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

Unsound:
I do not believe that a full evaluation of the environmental impact and traffic congestion has been carried out and that the evidence base is flawed due to data not being collected at busy times such as rush hour and school opening and closing times.
Priests Lane already gets very congested in the mornings and evenings as it is used as an access road by both immediate residents and people from surrounding areas. The building of 1,000 new dwellings in both Priests Lane and other nearby locations will add greatly to the congestion problem.
The Transport Assessment should have been made in Priests Lane at busy times as originally indicated by the Council.
The Plan does not fully recognize the safety of residents with new road accesses. The road is relatively narrow with a pavement only on one side. The road design is hazardous for increased traffic movements.
The planned site does not meet relevant sustainability conditions for access, transport network, mitigation of impact on local services and unacceptable effect on health due to increased pollution.
Previously the site has been rejected as it was thought to be a valuable open urban space.
No account seems to have been made of the increased pollution along Middleton Hall Lane and Priests Lane, with the junction of the two being especially congested and a pollution hotspot.
Priests Lane was never intended as a main distributary road, which it has now become. It does not comply with the Essex design guide with respect to road and pavement width. There is only a pavement on one side for most of the road and in parts the road is very narrow causing difficulties to passing vehicles.
NPPF Compliant:
Traffic concerns were identified in the sustainability review with no mitigation options being specified.
The viability of an access point has not been fully evaluated or explained.
There is no additional provision for increased educational and health needs.

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

Unsound:
I do not believe that a full evaluation of the environmental impact and traffic congestion has been carried out and that the evidence base is flawed due to data not being collected at busy times such as rush hour and school opening and closing times.
Priests Lane already gets very congested in the mornings and evenings as it is used as an access road by both immediate residents and people from surrounding areas. The building of 1,000 new dwellings in both Priests Lane and other nearby locations will add greatly to the congestion problem.
The Transport Assessment should have been made in Priests Lane at busy times as originally indicated by the Council.
The Plan does not fully recognize the safety of residents with new road accesses. The road is relatively narrow with a pavement only on one side. The road design is hazardous for increased traffic movements.
The planned site does not meet relevant sustainability conditions for access, transport network, mitigation of impact on local services and unacceptable effect on health due to increased pollution.
Previously the site has been rejected as it was thought to be a valuable open urban space.
No account seems to have been made of the increased pollution along Middleton Hall Lane and Priests Lane, with the junction of the two being especially congested and a pollution hotspot.
Priests Lane was never intended as a main distributary road, which it has now become. It does not comply with the Essex design guide with respect to road and pavement width. There is only a pavement on one side for most of the road and in parts the road is very narrow causing difficulties to passing vehicles.
NPPF Compliant:
Traffic concerns were identified in the sustainability review with no mitigation options being specified.
The viability of an access point has not been fully evaluated or explained.
There is no additional provision for increased educational and health needs.

I am writing with vehement objections to the proposed plan to build on Priests Lane , r.e chapter 9:site allocations Land at Priests Lane.
The local infrastructure simply cannot handle any more building. The local roads are already too congested , with both the roadways and pavements being in unsatisfactory condition. This will only be made worse during and after building.
The local doctors surgeries are bursting. If my children are ever ill , the waiting times are already far too long. The local schools are already increasing classroom sizes .
There are plenty of other reasons to object, but I feel those stated should suffice.
Regards

I am writing with vehement objections to the proposed plan to build on Priests Lane , r.e chapter 9:site allocations Land at Priests Lane.
The local infrastructure simply cannot handle any more building. The local roads are already too congested , with both the roadways and pavements being in unsatisfactory condition. This will only be made worse during and after building.
The local doctors surgeries are bursting. If my children are ever ill , the waiting times are already far too long. The local schools are already increasing classroom sizes .
There are plenty of other reasons to object, but I feel those stated should suffice.
Regards

I am writing with vehement objections to the proposed plan to build on Priests Lane , r.e chapter 9:site allocations Land at Priests Lane.
The local infrastructure simply cannot handle any more building. The local roads are already too congested , with both the roadways and pavements being in unsatisfactory condition. This will only be made worse during and after building.
The local doctors surgeries are bursting. If my children are ever ill , the waiting times are already far too long. The local schools are already increasing classroom sizes .
There are plenty of other reasons to object, but I feel those stated should suffice.
Regards

Removal of the Priests Lane sites from the plan.

