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.

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

Unsound.
The evidence base is flawed.
The lane was never meant to be a main distributary road which it has now become. As such it does not comply with the Essex Design Guide with respect to road and pavement width.
The secondary access roads to the site also do not comply with line of site rules. Notably St Andrews place junction with Priests Lane.
The land at Priests Lane should be removed from the Local Development Plan.

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

The Plan is unsound as the evidence is follows: 1. The transport Assessment is unaccurate as it did not include traffic along Priest Lane. The Assessment was taken at times when a large portion of school traffic was excluded. It did not assess potential access points which are hazardous. 2. The transport Assessment did include the future increase in traffic from the 1000 new homes planned in Shenfield, and the users of the Elizabeth line. 3. The plan fails to address the safety of residents and all road users. At present the road is unsafe. There are two narrow pinch points in the road where it is below the recommended width. There is a narrow pavement which is only along one side, pedestrians must cross at hazardous places to walk along the road. Residents have provided details of many accidents along Priests Lane. 4. The site does not meet relevant sustainability conditions, those of access, transport network, mitigation of the impact of local services and the detrimental effect on health due to the increase in pollution. The junction of Priets Lane and Middleton Hall Lane are at present a pollution hot spot. 5. Previously the site has been rejected for development as the open urban space was valued as an amenity, a green lung for the area. 6. The historic country lane was not designed to be a major through road carrying over 6,000 vehicles daily. It does not comply wit the Essex Design Guide with respect to both road and pavement width. NPPF compliant: Local Plans should address not only housing but traffic concerns, healthcare an education needs. 1. Potential access roads have not been assessed for safety and impact on the present residents. 2. The sustainability review refers to traffic as a concern, but there are no plans to deal with this issue. 3. There are no plans to meet the increase in educational and health service needs. Hogarth school expanding to meet existing needs of central Brentwood.

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

Unsound: The evidence base is flawed: 1. The Transport Assessment is inaccurate as it has excluded traffic along Priests Lane, and was taken at a times which excluded a large proportion of school traffic, despite Council assurances that a traffic assessment would be done for Priests Lane. 2. The Transport Assessment does not account for the increased usage of Priests Lane from the proposed development of 1,000 houses in Shenfield travelling to the A127, nor does it account for the impact of the Elizabeth Line. 3. The Plan fails to address safety of residents: the technical submissions of residents that new road accesses along Priests Lane are hazardous have not been addressed, nor concerns that the road design is dangerous for increased traffic movements. 4. The site does not meet relevant sustainability conditions, notably access, transport network, mitigation of impact on local services, and unacceptable effect on health due to increased pollution. 5. The Priests Land sites have been rejected previously because the land was deemed a valuable open urban space. 6. No account has been made of the increased pollution along Middleton Hall Lane and Priests Lane, the junction of which is a pollution hotspot. The Lane was never meant to be a main distributary road which it has now become. Residents have pointed out that as such it does not comply with the Essex Design Guide with respect to road and pavement width. NPPF Compliant: Local Plans should address not only housing but traffic concerns, healthcare and education needs. 1. The sustainability review refers to traffic as a concern, but no mitigation options have been identified. 2. No specific or robust argument has been made that a viable access point is possible. 3. When consideration against reasonable alternatives these sites can not be deemed justified and there is nowehere in the plan which allows for the enhancement of infrastructure as a result of development. 4. There is no additional provision for increased educational and health needs, the expansion of Hogarth School is to meet current demands and there is already a low level of GP per head. Schools further afield which may have space will required a car journey to attend, exacerbating the already dire traffic situation.

The land at Priests Lane should be removed from the local development plan. Doing this will make the local plan sound as it will negate all the issues that have described in question 5.

The plan is not sound. All transport assessments were take at times devoid of school traffic. Priests Lane is a 'residential lane' that has increasingly became a transport thoroughfare and is congested. The plan has not made itself aware of this congestion and does not take account of increased traffic that will occur due to this development and also the development of 1,000 homes in Shenfield and the Elizabeth line, so increased congestion and pollution on Priests Lane. The reasonable representations by residents that new road access along Priests Lane are hazardous have not been addressed, nor that they do not meet the requirements for safe highways. The plan does not address residents concerns that the road design is dangerous. The proposed plan for this site does not meet sustainability conditions. The Priests Lane site has been rejected a number of times in the past for users such as these described above and also because it is a valuable open urban space and should be protected as such to the benefit of current local residents. The development does not comply with the Essex design guide with respects to road and pavement width. The local plan needs to address other issues such as traffic concerns, healthcare and education needs and it does not, in relation to increased housing of this development. No specific or robust adjustment has been made tat a viable access point is viable. There are other alternative sites available that are better. The local infrastructure cannot support this development.

