardous sight lines.
The site does not meet relevant sustainability conditions, notably access, transport network, impact on local services and increased pollution from static bottleneck traffic on a road that is designated a 'Lane' by status and not a dual carriageway.This traffic pollution is particularly likely at the junction with Middleton Hall Lane. With increased pollution - runners , school children and dog walkers are less likely to want to use the current pleasant route.
The lane was never meant to be a dis-tributary road due to width restrictions and lack of proper pedestrian pathway at points.
The Priests lane site has been rejected previously as the land was deemed valuable open urban space.
NPPF Compliant : Local plans should address not only housing but traffic concerns health concerns and educational needs.

The Priests Lane sites should be removed from the plan.

PRIESTS LANE NEIGHBOURHOOD RESIDENTS ASSOCIATION ("PLNRA")

OBJECTIONS TO BRENTWOOD LOCAL PLAN 2016-2033 (PRE-SUBMISSION, REGULATION 19)

NOTE: THE DOCUMENT REFERRED TO WITHIN THIS SUBMISSION AS ATTACHED AND WHICH FORMS PART OF OUR RESPONSE HAS BEEN DELIVERED IN HARD COPY AS THE FILE WAS TOO LARGE TO UPLOAD.

The Priests Lane Neighbourhood Residents Association (PLNRA) represents residents who live in an area likely to be affected by the development of the Land at Priests Lane (Policy R19). We are writing with our continued objection to the inclusion of this land in the Brentwood local plan 2016-2033 (pre-submission, regulation 19), and the removal of the designation of Protected Open Urban Space. PLNRA also have several issues with the LDP as a whole and question the transparency and robustness of the process carried out by Brentwood Borough Council, which calls into question the soundness of the plan itself. In meetings with us the Council have made assertions which we consider have misrepresented the process and their responsibilities and have been contradicted by their subsequent actions. For these reasons we would like a hearing with the examiner as we consider the Council has not acted impartially with regard to all sites.

EXECUTIVE SUMMARY AND CONCLUSIONS

PLAN AS A WHOLE

The Plan document and process to date have failed to take into account detailed, evidence-based issues raised by consultees during the previous consultation processes, and have not provided evidentially based planning as required by the National Planning Policy Framework (NPPF). This framework requires that local Plans should address not only housing, but actions on traffic, healthcare and education needs generated. The evidential reports produced are superficial and do not provide clear plans on how to tackle infrastructure issues such as:
* Traffic - the LDP is virtually silent on one of the biggest issues facing the Borough;
* Primary school education; and
* health provision (particularly the low level of GPs per head of population)
This lack of attention to mitigation of infrastructure issues combined with evidence reports of which some are fundamentally flawed, results in a plan which is not wholly compliant with the NPPF and as a consequence is inherently unsound.

In addition, the central government policy on affordability is clearly inappropriate for the Borough of Brentwood and creates not only a significant artificial uplift in the numbers of new dwellings required to be built based on unstable forecasts that cannot predict the effects of leaving the EU, but compounds the problem by building in a further contingency of 6% on this flawed data.

OBJECTIONS TO INCLUSION OF LAND AT PRIESTS LANE (POLICY R19)

Once designated in the LDP these sites will lose their Protected Open Urban Space designation. The NPPF states that such sites should not be developed unless clear evidence has been provided that they are surplus to requirements, but no such evidence has been provided, in fact previous Council reports suggest the opposite. This designation should not be removed, because once lost it is lost forever.

Further, development of the sites should be rejected for the following reasons:

* the site accesses proposed are all unsafe for a housing development of this size onto a lane that is already too winding, narrow and dangerous, having become designated as a main distributary road over time, and there have been several accidents in the vicinity of the site access. The PLNRA has provided evidence that the road access does not meet current road design guidelines and has insufficient visibility splays - the Council's proposal to introduce a second access at Bishop Walk does not resolve the safety problem because the road is very narrow which was acceptable when built because it was a cul-de-sac for five houses;
* traffic often queues back from the junction of Priests Lane and Middleton Hall Lane to beyond the site access points. Developing the site would make this problem worse making travel at peak times intolerable;
* Priests Lane congestion is due to being a feeder road for Junction 8 (reviewed as part of the traffic work), however this traffic was not included in the review. This failure significantly underestimates the traffic using Junction 8 and had it been included, the junction would clearly be overcapacity. The traffic analysis concludes the junction as operating under capacity, but the revised data used for the analysis shows a number of inconsistencies and is subject to flawed readings due to the date on which it was taken. As a result, the data does not form a sound basis for the analysis, and the conclusion is flawed;
* the site suffers from surface water issues and Thames Water have stated that there are waste water issues on the site; Essex County Council stated that the site falls within the Brent-E flooding hotspot and local residents have identified flooding as an issue, meaning that significant flood management infrastructure would be needed;
* the sites are immediately adjacent to two schools which either need expansion or are at their maximum buildings to free space ratio - the Council has recognised that school expansion is needed to meet future needs, so development for houses prior to determining where schools should expand is short-sighted and not in line with evidential requirements as stated in the NPPF;
* Previous Open Space audits have identified a lack of open space in West Shenfield and this land has previously been identified as having value to the community as open space, despite it being privately owned. Previous Council reports have recommended acquiring land in this area if it becomes available to address this issue. Both Sport England and the Essex Playing Fields Association objected to the development, with the former concluding that this would contravene Paragraph 74 of the NPPF.
* This is the only greenfield land identified for development; the sites, along with some greenbelt land, forms part of a band of mostly undeveloped green area separating Shenfield from Brentwood, and so should have the same level of assessment as greenbelt land;
* While the Plan may suggest that brownfield sites be developed before greenfield sites, the Council have no way to control this in practice. Indeed, the housing trajectory as outlined within the plan indicates that by the removal of the protection, the Priests Lane sites are, in fact, targeted to be one of the first to be built upon despite brownfield sites being available. This means they are irretrievably lost, when in future they may be required to combat increased pollution or the local school requires the land for either expansion or for sport.
* This site received the second largest number of objections to the 2016 consultation as well as a 750-signature petition against development of these sites. In October 2017 PLNRA produced a detailed evidenced-based objections document (attached again to this document). The Council has so far not acknowledged the document or responded to the concerns raised.
* The PLNRA have been repeatedly told that existing traffic congestion and increased traffic concerns were insufficient reason to exclude a site from the Plan, however possible future traffic congestion was the reason for taking out the site at Honeypot Lane despite the Plan showing any supporting evidence. This inconsistency in decision making demonstrates a failure to act upon evidence as required by NPPF guidelines. Therefore, if potential traffic congestion is the reason for excluding similar sites in the Borough, then the significant increase in existing traffic congestion should be a sufficient reason to exclude the sites at Priests Lane.

CONCLUSION

Brentwood Borough Council should not remove the designation as Protected Open Urban Space for the land at Priests Lane (R19) because of the significant traffic safety and congestion concerns as well as practical difficulties related to surface water. The land should not be released for residential development, as the Council has not provided evidence that the land is not surplus to needs for playing fields or open space, and/or educational expansion for the adjacent schools. The land should as far as possible be retained as open space (in line with previous planning decisions), and the Council should work with the landowner to obtain access for community use, in line with Council recommendations in 2005.


 
COMMENTS ON THE OVERALL PLAN AND CONSULTATION

We have a number of objections to the Council's Approach in the Plan and the consultation process.

Strategy and Planning Criteria

The Consultation document from 2016, provided detailed information on the Council's policies and criteria for sites to be developed. The current consultation notes that the vision, strategic objectives and spatial strategy has been updated, but these are not set out in detail. We therefore assume that the planning policies and criteria for site inclusion remain the same.

A number of specific issues were raised in objections, but have had no formal response, nor are the concerns recognised or addressed in the new consultation document. The Plan only refers to objections for one specific site (Dunton Garden Village); it has been extremely disappointing that there has been no recognition of those sites which attracted high level of objections, nor any response to the objections. Priests Lane received one of the highest levels of objections during the 2016 consultation, followed by a petition in excess of 750 people objecting to the site.

The Plan identifies preferred development sites, however there is no evidence explaining why some sites are "preferred" over others, despite the Council stating that the assessment is objective and robust. The assessments provided of the various sites is very superficial, ignores traffic entirely and fails to address the cumulative impact of multiple developments. Given the size of public concern over some sites, we would expect a more detailed and robust assessment to be made public, including the reasons for dismissing objections raised in the previous consultation. It is insufficient to assess each site individually while ignoring the effect on Brentwood of the combined developments.

Most concerning has been the discussions which took place regarding certain sites prior to the Regulation 19 submission and the information provided by the Council to the PLNRA. As previously stated, the PLNRA has submitted technical evidence to support the removal of the Priests Lane sites from the plan and have expressed deep concern over the hazardous nature of the proposed access sites and the danger these pose to pedestrians and motorists alike. We have consistently requested official traffic reviews of the Lane and have been told these will only be required when a planning application is submitted. Despite this, we find that one site (Honeypot Lane) was apparently removed based on traffic congestion while contrary to this, the sustainability assessment actually supports the development of this site and indicates that constraints can be overcome with development management and, while it is greenbelt, 'it can tentatively be identified as relatively non-sensitive'.

