This is the text of the letter the Association sent to the Council regarding planning application 24/00804/FUL

Executive Summary

We write on behalf of the Priests Lane Neighbourhood Residents Association (“the Association”), a collective voice representing the concerns of the residents of Priests Lane and connected roads. Our purpose is to express the Association’s objections to the proposal to build a new housing estate for 97 houses on the land at 61a Priests Lane, together with a new access road. Our objections to the new access road are set out in our response to application 24/00760/FUL, however we address matters relating to that access that are relevant to this application. Our objections primarily relate to safety concerns relating to the access, the number of houses proposed, together with the consequent increase in volumes of traffic, and the removal of an historic tree in order to create the access point. The site, along with an adjacent site, has been allocated for development of around 75 dwellings in the LDP, but we consider this proposal is excessive, as it will result in a development that will be 50% higher than that allocated. The new junction has a number of design disadvantages that will compromise safety for such a large number of vehicles using it.

Road Safety Concerns

We consider that it is important to understand the nature of Priests Lane in order to place our objections in context to the current circumstances. The road historically was a lane linking the centres of Brentwood and Shenfield. It has a number of bends, and narrows in places to as little as 4.45 metres wide, with more than one stretch narrower than 5m. The new access point will be at one of the narrower parts of Priests Lane. In addition to the narrowness of the road at this point, this section of Priests Lane south of the junction with Friars Avenue has only one pedestrian footpath, which switches side at St Andrews Place. This footpath also varies in width with some sections less than 1m wide (see below for recommended road size). Although there is a small section of pavement opposite the site access it is a very short, narrow stretch accessing a handful of properties and is not really used by pedestrians. Despite the shortcomings of the road layout, Priests Lane is a County route and a PR2 local distributor road, presumably as it is deemed to have strategic importance in carrying through traffic for the area and bypassing the town centre. The traffic assessment in the application has assumed Priests Lane to be “a single-carriageway local access road”, although there is no evidence supporting this assertion. This categorisation does not seem to accord with the Essex Design Guide description of an access road, nor is it consistent with Essex Highways treating it as a local distributor road. Unfortunately, when contacted by us, Highways Essex were unable to tell us how Priests Lane was classified. The minimum design under current standards, for all roads bar the smallest, is a minimum 5.5 metre carriageway and 2x two-metre pedestrian pathways, which Priests Lane fails to meet. In evaluating the safety of the road we consider it vitally important to look at the function of the road as a local distributor road. The design of Priests Lane is clearly sub-optimal for a local distributor road and for the level of traffic it carries. We therefore regard that care and attention should be taken over new road junctions to ensure that a bad situation is not made worse. We consider that the level of traffic generated by the site will have a cumulative negative impact on safety, capacity and congestion on the road (in contravention of policy BE12) which we set out in more detail below.

Traffic Volumes

The road carries a significant level of traffic (per the Cala produced traffic count 4,490 vehicles per weekday, although see comments below about underestimate of traffic), which is expected to increase with the levels of development to the north of Shenfield, a factor not included in the transport assessment. Although traffic analysis was undertaken as part of the LDP, we do not think that the closure of Alexander Lane was proposed at that time, and that could have a significant effect rerouting traffic through Shenfield. One of the main factors affecting traffic on the road is the concentration of schools in the town centre. The traffic is noticeably lower during school holidays and from May when many students are on study and exam leave. June has been deemed a neutral month for a traffic count. This may be true generally across the county, but we consider it does not take account of the specific circumstances of this area particularly the proximity to Brentwood School, and we do not think June to be at all representative. This is evidenced from the data in the traffic report, which indicates that the average maximum queue at the junction with Middleton Hall Lane is 6 cars. This does not fit with most residents’ experience. Further, the analysis shows that the Middleton Hall Lane junction is nearing capacity based on light summer traffic. The junction will exceed capacity during autumn and winter traffic volumes when traffic often queues to Glanthams Road, and sometimes beyond. Priests Lane suffers from congestion during peak times, particularly in the morning. Outside peak times we also suffer from speeding traffic. The recent change to a 20mph limit has had some limited effect in reducing this, but very few cars adhere to the speed limit because it is not policed, nor are there physical methods enforcing the lower speed. In fact, we have observed more incidents of overtaking on the road than with the previous speed limit. Periodically Priests Lane suffers incidences of car collisions, the latest of which occurred on Wednesday 7 August 2024. Although normally there is no serious injury to participants, and although these incidents will not have been officially reported to Essex County Council, residents are able to show incidents where walls have been demolished when cars lose control. The traffic assessment provides very little information on how the number of trips has been calculated and the methodology is confusing. We note that it references the 2011 census for work related transport and we would like to point out that train users will also generate car journeys to the station, which suggests that at least 50% of work journeys will exit the estate by car. It also uses surveys based on a Cala development in Hitchin. While there may be superficial similarities, that estate appears to be closer to the local railway station and has a nearby bus route, unlike Priests Lane. Overall, there is little in the report that explains or supports the trip generation. Please see our comments in the objection to 24/00760/FUL. We think that the trip numbers underestimate the likely number of car journeys. For these reasons we think that the scale of the proposed development will generate an unacceptable impact on the travel network directly associated with it in terms of safety, capacity and congestion (in contravention of policy BE12). We think that this can be mitigated by reducing the number of proposed dwellings.