Priests Lane. 1. Pollution already above legal levels. 2. Road not wide enough - only one side has pavement. 3. Already too much traffic creating bumper to bumper queues. 4. No extra schools to be included. 5. No more surgeries - existing ones already too busy. 6. We need green areas to improve air pollution. 7. This is on flood plain. 8. Noise levels too high from traffic and rail lines.

Scrap Priests Lane in Local Plan.

Priests Lane. 1. Pollution even more!! 2. Too much traffic now. 3. Lane not wide enough nor pavements adequate to meet national standards. 4. Flood risk. 5. Insufficient schooling or GP practices. 6. Need to keep green area as urban space.

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

Unsound. The evidence base is flawed. 1. The transport assessment is inaccurate as it has excluded traffic along Priests Lane and was taken at a time which excluded a large proportion of school traffic, despite Council assurances that a traffic assessment would be done for Priests Lane. 2. The transport assessment does not account for the increased usage of Priests Lane from the proposed development of 1,000 houses in Shenfield travelling to the A127, nor does it account for the impact of the Elizabeth Line. 3. The Plan fails to address safety of residents: the technical submissions of residents that new road accesses along Priests Lane are hazardous have not been addressed, nor concerns that the road design is dangerous for increased traffic movements. 4. The site does not meet relevant sustainability conditions, notably access, transport network, mitigation of impact on local services, and unacceptable effect on health due to increased pollution. 5. The Priests Lane sites have been rejected previously because the land was deemed a valuable open urban space. 6. No account has been made of the increased pollution along Middleton Hall Lane and Priests Lane, the junction of which is a pollution hotspot. The Lane was never meant to be a main distributary road which it has now become. Residents have pointed out that as such it does not comply with the Essex Design Guide with respect to road and pavement width. NPPF Compliant: Local Plans should address not only housing but traffic concerns, healthcare and education needs. 1. The sustainability review refers to traffic as a concern, but no mitigation options have been identified. 2. No specific or robust argument has been made that a viable access point is possible. 3. When consideration against reasonable alternatives these sites can not be deemed justified and there is nowhere in the plan which allows for the enhancement of infrastructure as a result of development. 4. There is no additional provision for increased educational and health needs, the expansion of Hogarth School is to meet current demands and there is already a low level of GP per head. Schools further afield which may have space will required a car journey to attend, exacerbating the already dire traffic situation.

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

Unsound. The evidence base is flawed: !> The transport assessment is inaccurate as it has excluded traffic along Priests Lane and was not taken at a time which excluded a large proportion of school traffic despite Council assurance that traffic assessment would be done for Priests Lane. 2. The Transport assessment does not account for the increased usage of Priests Lane from the proposed development of 1,000 houses in Shenfield travelling to the A127 nor does it account for the impact of the Elizabeth Line. 3. The plan fails to address safety of residents: the technical submission of residents that new road accesses along Priests Lane are hazardous have not been addressed nor concerns that the road design is dangerous for increased traffic movements. 4. The site does not meet relevant sustainability requirements notably access, transport network, mitigation of local services and unacceptable effect on health due to increased pollution. 5.The Priests Lane sites have been rejected previously only because the land was deemed a valuable open space. 6. No account has been made of the increased pollution along Middleton Hall Lane and Priests Lane, the junction of which is a pollution hotspot. The lane was never meant to be a main distributary road which it has now become. Residents have pointed out that as such it does not comply with the Essex design guide with respect to road and pavement width. 7. NPPF Compliant: Local plans should address not only housing but traffic concerns, healthcare and education needs. The sustainability review refers to traffic as a concern but no mitigation options have been identified. 8. No specific or robust argument has been made that a viable access point is possible. 9. When considered against reasonable alternative these sites can be deemed justified and there is nowhere in the plan which allows for the enhancement of infrastructure as a result of development. 10. There is no additional provision for increased education and health needs, the expansion of Hogarth School is to meet current demands and there is already a low level of GP'spen head. Schools further afield which may have space will require a car journey to attend exacerbating the already dine traffic situation.

My major concern is the impact such a site will have on Priest Lane. If this site could be accessed - over the railway to Orchard Avenue and so traffic accesses A128 at an already existing mini roundabout would have less impact. Or could some negotiations occur with the Endeavour school - to allow access via Higarth Avenue - again this would reduce heavy traffic mixing with Brentwood School Traffic and crossrail etc. It wouldn't be a 'cut through' and traffic could leave Brentwod A127 without increasing congestion at Middleton Hall Lane.