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane sites

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane allocation.

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane allocation

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane allocation.

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane allocation.

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane allocation.

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane allocation.

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane allocation.

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

Removal of Priests Lane site.

It does not appear that many of the previous technical representations have been considered and acted upon. I am particularly aware that the Priests Lane Neighbourhood Residents Association has submitted many technical documents, none of which appear to have been reflected in the draft plan.
As far as development of the Priests Lane sites goes the plan does not meet NPPF guidelines and can be considered unsound for many reasons. Notably, there is only one potential access mentioned, the viability of which has been questioned most soundly via technical documentation presented by the Priests Lane Neighbourhood Residents Association indicating the speed of road users limits such an access at the proposed point and creates a hazard to pedestrians and motorists alike. There are three potential access routes to the sites although all must exit onto Priests Lane and all therefore face similar problems, although the proposed point has the added complication of being close to another junction. There is no infrastructure planning regarding the increased requirement for doctors, dentists school places and the suchlike.
The number of 75 houses was proposed without any assessment as to whether the area can withstand such a development. There has been no specific traffic assessment of Priests Lane itself nor of the junction of Priests Lane and Middleton Hall Lane.
More importantly the treatment of these sites is at odds with the treatment of other similar sites which have been excluded from the plan at the regulation 18 stage. There is an inconsistency with the site selection and many of the supporting documentation (for example the Transport Assessment) is flawed indicating a lack of robustness in the overall process, causing the plan itself to be unsound.
Outlined below in more detail are problems associated with the development of these sites which have not been mentioned in the plan and for which no mitigation has been suggested.
Air Quality
At peak times there is heavy congestion at the junction of Middleton Hall Lane and Priests Lane. The air pollution at this junction is a 'hot spot' for Brentwood. The top of Priests Lane is close to an Air Quality Management Area, so the additional traffic caused by any development will pass through this causing a further deterioration in the air quality.
The increase in traffic in the area not only from a development along Priests Lane but also due to the number of houses proposed for Shenfield and which will use Priests Lane as a conduit to the A127, A12, A128 and the M25 will significantly increase pollution in the area, causing significant health and safety issues which cannot then be combatted as an open urban area to assist in this will have been lost.
Biodiversity
The site has previously been designated as a protected open urban space and has been recognised as having value to the community. It is one of the few greenfield sites within the urban area separating Brentwood from Shenfield. It is important to retain it as such to maintain the quality of life within Brentwood, as green areas near the town centre are essential for health and well-being. Such areas also benefit the town by acting as a combatant against the increase in air pollution, which itself is exacerbated by the increase in vehicular traffic.
The sites have been visited by Essex Wildlife who have noted they provide a habitat to flora and fauna. Many birds such as woodpeckers, black caps and skylarks have been seen on the sites and in the gardens of homes around the area. The sites have been strategically mown to provide a flowering meadow in the springtime. There is significant evidence that they are a badger habitat and that these animals together with muntjac deer, foxes, shrews and voles regularly visit the sites together with houses along the Lane. There are also many mature trees such as Oriental Oak some of which are rare.
Clearly any development of this Greenfield site and the positive contribution the open space makes to Brentwood will be huge loss.
Community and Well-being