Impact on Priests Lane/Middleton Hall Road Junction

There is a transport analysis on the effect of the new development on the junction with Middleton Hall Road and also the effect on the signalled crossroad junction at Ingrave Road. We have already noted our reservations about the time of the traffic survey and that we consider it significantly underestimates the traffic. Investigation of the junction analysis raises a number of questions. Table 5.3 states that the observed average queue length on Priests Lane in the morning peak period was 6 cars. We have already stated that this is a surprisingly low number, given that traffic frequently queues beyond Shenfield Crescent. This is supposed to be the base data used to model how the junctions cope with the estimated development traffic projected to 2029 (Table 6.1). However, in this table, the base data used for the projections has reduced to a queue size of 2 cars on Priests Lane, which means that the projections are based on traffic sizes much lower than the actual observed numbers. Even using this much lower number the junction appears to be close to capacity, which suggests that using the actual observed number would likely exceed capacity. The report states that if traffic volumes increase the junctions would not operate efficiently, a fact that is already borne out by experience. The report states at 6.2.8 that the increase in traffic from the development is not significant, however the modelling clearly shows that it is sufficient to take the junction traffic to near, and likely over capacity. We are not sure that the suggestion in 6.2.11 that the traffic may result in queuing so bad that people no longer use it as a through route is a viable form of mitigation, but rather supports the fact that there is a current problem. This increase in traffic could have a negative consequence on residents in Shenfield Crescent and Hogarth Avenue which are often used to avoid the junctions at the top of Priests Lane, mainly in the morning peak time.

Pollution

The Council is already aware that the town centre junctions on Ingrave Road have the highest pollution counts. Increased queuing at the junction with Middletonhall Lane will have a knock-on increase on Priests Lane and a corresponding increase in pollution.

Sustainable travel

Priests Lane is supposed to form part of the safe cycle route in Brentwood, and we are concerned that the level of traffic is undermining this aim. We do not see much cycle traffic along the road; there is insufficient width for a cycle path and the narrowness of the road feels unsafe for cyclists. It should be noted that LTN1/20 states that roads with daily traffic volumes exceeding 2000 and an 85th percentile speed in excess of 10% over the posted speed limit would be “suitable for few people and will exclude most potential users and/or have safety concerns”, (table 4.1, page 33) ie it is unsuitable as a cycle route. We think that this is likely to be also true of the cycle route along Glanthams Road. Further, LTN1/20 states that cycle infrastructure must join together and be accessible for everyone from 8 to 80 (point 8 in the summary principles, page 11). While there may be safe cycle infrastructure on the development site, we do not think that it effectively joins up to any wider suitable network, and so does not contribute to sustainable travel plans. There is no bus route on Priests Lane. The nearest bus stop will be effectively 1km from the dwellings, and many of the amenities listed are not within easy walking distance. It should also be noted that the traffic assessment inflates the accessible amenities by including two private schools, a special-needs school and two private school sports facilities (not available to the public). There is only a single pedestrian walkway along this stretch of road (the small stretch across from 61a has little practical use). The walkway varies in width significantly along the road with some sections being less than 1m wide, and in places hemmed by hedges. In some places, residents report being nervous on narrow sections as vehicles pass by very close to pedestrians. The walkway is not continuous along the road, changing side at St Andrews Place, a blind bend. There are no formal crossings along Priests Lane. Pedestrians from/to Glanthams Road must cross at this section where the access to the site is proposed. For these reasons, we do not consider that the pedestrian walkways are easily walkable for all pedestrians and are generally unsuitable for wheelchairs or mobility scooters. The town centre and stations will be approximately 20-25 minutes’ walk, although in our experience many local residents still use a car for many journeys rather than walk. The new housing estate accesses onto a section of Priests Lane that has only one pedestrian walkway, although there is a very short and narrow walkway immediately opposite. The plan notes that there are suggested pedestrian/cycle accesses onto St Andrews Place and possibly Bishop Walk, but we understand there is no guarantee of access to St Andrews Place as the land is not controlled by the applicant. These do not add any benefit. In particular, St Andrews Place joins Priests Lane at a risky junction on a blind bend where there have been a number of car accidents; only recently the road sign was badly damaged by being hit by a car. For these reasons, we do not think the development scores highly in respect of policy BE09, neither does it meet NPPF s114(b).