Unsounds - concerned that no accurate transport assessment has been made - so evidence is flawed. 1. Data as taken during a school holiday and so does not account for majority of school traffic. Brentwood school and Hogarth School. 2. The majority of traffic during peak hours that makes it impossible to access or leave our property on Priest Lane disappears when Brentwood School is closed for holidays - yet the Transport Assessment did not account for pupils too and from this school. 3. The Transport Assessment does not account for any impact of Crossrail or other housing built. 4. No assessment has been carried out of Bishops Walk as a potential access route. The cul-de-sac and access has been designed and built with transport to only 5-6 houses in mind. Currently people park on pavements and bump up pavement to pass. The dustmen maintain they have to bring all rubbish to outside our house as their vehicles can't turn. Duty to cooperate - the technical submissions of residents have not been addressed. Submissions have been made regarding the safety issues surrounding the potential access routes and that they doe not conform to Essex Highways requirements and they have not been addressed. NPPF compliant. Local plans should also consider traffic concerns, healthcare and education needs. The plan does not include any planning for traffic concerns. There is no provision for increased primary educ need. No thought or health provision - we already wait weeks to see our GP.

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

Unsound: The Evidence base is flawed. 1. Transport Assessment is inaccurate as was not taken at busy times of day i.e. pre and post school runs and rush hours. 2. Proposed extra 1000 houses in Shenfield and opening of Elizabeth line will respond traffic in Priests Lane. Extra houses in Priests Lane will totally overload traffic flow. 3. Plan fails fails to address safety of residents. New accesses along Priests Lane for bends in road / would be hazardous. 4. Site does not meet sustainability conditions excess / transport / impact on local services / pollution. 5. Priests lane was never meant to be a main route between Brentwood and Shenfield the pavements and road itself are too narrow (do not comply with Essex Design Guide) do such a large flow of traffic. 6. Priests Lane is dangerous to pedestrians especially when pushing a buggy and has become an accident blackspot. 7. Priests Lane site is valuable open space and previously rejected for development.

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

Unsound: The Evidence base is flawed. 1. Transport Assessment is inaccurate as was not taken at busy times of day i.e. pre and post school runs and rush hours. 2. Proposed extra 1000 houses in Shenfield and opening of Elizabeth line will respond traffic in Priests Lane. Extra houses in Priests Lane will totally overload traffic flow. 3. Plan fails fails to address safety of residents. New accesses along Priests Lane for bends in road / would be hazardous. 4. Site does not meet sustainability conditions excess / transport / impact on local services / pollution. 5. Priests lane was never meant to be a main route between Brentwood and Shenfield the pavements and road itself are too narrow (do not comply with Essex Design Guide) do such a large flow of traffic. 6. Priests Lane is dangerous to pedestrians especially when pushing a buggy and has become an accident blackspot. 7. Priests Lane site is valuable open space and previously rejected for development.

Remove site for the Local Development PLan.

Unsound: The evidence base is flawed: 1. The Transport Assessment is inaccurate as it has excluded traffic along Priest Lane, and was taken at time which excluded a large proportion of school traffic, despite Council assurances that a traffic assessment would be done for Priest Lane. 2. The Transport Assessment does not account for the increased usage of Priests Lane from the proposed development of 1,000 houses in Shenfield travelling to the A127, nor does it account for the impact of the Elizabeth Line. 3. The Plan fails to address safety of residents: the technical submissions of residents that new road accesses along Priests Lane are hazardous have not been addressed nor concerns that the road design is dangerous for increased traffic movements. 4. The site does not meet relevant sustainability conditions, notably access, transport network, mitigation of impact on local services, and unacceptable effect on health due to increased pollution. 5. The Priest Lane sites have been rejected previously because the land was deemed a valuable open urban space. 6. No account has been made of the increased pollution along Middleton Hall Lane and Priests Lane, the junction of which is a pollution hotspot. 7. The Lane was never meant to be a main feeder road which has now become. Residents have pointed out that as such it does not comply with Essex design guide with respect to road and pavement width. NPPF Compliant Local plans should address not only housing but traffic concerns, healthcare and education needs. 1. The sustainability review refers to traffic as a concern, but no mitigation options have been identified. 2. No specific or robust argument has been made that a viable access point is possible. 3. When considered against reasonable alternatives these sites cannot be deemed justified and there is nowhere in the plan which allows for the enhancement of infrastructure as a result of development. 4. There is no additional provision for increased educational and health needs, the expansion of Hogarth School is to meet current demands and there is already a low level of GPs per head. Schools further afield which may have space will require a car journey to attend, exacerbating the already dire traffic situation.