The infrastructure in this part of Brentwood is already struggling to cope with our current demands. The current medical facilities are at capacity as are the primary schools (Hogarth Primary School has already been expanded to cope with existing need and while it may be feasible to further expand, this will only cause a depletion of the school's playing field, something which Sport England will surely contest.) The introduction of a further 75 dwellings into the area will increase the requirement for both GP and dental surgeries neither of which are readily available. If the population of Brentwood is expected to increase, then schools will likely need to increase with a corresponding need for playing fields. To remove this Greenfield asset does not appear to be a sensible decision.
While the sites appear to be close to transport facilities, they are approximately a mile from the local amenities and about a mile from the local train stations. Priests Lane is not on any bus route and the Lane itself could not become a bus route due to its narrow nature in parts and the health and safety issue of pedestrians having to cross the road many times as there are not continuous pavements down each side.
Priests Lane is already well known for its traffic problems including (but not limited to):
* Heavy congestion in the mornings and evenings, with queuing traffic from the junction with Middleton Hall Lane at least as far as Glanthams Road, and sometimes further.
* Speeding traffic at off-peak times.
* Poor visibility for residents trying to access the roadway from junctions or side roads.
* Safety issues for residents trying to access the road from their own drives where there is no pavement and therefore no 'buffer zone.'
* Health and safety issues for pedestrians attempting to cross the road, often on bends where the pedestrian path swaps from one side to another;
* Traffic accidents due to speeding and/or errors from difficulties with visibility and the narrow road.
* Lorries and wagons having to mount the kerb in some places to pass each other due to the narrowness of the road.
It is not yet clear where site access will be. The Priests Lane Residents Association have put together a very detailed road analysis outlining why the proposed access from the sites onto Priests Lane is unsafe, which is such a major health and safety issue. The position of all potential access turnings, combined with the heavy volume and fast travelling traffic, could make any site access difficult
The people living in any new development are likely to have at least one car per household (and in Brentwood this will often be more than one car per household) and due to the lack of available public transport, and despite encouragement to use alternative methods of travel, will regularly drive. Increasing the traffic volumes will worsen these problems, and so have an adverse effect on both the residents and other users of the road, with relation to safety and air quality.
Flooding, Waste and General Infrastructure
The land in this area can be very wet and indeed, I understand that development of this site was discussed many years ago but not taken forward due to advice that the land was too wet to develop. Current information suggests that the drainage and sewerage network is running at full capacity. Following heavy rainfall there are areas of Priests Lane and Middleton Hall Lane which experience surface flooding indicating that the drainage in the area is already struggling to cope. The open site currently absorbs water that would otherwise drain into the back gardens on Priests Lane or onto the railway, indeed, I am aware that some homes backing onto the site already experience pools forming in their gardens.
With the sewerage in the area operating at maximum capacity and may well already be exceeding capacity any development will put further strain on these facilities.
The area is well known for problems with gas leaks, fluctuations with electricity supply and poor water pressure. In addition, the various utility companies have indicated that the supply lines are in some state of disrepair and are constantly having to be regularly maintained. Most recently the whole of the road surface of Priests Lane was replaced and, due to the constant use, is already breaking up. The addition of further dwellings requiring access to an already strained utility grid can only result in further disruption of Priests Lane itself and compromise the service that residents receive, not to mention the damage done by construction vehicles during the actual building on the site.
General
I am aware that Sport England objected against development of the site on the grounds that it is the loss of a site which was previously used as a playing field and may well be again. With the open spaces report indicating that Shenfield is in short supply of such areas it does not seem logical in this day and age where we are attempting to fight child obesity that a potential playing field site is lost.
For all of the above reasons and for the fact that the 'evidence-based plan' does not actually have any robust evidence on which to develop the Priests Lane sites the soundness of the plan must be questioned.