No traffic survey has been carried out to support the removal of Honeypot Lane yet, without any council discussion, it was removed from the plan. This is despite the PLNRA being told that the Priests Lane sites with substantially more opposition to development and the submission of highly technical documentation, cannot be removed without substantive evidence. It is this lack of consistency and the absolute lack of transparency in the plan decision making process that leaves it open to question.

Also in this vein is the decision to, rather than remove the sites from the plan, arbitrarily reduce the number of houses to 75. This again is based on no factual evidence that the Lane can support the additional vehicular movement such a number of houses will bring. When questioned, our Councillor advised that despite our technical evidence on the safety risks and unsuitability of the access junctions, the Council has relied upon the unsupported opinion of the developer about access. The PLNRA were repeatedly told that decisions would be based only on evidence and so are astounded that such decisions have been made with no actual evidence base whatsoever.

Housing forecast

We accept that the Council needs to consider affordability of housing, but the Council cannot dictate who buys new housing, and the proximity to London means that new housing will continue to attract commuter buyers with higher wages, and the affordability target is unlikely to be achieved. We are concerned that increasing housing development to the detriment of existing residents is not a reasonable balance, in particular if this surplus development is met by releasing sites that should not be considered appropriate and infrastructure needs are not adequately considered or met.

We are also concerned that the housing forecast may be based on datasets that include migrant populations that will not continue to grow (and may in fact reduce) after the UK has left the EU, indeed the significant uncertainties over the effect of leaving the EU makes these long-term projections meaningless. Therefore, the baseline projections are likely to be flawed, and so an uplift would be even more inappropriate. This is particularly important because once sites with current protected designations (e.g. Greenbelt and Protected Open Urban Space) have these designations removed, they will be lost forever. Although the Council expect to review the Plan housing forecast every five years, this would be too late to save any of these currently protected assets as there is no prioritisation over the granting of planning permission for sites in the Plan (something that is a patently short-sighted failing of central government rules).

Traffic Analysis

Traffic concerns featured heavily in the objections at the last consultation. Brentwood town centre is subject to very high levels of congestion during peak travel hours. The NPPF (paras 156 and 157) requires that the local Planning Authority should "set out the strategic priorities for the area in the Local Plan." This should include strategic policies to deliver, among other things:
* the provision of infrastructure for transport, telecommunications, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);
* the provision of health, security, community and cultural infrastructure and other local facilities; and
* climate change mitigation and adaptation, conservation and enhancement of the natural and historic environment, including landscape.
The NPPF further states: "Crucially, Local Plans should plan positively for the development and infrastructure required in the area to meet the objectives, principles and policies of this Framework".
We consider that the Plan does not properly address the increased traffic nor has any realistic mitigation plans.
Priests Lane is a feeder road for Junction 8 (Ingrave Road, Middleton Hall Lane and Seven Arches Road), being only a few metres from this crossroads. The road is used by a significant amount of traffic accessing this crossroads at rush hour. It should be noted that this junction is in the vicinity of three large secondary schools.
The traffic analysis in the draft plan was based on traffic counts from November 2012 and showed that the crossroads are currently operating at capacity and are likely to go overcapacity with the increased housing, with no mitigation proposals identified. However, this analysis excludes the traffic approaching the junction from Priests Lane and so significantly underestimates the current and projected positions. Further, the afternoon rush hour starts at around 15:30 due to the proximity of secondary schools, but the afternoon traffic was only measured between 17:00 and 18:00 so ignoring school traffic.
The analysis was subsequently updated using more recent traffic analysis provided by a local school. The new counts showed significant variations in the traffic counts. However, this was dated 23 May 2017, a period falling during study leave for GSCEs and A levels. Given the use of the junction by traffic for schools this would have reduced traffic and account for some of this variation. The variations in traffic counts (Appendix A3 to the traffic analysis) were so wide and variable that they do not give any reliable evidence as to a definite increase or decrease in traffic. Indeed, if the data selected had been based on the traffic stream with the highest traffic count, then the conclusion would have been no significant decrease in traffic. It appears that the data has been cherry-picked to give the best result for the Council's needs.
This poor use of statistics undermines the soundness of the traffic analysis. We consider that if more appropriate datasets were used then Junction 8 would still be shown to be overcapacity.
We consider that this demonstrates that the conclusions in relation to the development of these sites are not based on sound evidence. This problem is compounded as this "reduction" in traffic has been applied to other junctions across the Borough, again meaning that the decisions may have been based on unsound evidence.
We note that the Council proposes to help mitigate the traffic problems by issuing travel packs to the over 50s. We do not think that this will provide any realistic help to the problem.

