brentwood.gov.uk

Removal of proposed developments R25 and R26 from the plan and reallocation of the 70 dwellings to more suitable brownfield sites in the borough.

I object to the inclusion of the proposed developments R25 and R26 on the grounds the Local Plan is not legally compliant, nor sound (on the basis that it is unjustified and inconsistent with national policy) and does not comply with the duty to Co-operate for the reasons set out below.

Inclusion of proposed developments R25 and R26 contravenes the requirements of the National Planning Policy Framework as follows:
(i) Contravenes para 77, in-so-far-as in relation to the proposed developments R25 and R26, local needs have not been formally identified and considered. Indeed Brentwood Borough Council representatives conceded during a meeting with Blackmore Parish residents on 31/01/19 that the proposals were developer led; a wholly inappropriate method of site selection.
(ii) Given the building of homes on the village boundary within the Borough of Epping Forest (at the ex-Norton Heath Equestrian Centre and in Nine Ashes), and the importance of sites R25 and R26 in their current state to the village community, serious consideration should be given to these being designated as Local Green Space in accordance with para 99 and 100, instead of being allocated to housing which would impair the beauty, historic significance, tranquillity and richness of wildlife of these sites in close proximity to the village centre.
(iii) Contravenes para 108 as the historic Red Rose Lane does not allow for safe and suitable access to the proposed sites R25 and R26, and the resulting adverse impact on highway safety would be unacceptable.
(iv) Contravenes para 118(b) as the proposed developments R25 and R26 fail to recognise the importance this currently undeveloped land has on village flood risk mitigation, carbon storage and potential alternative use for food production.
(v) Contravenes para 118(c) as the proposed developments R25 and R26 on greenfield (and Green Belt) land would not be required if the council gave the necessary substantial weight to the value of using available brownfield land within the borough. The council has not demonstrated that there are no brownfield sites available within the borough that would (and should) take priority for development over the greenfield land off of Red Rose Lane.
(vi) Contravenes para 133 as the proposed developments R25 and R26 fails to recognise the great importance that the Government attaches to the Green Belt.
(vii) Contravenes para 134 (c) and (d) as the proposed developments R25 and R26 encroach upon the countryside and harm the setting and special character of the village of Blackmore.
(viii) Para 136 states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. This bar has not been achieved with regards to the proposed developments R25 and R26 on greenfield / village Green Belt land. No exceptional circumstances exist, as alternative, more suitable locations for housing, which do not encroach on greenfield or Green Belt land, exist elsewhere within the Borough.
(ix) With alternative brownfield sites available, and/or it being possible to accommodate the number of proposed houses within other proposed developments within the LDP, the council has not demonstrated that it has examined fully all other reasonable options which are required to justify changes to the Green Belt, so has contravened para 137(a). The council has failed to demonstrate that is has examined fully all other reasonable options for the building of 70 houses on greenfield / village Green Belt land (which the proposed developments R25 and R26 would result in).
(x) The changes to the village Green Belt boundary that would result from the proposed developments R25 and R26, has failed to be informed by adequate consultation with neighbouring authorities (a requirement of para 137(c)), as it does not recognise the development that has recently occurred on the village boundary at Nine Ashes, nor the current development underway on the village boundary at the ex-Norton Heath Equestrian Centre (both falling within the Epping Forest District), which will adversely affect traffic levels and road safety in the village of Blackmore as well as lead to further over-subscription at the village primary school and over-capacity at the local doctors surgery.
(xi) Contravenes para 138 as the proposed developments R25 and R26 are not well-served by public transport; also they are located on greenfield / village Green Belt land and insufficient consideration has been given to identify previously-developed land.
(xii) Contravenes para 140 as the proposed developments R25 and R26 are situated in a village (Blackmore) on greenfield land and the open character of the village makes an important contribution rural setting. The council have until only recently treated as Blackmore as "unsuitable" for development for this reason.
(xiii) Contravenes para 141 as the council has not planned positively to enhance the beneficial use of the greenfield / village Green Belt land upon which the proposed developments R25 and R26 are situated.
(xiv) Contravenes para 143 as the proposed developments R25 and R26 are inappropriate (given their size, scope and impact on the character of the village and the adverse impact on the natural environment, road safety, road noise and essential services), so by definition, harmful to the village Green Belt and should not have been approved. The "very special circumstances" exemption has not been proven, or met, by the council.