It is recommended that criteria A- Amount and type of development be changed to increase numbers and wording to "provision for around 100 new homes of mixed size and type including affordable housing".

We support the strategic objectives of the Local Plan as set out in paragraphs 3.15-3.19 this particular submission is in relation to the specific housing site allocation R19-Land at Priests Lane, Shenfield. It has been a site of continued discussion and cooperation with the Local Authority since the last Local Plan review and publication of the Brentwood Replacement Plan 2005.
It is open land currently given the designation of Protected Urban Open Space. It was land associated with use by The Ursuline School and handed back to the Sisters as too remote from the school in 2000 when it had then generally only been used on a limited basis for summer athletics and sports day. That use is now shared with Brentwood School and its athletics track facility. At the last Local Plan review the Inspector acknowledged that the site had no public amenity contribution but the Local Authority were awaiting the results of their leisure audit. The Sport Leisure and Open Space Assessment final report August 2016 and related appendices for protected urban space identifies the site ID as 40 with limited or no public accessibility, no recreational value and low scoring as amenity value.
The Sustainability Appraisal supports the site as one of the most sustainable potential development sites within the Borough. We support Policy R19: Land at Priests Lane but as one of the most recognized sustainable sites consider within the policy that it is too restrictive. The evidence base had shown that the site was capable of accommodating some 130 homes which had originally been brought forward in consultation on an earlier version of the Plan. This had been reduced to 95 in the light of unfounded local objection in relation to highway and traffic congestion. We had provided the potential indicative masterplan layout that addressed drainage and responded to objections and showed approximately 95 dwellings attached. As highlighted below it is one of the few sites that can deliver housing immediately and within the first two-three years of the Local Plan. It is within walking distance of Brentwood town centre and walking distance of Shenfield station. It is close to a wide choice of schools both Education Authority and private. The site itself has no physical constraints and no ecological issues. In accordance with the NPPF it is exactly the sort of site that should comply with NPPF policies making effective use of land and achieving appropriate densities as well as ensuring delivery of a sufficient supply of homes. (NPPF Chapters 11 and 5).
The highway evidence base has shown it is capable of delivering up to 130 dwellings. The Local Planning Authority had on the 8th November an Extraordinary Planning Committee Meeting to review the recommended planning strategy and Draft Local Plan document to proceed to the final stage of the Local Plan Review seeking authority to publish the Regulation 19 pre-submission document. There are other policies within the Plan on which the Ursuline Sisters should be making some comment but I will deal with those as a separate paper.
Chapter 3 Spatial Strategy Vision and Strategic Objectives
Draft Policy SP01: Sustainable Development is such that it can be seen that the Priests Lane land will fall directly in accordance with that Policy. Chapter 5 is under title the 'Resilient Built Environment'. It is explained in Paragraphs 5.1 to 5.7 that design and layout of our built environment provides for opportunities to live a healthy lifestyle and draws on key paragraphs in relation to this within the NPPF and in relation to climate change. Part of that Chapter relates to transport and connectivity. Reference is made to Policy BE11: Strategic Transport Infrastructure. Part of that policy is maximising the value of railway connectivity and Elizabeth Line (Cross Rail) and addresses the need to improve pedestrian and cycle infrastructure. I draw briefly on sub-criteria (b):
"Development in proximity to the railway stations will demonstrate how the schemes connect to the surrounding walking, cycling and public transport links to the station. The proposed schemes must offer direct routes as well as easy effective orientation and navigation to the stations".
The policy highlights that developments close to schools and early years and child care facilities should seek to encourage walking and cycling to address the impacts of school run traffic. This is recognised by ourselves and Officers and in their selection of the Priests Lane site as part of their housing delivery.
Site Allocations
I comment further on the delivery which is seen within other Council evidence base documentation. Delivery in early years of the Plan, i.e. 21-23 is very important as it is one of the few sites where this can be assured and has been a main plank of our submissions to the LPA. Part of the housing evidence base has shown that the LPA currently does not have a 5-year housing supply and that this will continue during the early part of the Plan. Thus, the position remains that there must be substantial and demonstrable harm to refuse any planning application even where such application was submitted at an early date.
Highways Traffic Congestion
The general text paragraph 9.172 refers to the main vehicular access from Priests Lane and its expectations to mitigate likely impacts on the performance on the local strategic road network. Paragraph 9.173, opportunities to create improved pedestrian and cycle connections are expected to be provided within the site and to the wider area. These have already been discussed with the LPA, including speed control platforms and safer pedestrian crossing points close to the site entrance to provide a good and easy pedestrian access along Worrin Road into Shenfield rather than just using Priests Lane.