Proposed road access

The access to the new estate will be via a new road junction on Priests Lane, at a point which has limited visibility on the left of the access because of the curvature of the road and also vertical obstructions in the line of site. Our concerns about the safety on this access point set out in our comments re application 24/00760/FUL. But we would like to reiterate that the junction has poor visibility to the left. There is a large hedge that obscures part of the of the area shown as Highways land. There is a telephone box, a telegraph pole and a road sign within the visibility envelope and obscure the point at 45m along the road. A visibility window drawn to avoid these obstructions would reach only 37m. This may result in cars waiting at the junction pulling forward and protruding into Priests Lane which is narrow here so could pose a safety risk. Glanthams Road has a similar difficulty and cars often protrude in order to see up the road. Glanthams Road will be only 25m away, and will create a left-right staggered junction, which the Essex Design Guide states is less preferable as it increases the chance of conflicting traffic movements. Pedestrians using Glanthams Road must cross Priests Lane, as must the house owners across the road from the junction. It can be particularly difficult in the morning rush hour with school children trying to cross the road along with traffic trying the negotiate the junction and frequently mounting the pavement to do so. We consider that the number of obstructions to the visibility, combined with close proximity to Glanthams Road and that pedestrians must cross Priests Lane between these two junctions makes this junction a higher risk. This cumulative effect together with the volume of traffic generated by an estate that will ultimately be in excess of 100 dwellings will have a potentially severe negative impact on Priests Lane in terms of safety and congestion. The transport assessments indicate that the amount of traffic using the junction can easily be accommodated. We are concerned about how the number of trips has been generated. The traffic assessments have used a combination of census data from 2011, and a survey taken at a site in Hitchin, although there is very little information to establish if this is statistically sound (the use of the Hitchin site is not directly comparable as explained in our response to 24/00760/FUL). The 2011 census has been used to establish work transport patterns, but it fails to take into account that a high proportion of train commuters also generate car trips to the station at rush hour, and indeed the provision of station car parking is mentioned as a positive point for the development. The Cala submitted trip generation analysis for the junction produces a surprisingly low number. We would also point out that the traffic analysis seems to assume trips are evenly spread across the rush hour, but this will not be the case, and it is the lumpy nature of rush hour traffic that usually gives rise to the queues along Priests Lane. During busy times when the Priests Lane traffic queues back beyond this point, this junction can cause great difficulty with cars mounting the pavement to turn in or out of Glanthams Road. We consider that the number of vehicles accessing the junction particularly at rush hour will compromise road safety when we take account of the close arrangement of the junctions at this point together with the poor visibility, visual obstructions and poor pedestrian access. In summary there are a number of difficulties with the siting and design of the new junction. We consider that there will be a cumulative negative effect on road safety.

Number of Dwellings and Housing Density

The Association recognises that the National Planning Policy Framework (paragraph 117) states that “Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions.” A development of 97 Houses on 4.23 hectares produces a density of 23 dwellings per hectare (dph). The current LDP for both sites included in R19 which had an allocation for around 75 dwellings, which was a density of 14 dph. This recognised the lower density in the surrounding areas and the impact on traffic and safety as specifically addressed in the LDP hearings. It should be noted that site R19 of the LDP also contained approximately 0.6 hectares of land owned by Mr & Mrs Fleming for which a planning application has yet to be lodged. A density of 23 dph would add a further 14 dwellings, resulting in a total equivalent site development of 111 dwellings which is a massive increase over the LDP number and cannot, in any responsible way, be represented as a number that is “around 75”, as Cala Homes claim. A total number of 111 homes would represent a 150% increase over the original 45 homes originally recommended by the Council. Policy HP03 provides for the Council to have a lower density housing where it would be appropriate to the character of the surrounding area or to avoid an adverse traffic impact. The site is in Old Shenfield, an area specifically characterised by its low-density housing and individual housing designs. Data submitted for the Examination of site shows that the three immediately adjoining areas to the site have densities of 6.8, 8.3 and 14.8 dwellings per hectare. That would suggest an average of 10 dwellings per hectare in the immediate vicinity of the development. Brentwood Borough Council in their original LDP document proposed 12 dwellings per hectare in line with the data in their study area. The average density per the Council’s study area equated to 14 dwellings per hectare. In the submissions at the LDP examination JTS Partnership argued for including areas that had 25 dph and 22 dph which were at the very fringes of their study area. However, it seems that the developers are ignoring comparisons with areas closest to the site, which seems entirely wrong. Including the fringe areas produces a density of 14dph and we think that this is more appropriate to the specific characteristic of the area. This Association would argue very strongly that the specific conditions relating to Priests Lane, the impact on road safety from the volume of traffic from the proposed 97 dwellings for the one site alone, and the poor access means that going above the average level of 14 dwellings per hectare in the Council’s study area would compromise safe and healthy living conditions.