(xv) Contravenes para 144 as insufficient weight has been given to the harm that would be caused to the village Green Belt from the proposed developments R25 and R26. The council have not demonstrated that other considerations outweigh the potential harm to the village Green Belt by reason of inappropriateness or any other harm resulting from the proposals, so have failed to meet the "very special circumstances" test.
(xvi)Contravenes para 145 as the proposed developments R25 and R26 are inappropriate as they would require the construction of new buildings in the village Green Belt and the listed exceptions do not apply:
(a) the proposed buildings are not agriculture / forestry;
(b) the proposals are not for the provision of appropriate facilities;
(c) the proposals are not for the extension or alteration of an existing building;
(d) the proposals are not for the replacement of an existing building;
(e) the proposals are not for the limited infilling in villages, as the sites are on the edge of the existing built-up area which only borders one side of the sites, so do not meet the "infilling" definition and the scale of the proposals (70 new houses) represents more than 20% increase in the number of village properties, so cannot be described as "limited".
(f) the proposals are not for limited affordable housing for local community needs, as this need has not been formally assessed; also the council have inappropriately passed a motion that would allow up to 75% of the properties built on the proposed sites to be sold to those other than local people (indeed the other 25% are reserved for "local people or those over 50 years of age", so there is no guarantee that any would be allocated to local community needs).
(g) the proposals are not limited infilling (as stated under (e) above), nor the partial or complete redevelopment of previously developed land.
(xvii) Contravenes para 149 and 150 as the proposed developments R25 and R26 would reduce the future resilience of Blackmore to climate change impacts and increase the vulnerability of the historic centre of Blackmore to further severe flooding, due to the loss of natural drainage / absorption of rainfall provided by the greenfield land that currently exist on these sites. The proposed developments R25 and R26 would also result in the loss of a natural carbon sink that currently helps absorb carbon dioxide (a key contributor to climate change) from the atmosphere.
(xviii) Contravenes para 155 through to 163, as the council has not taken into proper consideration the history of flooding in the historic village of Blackmore and the adverse impact that the proposed developments R25 and R26 would have on the future likelihood of further such flooding.
(xix) Contravenes para 170(b) as the proposed developments R25 and R26 demonstrate that the council have failed to take into account the intrinsic character and beauty of the countryside (as alternative brownfield sites exist within the borough that could accommodate the number of houses proposed for these two sites), and the potential benefits that this agricultural suitable land could provide.
(xx) Contravenes para 180(a) as the proposed developments R25 and R26 will add to traffic volumes in and around the village of Blackmore, which for those living directly on one of the main roads in the village (as I do), this increased traffic noise is highly likely to lead to increased sleep deprivation such that it adversely impacts my family's health and quality of life.

Inclusion of proposed developments R25 and R26 contravenes Brentwood Borough Council's own policies as follows:
(i) Contravenes SP01(B) as the proposed developments R25 and R26 will degrade the environmental conditions in the Blackmore area.
(ii) Contravenes SP01(D)(a) as the proposed developments R25 and R26 would harm the character and settlement setting of Blackmore.
(iii) Contravenes SP01(D)(b) as the proposed developments R25 and R26 would have an unacceptable effect on the character appearance of Blackmore as a historic, rural village.
(iv) Contravenes SP01(D)(c) as the access points to the proposed developments R25 and R26 on Red Rose Lane would not provide satisfactory means of access to the site and would endanger vehicles, pedestrians and leisure users (cyclists, horse riders, runners, dog walkers etc.); also insufficient parking exists in the village to accommodate the additional demands on existing village amenities and infrastructure.
(v) Contravenes SP01(D)(d) as the country lanes leading into and out of Blackmore cannot satisfactorily accommodate the additional travel demands generated from the proposed developments (R25 and R26) and would give rise to adverse highway conditions and safety concerns for leisure users (cyclists, horse riders, runners, dog walkers etc.).
(vi) Contravenes SP01(D)(e) as the proposed developments would have an unacceptable effect of health and the environment due to the loss of viable farmland as well as the additional noise pollution and vibration that would be generated from the additional traffic on the roads in and around the village.
(vii) Contravenes SP01(D)(f) as the proposed developments would cause unacceptable effects on village properties and their occupiers through excessive noise and activity arising from the additional vehicle movements that would result on the roads in Blackmore.
(viii) Contravenes SP01(D)(k) as no mitigation for the impact on the already over-subscribed village primary school and over-capacity local doctors surgery is included in proposed developments R25 and R26.