The general text Paragraph 9.174 expects residential travel information packs which should be produced in consultation with the Highway Authority. This is a standard requirement for major new developments and is straightforward to provide, in the context of this development.
Agreement has been reached with Endeavour School, a special needs school. Appendix 1 Local Development Plan Housing Trajectory The Plan identifies the approximate housing delivery over the Plan Period. It is highlighted that page 310 shows the site as being at the fore front of housing delivery.
Appendix 2
Provides the plans for residential-led site allocations identified on Page 315 R19 Land at Priests Lane, Shenfield. The Site Allocation Plan at page 335 treat the land comprehensively with part Endeavour School land and land adjacent to Bishops Walk.
PART 2: SUSTAINABILITY APPRAISAL
The Sustainability Appraisal supports the Brentwood Local Plan and as a document sets out the various strategies that have been considered for delivery of the necessary housing employment and infrastructure needs of Brentwood.
Following the 8th November 2018 Extraordinary Council Meeting, the document sets out some even options which centred around delivery of West Horndon East, West Dunton Hills Garden Village and Brentwood Urban Centre. The focus and overall conclusion is development on the A127 Corridor and the strategy involving DHGV Option 3. In these comments I concentrate on the housing delivery and reference to Priests Lane. Table 8.2, Page 46, refers to the proposed housing allocations and land at
Priests Lane, Shenfield, Page 47.
Paragraph 9.2.4, Page 49, the statement is made with regards to the 8th November 2018 decision to delete Honeypot Lane and reduce the quantum of homes at Priests Lane by 20 homes (there was also a reduction at Priests Lane between the 2016 Draft Plan and the 2018 Preferred Allocations Stages).
This is supported from an air quality perspective .....
Attention is drawn to the text at Paragraph 9.2.10 appraisal of the proposed submission plan refers to the Draft Plan (2016 appraisal) highlighting some concerns but concluded no significant effects .....On balance, significant negative effects are not predicted at the current time. However, there is considerable uncertainty, with growth at the main urban area and elsewhere set to increase traffic congestion in the AQMAs .....
Under the heading of 'Biodiversity' and commentary from the Spacial Strategy, Paragraph 9.3.2, the Preferred Allocations Consultation document then proposed a notably increased focus of growth at the main urban area, before the decision was taken to reduce the focus of growth at the 8th November Extraordinary Council Meeting (see discussion in 5.5).
Similar comments continue under the sub-heading of Climate Change Mitigation, Section 9.4. Section 9.9 Housing It explains that the proposed housing land supply proposes to be monitored against a housing trajectory that involves provision for 456 dpa on average across the 17 year Plan Period. There will be a stepped trajectory involving a monitoring target of 310 dpa for the period to 2023 and for the period thereafter to 2033, 584 dpa. However, there is a recognised Local Housing Need (LHN of at least 350 dpa). The Sustainability Appraisal sets out that for the strategy they are adopting, there is a continued risk of slippage. The conclusions on the emerging Draft Plan, as a whole, recognise that there is a risk against updated housing figures that LHN could increase to a figure as high as 454 dpa (Paragraph 9.9.10).
It is helpful to note that in considering landscape, Section 9.10, the comment:
"Decisions taken at the 8th November Extraordinary Council Meeting - the decision to reduce the quantum of homes at the Priests Lane site is not supported from a landscape perspective recognising that this site falls outside the green belt and within the defined settlement boundary"
I turn to the Climate Change Mitigation and Community and Well-Being Section within Appendix 2 context and Baseline Review.
Under the sub-heading of Community and Well Being, there is reference to the Brentwood Borough Sport, Leisure and Open Space Assessment 2015, highlights there are relatively good levels of access to green space and sports provision ...... A review of that document has established that the Priests Lane site is of limited value to such leisure provision and, in particular, sports playing field provision.
Policy Amendment
The general thrust of Policy R19 is supported. It is recommended that criteria A Amount and type of development be changed to increase numbers and wording to provision for around 100 new homes of mixed size and type including affordable housing.
The Plan is unsound with respect to Policy R19 for the reasons set out above. The subject housing site is in a highly sustainable location and the evidence base does not conclude that it is not able to take anything more than 75 houses. We have set out that it should include for more housing. It is only political expediency that had reduced the numbers of housing.
The amendment to Policy R19 will achieve the policy requirements of the NPPF to make the most efficient use of land and to deliver a sufficient supply of homes. This is an important housing site capable of delivering a small but significant number of houses in the early part of the plan period.
Policy Amendment
It is recommended that criteria A Amount and type of development be changed to increase numbers and wording to: "provision for around 100 new homes of mixed size and type including affordable housing".
It is an important policy for one of the most sustainable sites within the Borough Plan, it is anticipated that there will be a large number of objections and the arguments in favour are many which would best be promoted orally.