The failure to address these difficulties at this stage with meaningful and definite mitigation policies will result in poor planning for the future, and is clearly the reason why the NPPF requires them to be included in local plans.

Infrastructure

The plan does not properly address future infrastructure needs. The evidence indicates that current health and education services do not have capacity to meet future demand, but there are no plans to address the shortfall. As stated above, the NPPF states that infrastructure needs should be addressed as part of the plan together with plans on how the needs are dealt with. It is insufficient to state that they will be considered in the future.

The Plan identifies the need for additional capacity in schools by expanding existing schools and possibly building new schools. The Plan proposes the building of a Primary School on the land North of Shenfield (R03). However, with primary schools already at a capacity within the area and unable to meet current needs it is hard to see how one primary school on a site with a proposed 825 homes can continue to meet the local requirements. Consequently, people will need to drive to reach schools further afield thereby exacerbating the traffic situation. Again, this is a failure to provide sustainable solutions to town development and does not meet the requirements for a local Plan set out in the NPPF.

Greenbelt versus Greenfield

The Plan puts great emphasis on preserving greenbelt land, which is valued by the community. However, greenfield sites within urban developments are also valued by the community. Such sites are increasingly rare, much more so than the greenbelt land. Surveys undertaken by the Council show that the residents value the "green" environment of the town and want to protect the nature of the town.

The Plan refers to the need to preserve "green highways", and these sites form part of undeveloped land separating the towns of Brentwood and Shenfield, which is one of the Council's objectives. We consider that, where possible the Council should try to preserve greenfield land within town centres.

Evidence base

The Plan consistently refers to requiring evidence, but evidence is frequently lacking to support the inclusion of certain conclusions and site allocations. Further, evidence has been supplied by residents that demonstrate significant difficulties with some sites, but the evidence has not been included or addressed.

Land off Priests Lane - (R19)

Evidence based assessment

We have included a supporting document that PLNRA prepared with detailed evidence supporting our objection. This was provided to the Council in 2017 as evidence supporting the community objection to the 2016 LDP (as requested by the Council leadership). This evidence continues to be valid, although it has not been reflected in the latest plan, nor in the summary of responses to the last consultation.

We are disappointed that there is no reference to the very large number of objections, nor the issues raised in those objections. We cannot consider the site assessment to be robust where detailed objections and evidence has not been properly addressed.

The Plan recognises that the original housing density was far too large for the area, and the density has been reduced. We note that it still exceeds the average housing density of the neighbourhood, despite this being one of the Council criteria in reviewing site allocations. The Council provides no evidence to support the number of houses on the site, nor why it exceeds the average housing density in the area.

The current plan fails to indicate that the housing is to be specified as for the over 50s, this aside, it is hard to see how being designated as housing for the over 50s will be of any consequence. The over 50s will still drive which will not mitigate the already dire traffic situation and they will still somehow have to access the site, so our argument over site access is still relevant. The inclusion of a care home within the housing number may, on face value seem reasonable, but a care home brings different issues such as an increase in traffic at all time of day and larger vehicles requiring access to the site, together with the requirement for access for emergency vehicles at all times. The Council have also told us that this is advisory only, and cannot be enforced during the planning proposal stage. It is hard to see that any developer will be happy building a care home and a reduced number of houses as this will potentially not be an economically viable proposition for them.

Protected Open Urban Space

The site is currently a Protected Open Urban Space. The land was previously used as school playing fields, as well as being used by local football clubs, which continued after the grounds ceased being used by the school, until fees became too expensive for local clubs to use. This site was recognised in the 2005 open spaces audit as having value to the community as an open urban space, despite the land not being used. The report in 2016 does not address in any depth the existing open spaces, nor provide an assessment of the value (although the lack of public access is noted in the Plan site allocation). The report indicates that although the Borough has some good provision of sports facilities, there is a high demand for quality facilities, which are not always available. The report does not conclude that there is a surplus of open spaces. This site is attributed a low value as open space because it is not open to the public. PPG17 advises that sites can have value despite no public access.

Further, the Open Spaces Strategy report (2005) 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. We note that the 2016 LDP recommended keeping part of the land for open space and available for community. However, this has been removed at the request for the land owner. It seems reasonable, and in line with available evidence, that the Council should seek to obtain some retention of open space for the benefit of the community in the event the land is released for residential development.