(ix) Inclusion of the rural village of Blackmore within Settlement Category 3, rather than Category 4, appears inappropriate given its sparse setting (given its setting is more remote than, or comparable with Wyatt's Green, Hook End and Stondon Massey) and it having poor public transport, limited shops, jobs and community facilities and it being reliant on nearby settlements for some of its services (doctors, vets, supermarkets etc.).
(x) The council's stated approach to development within Category 3 settlements should be limited to brownfield redevelopment opportunities and limited urban extensions to meet local needs where appropriate, with any development needing to be appropriate to the rural setting of the area. However, the inclusion of the proposed developments R25 and R26 does not comply with these objectives, as they are not on brownfield land, are not "limited", nor "minimal" (together they would represent more than a 20% increase in the number of village properties, so is actually a highly inappropriate large scale development for the village), nor are they for local needs (no formal local needs survey for Blackmore has been undertaken; and the proposed developments are not exclusively for the provision of housing to locals), nor are such large scale developments appropriate to the rural setting (instead they will be detrimental to the rural character of the village and borough).
(xi) Inclusion of the proposed developments R25 and R26 do not meet the council's stated aim of encouraging Brownfield redevelopment opportunities. Such opportunities exist within the parish of Blackmore and elsewhere in the borough, but these opportunities have not been sufficiently explored. This provides further evidence of the selection of sites R25 and R26 being developer-led (as admitted to by representatives of the council's planning team at a meeting with parishioners on 31/01/19), rather than through proper identification, evaluation and assessment by the council, free from undue influence by developers. The development of greenfield land currently occupying sites R25 and R26 would not be required if brownfield sites were appropriately identified and included in the LDP by the council, as required in its own stated policies.
(xii) Inclusion of the proposed developments R25 and R26 contravenes the council's stated aim (section 4.6 of the LDP) of directing development to locations that are supported by effective transport provision, community and other essential services, while minimising harm to the environment and preserving the Green Belt.
(xiii) Inclusion of the proposed developments R25 and R26 contravenes the council's stated requirements (section 4.9 of the LDP) for developments to be capable of being satisfactorily accommodated by the transport network and not give rise to unacceptable highway conditions, safety and amenity concerns.
(xiv) Recognition by the council of the existence of Green Belt land in the borough (per para 4.19 of the LDP) and presumption that such land will be available for development upon adoption of the LDP fails to take into account the importance that the Government attaches to the Green Belt as set out in the National Planning Policy Framework (para 133) and shows the council's intent on building on it without due consideration and without fully evidencing and justifying the exceptional circumstances required before such boundaries can be altered (especially in light of the existence of alternative brownfield sites within the Borough that have not been adequately considered).
(xv) Contravenes SP02(B)(b) as the proposed developments R25 and R26 are not located in transit / growth corridors and Red Rose Lane (the proposed access points) cannot be regarded as "highly accessible" given how narrow they are and also the existence of blind bends and use by cyclists, horse riders, runners, dog walkers etc.
(xvi) Inclusion of the proposed developments R25 and R26 contravenes the council's statement that they have prioritised "growth based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas", as these sites are not situated on brownfield land, but on agriculturally viable greenfield (and village Green Belt) land.
(xvii) Insufficient assessment has been undertaken of the impacts on health and well-being, upon the capacity of existing health and social care services and facilities, and the environmental impacts arising from the proposed developments R25 and R26 (which would add a combined 70 homes to the village). The following factors relating to these proposed developments will adversely affect the physical, social and mental health and well-being of existing Blackmore residents and the Blackmore community: sites are located on greenfield land (within the village Green Belt) which provide green space within the village boundary; the surrounding roads are unsuitable for the extra traffic that would be generated (unsafe for existing car and leisure users of Red Rose Lane and additional noise impacting residents of houses located on the main roads of Blackmore); existing inadequate access to public services (village school is over-subscribed and local doctors surgery is operating over-capacity); and the increased risk of flooding in the historic heart of Blackmore (due to the loss of vital natural drainage / rainfall absorption).
(xviii) Given the combined size of the neighbouring proposed developments R25 and R26 (a combined 70 dwellings) and given their impact on the community and local infrastructure, a full and proper Health Impact Assessment and Environmental Impact Assessment should have been performed prior to the inclusion of these sites in the Local Development Plan.
(xix) Contravenes SP04(A) as the proposed developments R25 and R26 are not supported by, nor have good access to, all necessary infrastructure. Transport infrastructure is inadequate for these developments as well as health provision and schooling infrastructure.
(xx) Contravenes SP04(B) as it has not been demonstrated that adequate mitigating measures have been agreed in respect of the proposed developments R25 and R26.