Remove Priests Lane from plan

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

I would like to add my objection to the inclusion of the Priests Lane site in the Local Development Plan for several reasons, most significantly road safety, traffic congestion, air pollution, site access and the loss of a Protected Urban Space.

These reasons and more have been fully investigated by the PLNRA who have supplied the council with detailed information to back up the arguments against developing this site but this information seems to have been ignored.

The LDP includes a number of features which are simply a work of fiction, for instance, the idea of a cycle path has been cut and pasted on numerous sites but Priests Lane is far too narrow to allow pavement on both sides of the road in some places and there is no room for a cycle path.

The traffic in Priests Lane is either backed up at rush hour or a dangerous rat run at other times, there have been numerous accidents along the road and there doesn't seem to be any provision in the plan to cope with an increase in traffic from various new housing in the area as well as the proposed development in Priests Lane. Air pollution in the area is already an issue, particularly at the junction of Priests Lane and Middleton Hall Lane and the junction of Middleton Hall Lane and the A128 Ingrave Road, and will only be made worse by the proposed development.

The plan has suggested that some of the housing should be allocated for the over 50's. This is meant to be a strategy to help reduce the amount of traffic flowing onto Priests Lane at peak times but fails to consider that the retirement age is now 67. In the case of a nursing home, there will still be staff and visitors coming and going throughout the day. But even if this type of housing were to be approved, it is merely a suggested use of the site and it cannot be guaranteed.

The PLNRA has given the Council detailed technical evidence clearly showing that the access from Priests Lane to the site does not meet road design guidelines and is unsafe. This issue has not been addressed in the LDP, in fact it has been completely ignored. Without a viable means of access, the site is not capable of being delivered and so should be removed from the DLP.

Using the site would be a failure to preserve a Protected Open Urban Space. It was previously used as a school playing field. There are two schools backing onto the site and both will require land to expand onto in the future and once this site is developed it is lost forever. The area still requires room for other uses, not just housing. Building housing on every plot available does not allow for expansion of the schools, it doesn't allow for additional services to be added to the area.
In their submission the PLNRA concluded:-

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.

I support the PLNRA in its request to participate in the oral stage of the EiP and would ask the Council to review all of the information that has been compiled and submitted by the PLNRA, since much time and effort has gone into thoroughly investigating all the issues involved in this proposed development.

Remove priests Lane from plan

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

I would like to add my objection to the inclusion of the Priests Lane site in the Local Development Plan for several reasons, most significantly road safety, traffic congestion, air pollution, site access and the loss of a Protected Urban Space.

These reasons and more have been fully investigated by the PLNRA who have supplied the council with detailed information to back up the arguments against developing this site but this information seems to have been ignored.

The LDP includes a number of features which are simply a work of fiction, for instance, the idea of a cycle path has been cut and pasted on numerous sites but Priests Lane is far too narrow to allow pavement on both sides of the road in some places and there is no room for a cycle path.

The traffic in Priests Lane is either backed up at rush hour or a dangerous rat run at other times, there have been numerous accidents along the road and there doesn't seem to be any provision in the plan to cope with an increase in traffic from various new housing in the area as well as the proposed development in Priests Lane. Air pollution in the area is already an issue, particularly at the junction of Priests Lane and Middleton Hall Lane and the junction of Middleton Hall Lane and the A128 Ingrave Road, and will only be made worse by the proposed development.

The plan has suggested that some of the housing should be allocated for the over 50's. This is meant to be a strategy to help reduce the amount of traffic flowing onto Priests Lane at peak times but fails to consider that the retirement age is now 67. In the case of a nursing home, there will still be staff and visitors coming and going throughout the day. But even if this type of housing were to be approved, it is merely a suggested use of the site and it cannot be guaranteed.

The PLNRA has given the Council detailed technical evidence clearly showing that the access from Priests Lane to the site does not meet road design guidelines and is unsafe. This issue has not been addressed in the LDP, in fact it has been completely ignored. Without a viable means of access, the site is not capable of being delivered and so should be removed from the DLP.

Using the site would be a failure to preserve a Protected Open Urban Space. It was previously used as a school playing field. There are two schools backing onto the site and both will require land to expand onto in the future and once this site is developed it is lost forever. The area still requires room for other uses, not just housing. Building housing on every plot available does not allow for expansion of the schools, it doesn't allow for additional services to be added to the area.
In their submission the PLNRA concluded:-

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.

I support the PLNRA in its request to participate in the oral stage of the EiP and would ask the Council to review all of the information that has been compiled and submitted by the PLNRA, since much time and effort has gone into thoroughly investigating all the issues involved in this proposed development.

I would prefer is this site excluded from the Plan, but if it continues to be in the Plan then think the Council should reduce the number of houses. They should also show how they will deal with the traffic risks, and show that the new roads will be safe. If they cannot, then the site should fail the tests and be excluded.