Affordable housing

We support the inclusion of affordable housing. However, the figure of 35% is reached because it is in the form of 1 and 2 bedroom flats. There appears to be a great many of such dwellings developed recently in Brentwood, but there are not sufficient affordable family homes, similarly we understand there is a shortage of bungalow properties in the town. While there seems to have been an effort to create attractive houses, this does not seem to extend to the apartment blocks. As a result, we think that these will detract from the visual amenity of this estate.

Level of Car Parking Spaces

We note the level of parking spaces proposed by the developers is 202 spaces, 180 spaces allocated to home dwellers. Of the allocated spaces, 32 are on street parking, separate from the visitor parking bays. Most of the houses with more than one allocated parking space do not have side-by-side parking, but rather the space lie in a straight line toward the frontage, creating a chain of two or three spaces. We see that this is space efficient, but think that this may compromise the “useability” of some spaces, and so effectively reduce the number. As noted by Cala Homes, Brentwood has a higher than average car ownership. There are only 22 visitor car parking spaces, which may well be taken up by residents. The Association believes that there is a possible risk that cars will be parked on the roads around the development, causing blockages and in periods of high demand parking may spill over onto Priests Lane, causing even further problems on that narrow local distributor road, or Glanthams Road. Residents in St Andrew Place may also be concerned that a pedestrian path onto St Andrews Place could result in that road being used for overflow parking, which would be unsuitable.

Privacy concerns

The Association notes that there a small number of dwellings on the proposed site that are quite close to and overlook the back gardens of existing dwellings on Priests Lane and St Andrews Place. Particular plots have been sited unnecessarily close to neighbours on Priests Lane and St Andrews Place: plot 7 is particularly badly sited being positioned unnecessarily close to the boundary of properties on Priests Lane and overlooking property on St Andrews Place. Concerns have been raised about sites 36, 37 and 38 overlooking a swimming pool. It is felt that this could be avoided quite easily on the basis that the number of dwellings proposed is too high and should be scaled back, and so these houses could be re-sited to avoid overlooking existing properties. We also note that there are mature trees and hedges along the boundary with existing residents, but we cannot see any guarantee that these trees and hedges will be retained. We think that a condition should be that these trees be retained and that development should not endanger them. We think that this would help to mitigate the loss of green space and would support the biodiversity on the site.

Drainage

The proposed site is quite a wet site and retains a lot of water. Whilst we note plans to create a green centre at the heart of the development, the Association is very concerned that the concreting over of the site will lead to water run-off into the back gardens of those in Priests Lane, and in particular into gardens on St Andrews Place given the site slopes West to East. Additionally, there is a steep embankment down to the railway line which would also be at risk of having significant additional run-off water being diverted onto the railway line. No analysis has been provided in the documents about how this situation will be avoided.

Construction Period

It was disappointing that the application does not include any information on the management of the construction traffic. We would expect the construction to require a great number of large vehicles to be entering and leaving the site. As has already been mentioned, Priests Lane is fairly narrow at this point, and it is important to ensure that large construction lorries turning into and out of the new junction can be safely accommodated, especially given the busy nature of this through route.

Conclusion

Whilst the Association supports the need to build new homes in the area and that the site should be developed, the scale of the development is too large, especially given that this site is expected to be developed further on the adjacent site. It will give rise to real safety concerns on Priests Lane with the increased volumes of traffic on a local distributor road that is not really fit for purpose and the dangerous access road junction layout on that section of road. The Association also has a small number of recommendations to alleviate residents’ concerns that would be easily achievable if the number of dwellings proposed is reduced.