Sport England objected to the allocation of this land for housing development, as the Council had not provided evidence that the land was surplus to needs, regardless of their current use, and so was not in accordance with NPPF guidelines (para 74). The Essex Playing Fields association also objected to the sites' inclusion.

The Plan stresses the need for "green highways" and the importance of separation of the urban environments. This site forms part of a stretch of undeveloped land linking green belt land separating the conurbations of Brentwood and Shenfield and is possibly of more strategic value to the community than some Green Belt land.

Infrastructure

The site is adjacent to two schools, both of which have limited land resources. Hogarth School recently expanded into their limited grounds (the school has reached the maximum ratio of buildings to land so that further development is not possible without additional land resources being made available). Endeavour School has already noted a need for land to support much needed expansion and the Plan recognises that it will need land to expand to meet educational needs.
We consider that the Plan incorrectly concludes that there is sufficient provision of education places at the nearby schools. The data indicates that there is no surplus capacity at local secondary schools. It also indicates that there are surplus places available at Hogarth Primary School, but we consider that the data analysis is flawed as it does not seem to take into account the staggered pupil in-take, and that there are no surplus places.

The NPPF states quite clearly that Local Plans should "positively plan" for infrastructure needs. Although Brentwood Borough Council may be a commissioner of education, rather than a provider, it should be working with the providers to have a positive plan to meet future needs. This element is missing from the Plan.

We consider that it is important that the Plan provides a more robust approach to meet the educational needs of an expanded population. The Council should provide evidence that these historic playing fields next to two schools will not be needed for educational infrastructure, and so are surplus to the Borough's needs, before they are released for residential development.

In addition, the Plan is silent on the provision of healthcare, but there are legitimate concerns raised by the residents about the inability of GP surgeries to meet existing healthcare needs. The data in the Plan shows that the ratio of doctors to Brentwood and Shenfield residents is worse than the national average. The Priests Lane neighbourhood is poorly served by GP surgeries in the area, and there is no potential for new surgeries.

Road Safety concerns

There were significant numbers of objections raised relating to traffic concerns. Priests Lane is an important part of the distributary network within the Brentwood/Shenfield area; as such it sees large volumes of traffic at peak times.

There have been a number of traffic accidents along Priests Lane between the two proposed access points including at least two incidents where cars mounted and crossed the pedestrian path. In addition, there have been accidents nearer the Middleton Hall Road junction involving serious injury to pedestrians.

The road is a main through route from Shenfield to access the A128, which will be the main access to the employment centres along the A127 corridor. It is reasonable to assume that the large housing developments north of Shenfield (such as Officers Meadow) will result in significant traffic using the road.

We are concerned that the increased level of traffic using the road, particularly at peak times, combined with new traffic from this proposed residential development will be unacceptably detrimental to the residents' amenity. It should be noted that due to the narrowness of the road, it can be difficult and dangerous to exit driveways in busy periods as turning out of driveways requires the road to be clear in both directions. This is particularly difficult for residents on the even-numbered side where visibility is poor and there are no pavements.

The road is ill-designed to cope with large volumes of traffic; it is residential, winding and narrow, in places less than 5.5m wide. Road design guidelines state that a road of this nature in an urban development should be at least 6m wide. Further, sites at R19 are located where part of the road has a single pavement only, which is often less than the recommended 2m wide.

We have previously provided evidence that the original proposed access road and junction were poorly sited, with poor visibility, and would not meet the recommended dimensions for safe road junction design. We note that the Plan now proposes to consider Bishop Walk as an alternative or supplementary access, and therefore assume that our concerns are accepted.

However, we consider that proposing an additional access point at Bishop Walk does not answer the original objections. The lack of visibility of a junction at no. 61A will not be altered, and therefore this junction is still not viable as a safe exit from the site. In addition, Priests Lane is narrow at this point with private driveways immediately opposite and in close proximity to Glanthams Road, which would create an undesirable left-right staggered junction, and suggests that any junction at this point would not be viable.

In this case, Bishop Walk would be the only access to/from this site. The road is very narrow being 4.8m wide with pavements of 1.5m wide either side. This is less than recommended widths (which are minimum 5.5m and 2m respectively). There is no possibility to widen the road. In addition, while the visibility is better than at no. 61A, the sight splays were designed at the minimum size for the development of the small cul-de-sac. The road was not designed to cater to the size of development proposed, and using it as an access would be to the detriment of existing residents. Indeed, during the planning application for Bishop Walk, objections were raised about traffic safety and the Highways Agency raised concerns. The plan was only approved after the length of the road (Bishop Walk) was reduced and the number of houses reduced from 8 to 5.