I object to the proposed development at R19, land at Priests Lane. All the traffic from this site has to turn onto Priests Lane. I regularly walk along Priests Lane at peak time and there are usually long traffic queues waiting for the lights at Ingrave Road, which produces a lot of pollution. There is only one pavement and it is quite narrow. The road is also narrow and the cars pass very close to pedestrians. There have been some car accidents along this road and I am worried about the risks. I would not feel safe cycling along this road.
The report on the cross road done by the Council has ignored all the Priests Lane traffic. The traffic count used for the junction was done in the summer when study leave had started for GCSEs and A levels, but this was not a good time to measure traffic because a lot of the traffic is caused by the schools. The Council says that they will try to reduce school traffic, but I do not think that it will work because a lot of school children get driven to school, and it doesn't work for Brentwood School which has car parks for dropping students. I do not think that a travel plan will stop people from driving into town.
I think that the number of houses for the site is too large and does not seem to be based on what fits in with the surroundings.
I do not think the Council has used a sound basis for including this site for this number of houses.
I would prefer is this site excluded from the Plan, but if it continues to be in the Plan then think the Council should reduce the number of houses. They should also show how they will deal with the traffic risks, and show that the new roads will be safe. If they cannot, then the site should fail the tests and be excluded.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

Changes to Plan:
ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.

ADD Paragraph 9.176A: "Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."

This policy relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and178 (Land off Bishop Walk, 0.6 Ha). These are both in separate ownership, and circumstances relating to each site are different.

However, these have been merged in the Plan so that the large-site planning policies relevant to site 044 have been applied to the much smaller and entirely separate development of (say) 10 to 12 houses on site 178.

Re policy A (a): A mixture of house sizes, types and affordable housing may well be appropriate when spread across a large development on the 4.5 Ha Ursuline fields, but any development on Site 178 would normally just be classed as a small development, free of such planning restrictions. Development on Site 178 would be a continuation of the existing housing in Bishop Walk, which are 4/5 bed high value houses in large plots, and so it would be more appropriate and important to maintain the "special character of the surrounding area" on this site.

Re policy A (b): This policy relates solely to Site 044. Site 178 is too small for a care home.

Re policy B (a): Site 178 already has direct access off Bishop Walk, a residential Type 4a Minor Access Road with an existing junction to Priest's Lane with 4.5m x 90m sight lines, all in accordance with Essex Highways Standards. As far as the NPPF 2018 is concerned, some traffic impact on the road network is to be expected, and refusal should only be when this is severe. With the limited number of houses proposed on Site 178, the effect would be negligible. Instead, the mitigation measures mooted at paragraph 9.172 relate solely to the new access road that will be required further down Priests' Lane for the large development on Site 044. This only has 45 m forward visibility and so traffic calming measures, such as a raised traffic table at the junction with Glantham's Close, have been suggested.

Re policy B (b): This policy also relates solely to Site 044. Site 178 has never had public access, and in any event the site is too small to make a meaningful contribution. Instead, significant public open space has been proposed for dog-walking and play on the playing fields Site 044.

Re policy B (c): This would require negotiation with third parties and so could result in a ransom situation.

Re policy B (d): The Endeavour School borders Site 044 as well as Site 178 (N.B. The R19 plan on page 335 of the Local Plan is incorrectly drawn). It is understood that the owners of site 044 are willing to provide land as necessary and so this should not be a restriction on Site 178.

Re policy C (a): This policy relates to Site 044. Site 178 lies within Flood Zone 1 (not subject to flooding and therefore a preferred location for development under the NPPF sequential test). Site 044 borders railway land, which is subject to flooding, and being larger than 1 Ha the development there could well have an impact.

Refer to Site Plan on following page:-
Plan to show Site ref 178, Land off Bishop Walk

Modification:

ADD Paragraph 9.176A

"Policy R19 relates to two adjoining sites, HELAA refs 044 (Land off Priests' Lane - former Ursuline Playing Fields, 4.5 Ha) and 178 (Land off Bishop Walk, 0.6 Ha). The large-site planning policies outlined above are only applicable to Site 044 and should not delay a smaller scale housing development on Site 178."


Reason:

It is important that housing development can take place at the earliest opportunity in order to meet the Council's target for year 5 (15 houses on this site in years 2020/2021). Policy R19 is unnecessarily restrictive with regard to Site 178 as it would rely on successful negotiations with third parties in order to meet deadlines. Site 044 is expected to be developed over a longer time-frame than Site 178.

As landowner, I can provide detailed responses in relation to Site 178.