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

Refer to attached. Summary: Transport assessment evidence is flawed: Middletown Hall Lane junction data was taken during exam period, therefore 1/3 fewer students. TA ignores transfer of pupils Brentwood Schools which causes most of congestion; doesn't account for increase in traffic from 1,000 Shenfield new homes; ignores impact of Elizabeth line; no specific assessment of supporting more traffic along Lane at peak times or access routes. No assessment of safety to motorists or pedestrians due to increased traffic
Priests Lane site is not sustainable - access, impact on transport network, no mitigation on local services and impact on health due to pollution.
Duty to cooperate not addressed as comments from residents regarding access routes, impact on Priests Lane, loss of protected open space, increase in pollution, or suitability of road not considered.
Plan is not NPPF compliant as ignores traffic concerns, need for educational facilities, or health provision.
The needs of the current population need to be assessed regarding traffic flow, GP and school availability; Accurate traffic assessments should be carried out before any site is decided on for development and a sensible debate had regarding its viability and housing delivery; The health and safety of current resident should be considered before increasing traffic and therefore pollution in an already congested area; the plan must address the requirements for open space and special consideration must be given to requirements of the two schools bordering the sites as they will inevitably be requiring additional space, be it playing fields (due to loss of their current areas) or future expansion of the schools (in the light of extra demand from the rapid increase in population as a result of the proposed plan); the site is not justified given the amount of technical evidence against development.

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

Refer to attached form. Transport assessment evidence is flawed: Middletown Hall Lane junction data was taken during exam period, therefore 1/3 fewer students. TA ignores transfer of pupils Brentwood Schools which causes most of congestion; doesn't account for increase in traffic from 1,000 Shenfield new homes; ignores impact of Elizabeth line; no specific assessment of supporting more traffic along Lane at peak times or access routes. No assessment of safety to motorists or pedestrians due to increased traffic
Priests Lane site is not sustainable - access, impact on transport network, no mitigation on local services and impact on health due to pollution.
Duty to cooperate not addressed as comments from residents regarding access routes, impact on Priests Lane, loss of protected open space, increase in pollution, or suitability of road not considered.
Plan is not NPPF compliant as ignores traffic concerns, need for educational facilities, or health provision.

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

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

Refer to attached form. Summary: Transport assessment evidence is flawed: Middletown Hall Lane junction data was taken during exam period, therefore 1/3 fewer students. TA ignores transfer of pupils Brentwood Schools which causes most of congestion; doesn't account for increase in traffic from 1,000 Shenfield new homes; ignores impact of Elizabeth line; no specific assessment of supporting more traffic along Lane at peak times or access routes. No assessment of safety to motorists or pedestrians due to increased traffic
Priests Lane site is not sustainable - access, impact on transport network, no mitigation on local services and impact on health due to pollution.
Duty to cooperate not addressed as comments from residents regarding access routes, impact on Priests Lane, loss of protected open space, increase in pollution, or suitability of road not considered.
Plan is not NPPF compliant as ignores traffic concerns, need for educational facilities, or health provision.

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

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

Priests lane standard text - for information. March 2019

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

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

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

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

Priests lane standard text - for information. March 2019

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

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

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

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

Chapter 9: Site allocations Policy R19 Land at Priests Lane
Unsound: The evidence base is flawed.
The Transport Assessment is inaccurate as it has excluded traffic along Priests Lane, and was taken at a time which excluded a large proportion of school traffic, despite Council assurances that a traffic assessment would be done for Priests Lane.
The Transport Assessment does not account for the increased traffic usage of Priests Lane as a result of cars travelling from the proposed development of 1,000 houses in Shenfield to the A127, nor does it account for the impact of the Elizabeth Line.
The plan fails to address safety of residents: the technical submissions of residents that new road accesses along Priests Lane are hazardous and have not been addressed, nor concerns that the road design is dangerous for increased traffic movements.
The site has been rejected previously because it was deemed valuable open urban space.
No account has been made of increased pollution along Middleton Hall Lane and Priests Lane, the junction of which is a pollution hotspot.
The lane was never meant to be a main distributor road which has now become.
Residents have pointed out that as such it does not comply with the Essex design guide with respect to road and pavement width.

Duty to Cooperate: Local plans should address not only housing but traffic concerns, healthcare and education needs.


NPPF Compliant: Local plans should address not only housing but traffic concerns, healthcare and education needs.
* The sustainability review refers to traffic as a concern, but no mitigation options have been identified.
* No specific or robust argument has been made that a viable access point is possible.
* When considered against reasonable alternatives these sites cannot be deemed justified and there is nowhere in the plan which allows for the enhancement of infrastructure as a result of development.
* There is no additional provision for increased educational and health needs, the expansion of Hogarth School is to meet current demands and there is already a low level of GPs per head. Schools further afield which may have space will require a car journey to attend, exacerbating the already dire traffic situation.

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

Remove R19 from plan, this would make plan sound as it will negate all the issues I have describes .

The plan is not sound. Refer to attached scanned form.

See attached.

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

See attached.