Further, as a result of the road being very narrow, there will be problems with cars turning into the road from Priests Lane while traffic is waiting to exit Bishop Walk. This could cause problems with traffic flows, particularly in the mornings when traffic often queues past this junction. Similar difficulties can be seen at Shenfield Crescent, which is a wider road than Bishop Walk.

It should also be noted that approximately 100m from the junction is an access to the Hogarth School playing field (the Council has a vehicular right of access at this point) and has historically been used by parents to access the school. This can help to alleviate traffic using Shenfield Crescent, which is getting worse with the expansion of Hogarth School. The proposal to use this road as an access for building traffic and for a new large residential development could create safety risks, as well as increasing traffic using Shenfield Crescent to access Hogarth School.

We consider that it is disappointing that the Highways survey will not be available as part of the consultation, nor even that one has been requested. This is a critical piece of work in respect to this site, and should be open to scrutiny as part of the consultation process. The only report available at this time is the analysis of major junctions. However, the NPPF states that travel assessments should be undertaken as part of a local Plan, which should look at the cumulative effect of new development on traffic flows, congestion and pollution.

We consider that the existing Highways report on critical junctions is flawed in respect to the Priests Lane site, please see our comments above. We consider that the original report is more reliable than the updated version, and it concluded that the junction is already saturated, and at the peak morning time is already overcapacity. All models indicated that the junction would perform significantly worse after development. But, residents will agree that the traffic queuing along Priests Lane to access this junction exceeds the traffic queuing in Middleton Hall Lane, and so should have been considered as part of this analysis.

In summary, we consider that the junction analysis materially understates the level of traffic accessing this junction, and the true situation is much worse. Previous traffic analysis has not provided any ways of mitigating the traffic difficulties at this point, and the Plan fails to provide the appropriate travel and transport assessments or management strategies.

The evidential objection document "Objections to Priests Lane Development Plans" is attached and forms part of this response.

The land at Priests Lane (site Refs. 044 &178) should be removed from the Local Development Plan. [Site new ref R19].

1. Road access, The access to the sites can only be from Priests Lane through St, Andrews Place, Bishop Walk or the present track at 61a Priests Lane. Priests Lane already carries far more traffic than it is suited to being a narrow two lane road with blind curves and a sharp bend at the St, Andrews Place junction. There have been at least six major Road Traffic Accidents on this road in the past few years and the increase in traffic which the proposed development would generate would greatly exacerbate the danger of even more such incidents . The technical submissions of residents have shown that the present accesses to the sites are hazardous, in particular that at No. 61a which has an inadequate line of site in one direction and is almost opposite the junction with Glanthams road.
2. Pollution. In addition to the increase in the volume of traffic using Priests Lane, the development would also produce a very significant rise in the air pollution levels from car exhaust emissions in the vicinity. Such levels already exceed E.U.limits at the junction of Priests Lane and Middleton Hall Lane, due no doubt to the long traffic tail-backs which occur around this junction at peak times. The inevitable light pollution associated with such a housing development would illuminate what is at present a relatively dark area of night sky thus spoiling a facility regularly used by local amateur astronomers.
3. Local Services. Public Transport. At present there is no public transport such as a bus service in that part of Priests Lane at the proposed development site for very good reasons. That part of the lane can just allow two vehicles of the Range Rover type to pass in opposite directions in safety leaving no scope for anything wider such as a bus. The footpath which is only on one side of the lane is so narrow that pedestrians including mothers with babies in buggies are only inches away from the fast moving traffic.
4. Surface Flooding. At times of heavy rainfall which are not infrequent, Priests Lane, Middleton Hall Lane and St Andrews Place suffer surface flooding. At times of less heavy rainfall, parts of gardens adjoining the proposed development site can remain under water for several days due to the very poor surface drainage in the area. It is reported that some years ago when a previous development was under consideration the plan was abandoned as the site was deemed too wet for the purpose.
5. Environment. The proposed development will be detrimental to the character and appearance of the surrounding area and will occupy what is currently designated Protected Open Space.
For all the above reasons the development of Priests Lane sites 044 and 178 should be removed from the current Local Development Plan.

The transport assessment is inaccurate as it has excluded traffic along priest lane and was taken at times which excluded school traffic. Furthermore, the assessment does not factor in the Elizabeth Line and the impact that this will have on additional traffic in the future. The plan fails to address the safety of residents, any new road access are hazardous and have not been addressed. There is no evidence of improvements to help dilute traffic congestion. The Priest lane sites have been previously rejected as it was deemed a vulnerable open space. Nothing has been done to factor in the health consequences on the residents due to increased pollution/construction works. Priest lane has never been designed to act as a main network road, however, with these changes the fundamental object of the road will change.

NPPF Complaint: Local plans should address not only housing, but traffic concerns, healthcare and educational requests. Therefore, the review refers to traffic as a concern but no contingent plans have been put in place to mitigate concerns. No specific or robust argument has been made that a viable access point is possible. Lastly, there is no additional provisions put in pace for increased educational and health needs; the expansion of Hogarth School to meet correct demands and there is already a low level of gps per head.
Schools further away from the area will enhance traffic flow as they will now need to travel to the school.

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.

While the protection of the site and the removal of the proposed allocation from the local plan would be an acceptable solution, as an alternative, potential would exist for this objection to be addressed in accordance with paragraph 97 of the NPPF and Sport England's playing fields policy if the playing fields were acceptably replaced as a requirement of the site allocation policy. As the Council's playing pitch strategy has recently considered the matter and specifically recommended that the loss of the playing fields be mitigated through replacement playing field provision, a solution that would be acceptable would be for an appropriate financial contribution to be secured towards the delivery of replacement playing field provision either on new playing field sites or in enhancing existing playing fields nearby. This could be addressed through modifying the policy's development principles to make provision for replacement playing field provision to be a pre-requisite of the development.

To take this matter forward with a view to reaching a mutually agreeable solution in advance of the matter being considered at the local plan examination, the Council are urged to engage with Sport England to explore a potential solution.

Sport England objects to the allocation of Land at Priests Lane, Shenfield for residential development in the local plan.

The majority of the site (around 4 hectares) was used as Brentwood Ursuline School's detached playing fields in the past. When the school discontinued use of the site, the site was used by a local football club. Historic aerial photographs indicate that the site was marked out for a number of sports pitches.

The Council's new Playing Pitch Strategy (November 2018), which forms the local plan's current evidence base for sports facilities, has assessed community playing pitch needs in detail and has identified deficiencies in pitch provision especially for youth and mini football pitches and 3G artificial grass pitches. In response to the deficiencies identified in the strategy, the action plan in the document has specifically confirmed that the loss of this site should be mitigated by investment in replacement facilities elsewhere in the Borough. Furthermore, recommendation 5 of the strategy specifically refers to protecting the current level of football provision including sites that have been used for football in the past. The study has not identified that this playing field could be disposed of without mitigation because it is surplus to requirements.

The site allocation policy does not make reference to the playing fields and there are no development requirements for retaining or replacing the playing fields in accordance with Government policy or the Council's evidence base. As there is no supporting information to explain the Council's position on this matter or any specific policy requirements set out in the allocation, it has been interpreted that it is proposed that the site will be allocated for development without any provision being made to retain or replace the playing fields. This would not be justified by the Council's evidence base on playing pitch provision or by policy BE23 of the local plan which contains a presumption against development which would result in the loss of open space or sports facilities unless it can be demonstrated that alternative facilities will be provided. While reference is made to the provision of public open space being a development principle, it has been interpreted that this relates to public open space to support the residential development rather than provision to mitigate the loss of the playing fields.

The allocation would not accord with Government policy in the NPPF, especially paragraph 97, which specifically applies to proposals for developing playing fields. None of the three criteria in the policy would be applicable for the following reasons:

* It has not been demonstrated that the site is surplus to requirements as set out above;
* No replacement playing field provision is currently proposed as part of the site allocation;
* The allocation is for residential development and therefore would not represent alternative sport and recreation provision.

The allocation would also be contrary to Sport England's playing fields policy www.sportengland.org/playingfieldspolicy which is used by Sport England for assessing planning applications affecting playing fields where Sport England is a statutory consultee. This policy mirrors paragraph 97 of the NPPF and is given weight in the development management process due to Sport England's statutory consultee role. The proposal in its current form would not therefore be considered to meet the 'justified' or 'consistent with national policy' tests of soundness.

While the site may not be currently in use as a playing field, Sport England considers proposals for the development of such sites in the same way as playing fields that are in active use because development on them would permanently prevent such sites from being brought back into use. Even if the playing fields are no longer needed for use by the current owner (the Ursuline Sisters Brentwood CIO), this does not affect our position. Sport England's playing fields policy and the Government planning policy in the NPPF does not distinguish between public and private playing fields and whether playing fields are currently in use or not. It should be emphasised that Sport England's role is to safeguard playing fields for meeting the needs of current and future users. While this playing field may not be in active use at present, it may be required for meeting current or future community playing pitch needs. This is recognised in the Council's playing pitch strategy and explains why the strategy's action plan seeks mitigation in the form of investment on other playing field sites.

Amend Policy R19 A. b. as follows -
provision of a residential care home (around 40 bed scheme as part of the overall allocation)

3. Effective.

Policy R19 A. b. needs to be amended to be consistent with the wording provided in all other site allocation policies.

The site should be excluded or the number of houses reduced in line with planning criteria.

The site is unsuitable for the number of houses that have been proposed. The proposed main access has signifiant traffic safety risks and does not meet road design standards. This has been shown in the resident's technical evidence which has examined the site access and whether it conforms to the Essex Design Guide. The Council has no viable plans to mitigate the risk to road users and local residents. Previous developments along this road have been limited in numbers due to the safety risks of roads accessing Priests Lane.
It will create additional congestion and pollution along a route already suffering from traffic congestions and prone to traffic incidents.
The housing density is not in line with the surrounding area, contrary to the Council's stated policy and not in line with NPPF guidelines.
The development is likely to have a negative effect on surrounding properties with respect to drainage and utility supplies.

The site should be excluded or the house numbers significantly reduced.

The proposed number of houses at R19 is not sympathetic to the surrounding area. The road access onto Priests Lane has limited visibility and is likely to be unsafe according to evidence provided in line national guidelines. The road already has heavy congestion at peak times, and suffers from speeding traffic at other times. There have been a number of accidents along this road. This has been a Protected Open Urban Space being an ex-playing field, and is adjacent to two schools which already need space for development. Overdevelopment of the urban centre is undesirable. The Council has ignored representations from several groups including the local water authority, significant evidence and statistics from the Priests Lane Neighbourhood Residents Association, Sport England and has conveniently produced evidence that contradicts previous reports produced by the Council around open space and playing field provision. The traffic mitigation proposal to provide an information pack to residents is laughable. In my opinion the Leader of the Council has provided misleading and incorrect statements about the process of the consultation in an attempt to avoid dealing with the evidence provided by the residents.

The site should be excluded as inappropriate due to traffic problems and access risks, or the number of houses should be significantly reduced.

This site used to be a school playing field. Previous audits have recommended that this site should not be developed. The original proposal included leaving some of the land as open space for the community, and this was in line with recommendations by previous open space audits which said that the Council should try to increase public open space in this area. However, this was taken out at the request of the developer. It is a shame that the Council has ignored its own evidence.
Priests Lane already has a lot of traffic congestion, and the new roads will make his worse especially with the other new housing in Shenfield. There is only one narrow pavement for pedestrians and no room for a cycle path. It can be difficult to cross safely as the crossing points are on blind bends.
The Council has excluded other sites because of traffic congestion, to be consistent R19 should also be excluded due to congestion and traffic risk.

removal from LPD

Transport assessment was not representative or accurate - taken at times which excluded large proportion of typical school traffic.
Transport assessment didn't account for further development of 1000 houses elsewhere in Shenfield, travelling to / from A127 / Brentwood.
Road safety and design hasn't been addressed, with road design dangerous when under strain of increased traffic flow. Pedestrian safety with increased traffic flow has not been addressed.

Remove the site from the LDP.

Test of Soundness.

Summary:
Delivery forecast of 1-5 years is not feasible given previous representation 15459 from Thames Water (Mr Mark Matthews [6089]) who have "concerns over wastewater Services at this site. Specifically, the wastewater network capacity is unlikely to be able to support the demand anticipated from this development. ...It is important not to under estimate the time required to deliver necessary infrastructure. ...local network upgrades can take between 18months - 3 years to design and deliver".

Has this and other turnaround times been taken into account?

I question if this site meets the NPPF definition of "deliverable".

This site should be removed from the LDP.

Suggest that an updated Open Space Audit be conducted. I fully expect that this would result in retaining this Playing Field as a Protected Urban Open Space. This is pertinent given that 45.16% of the Green Belt Total (825/1827 net dwellings) is being met by Shenfield Village. This area will be in need of public open space/sports facility to meet identified need.

Also, brownfield land should be utilised first - see brownfield register link below. There are brownfields not included in the LDP. These should be prioritised as there's currently a failure to preserve "Protected Urban Open Spaces".

http://www.brentwood.gov.uk/index.php?cid=2838

Update development principles from:

provision for public open space;

to

include provision of open space and Sports facilities for public use.

This land has been originally used as playing fields, and is a protected urban open space.

Once lost, it's lost forever as use as a playing field, as previously represented by "Sport England".