Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22303

Received: 16/03/2019

Respondent: Mr N McCarthy

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

We object on grounds of unsoundness and inconsistency in application of planning guidelines. Key information needed to assess the Plan has not been readily available leading to concerns over the legality of the undertaking.

Change suggested by respondent:

The immediate withdrawal of sites R25 and R26.

Full text:

This representation is made by Mr Neil McCarthy and Mrs Valerie McCarthy and should therefore be treated as two objections. We object to the two proposals designated R25 and R26, identified here as the Blackmore developments. Continued inclusion of these sites renders the Local Development Plan unsound under national guidelines -- indeed it is also inconsistent with the Borough's own planning criteria as applied elsewhere during compilation of the Plan.
The adjacent sites are in an entirely unsuitable location for housing allocation of a scale that will overwhelm the infrastructure and character of the existing community.
Access to the Blackmore developments is determined to be solely via a narrow country lane that presently carries little if any through traffic and is signposted as unsuitable for heavy vehicles. Redrose Lane is manifestly unfit for the purpose of providing up to an estimated (TRCS™ indicative) 700 additional daily traffic movements. The failure of the Plan to acknowledge and allow for the implications of this defect is sufficient cause to immediately withdraw both Blackmore developments. Withdrawal before Examination - during which the Blackmore developments would be subject to valid legal challenge - will enable the remainder of the Plan to meet the tests of soundness and legality required for adoption.
It is necessary to compare and contrast the case of the Borough's long-standing preference for a site known as Honeypot Lane to deliver 200 new dwellings in a location offering easy walking-distance to all the public and private amenities of Brentwood's town centre. This site complied with or exceeded all the objectives of the Plan by benefiting from immediate proximity to public transport hubs, employment opportunities, and commercial and social facilities. Whereas Honeypot Lane featured as a significant element towards the LDP's social and private housing ambitions from the outset, the Blackmore allocations, previously discounted as unsustainable, were only added in 2018 when number targets were increased.
In November 2018, the then Leader of the Council announced she was authorising withdrawal of the Honeypot Lane site from the published LDP. She confirmed the single reason for this volte-face was that a minor section of Honeypot Lane created a 'pinch-point', creating potential difficulty for access.
We have driven and walked the entire similar lengths of both Honeypot Lane and Redrose Lane. A reasonable person would have to concede that Redrose Lane presents a far worse set of circumstances relating to on-going access than Honeypot Lane. And It can be fairly stated that only minor road works incorporating vacant land to the side of Honeypot Lane would relieve the short 'pinch-point' between the extensive remaining doubly-paved and two-lane sections leading to the site. The entire length of Redrose Lane would require to be brought up to the standard already in place at Honeypot Lane,. This upgrade would have to include the cross road intersecting junction with Fringrith Hall Lane, thus destroying the Green Belt aspect and habitat of its surroundings. Again in comparison, Honeypot Lane has at one end a permanent 20mph limit due to location in the Town Centre Zone, and 30mph for the remainder where it runs parallel with the A12 Brentwood By-Pass. Redrose Lane through its distinct unbuilt rural location is subject to the National Speed Limit for a single-carriageway of its type, 60mph.
We endorse the more comprehensively informed and presented objections contained in the Regulation 19 submission prepared by the Parish Council and the wider village community. However, we believe the unsoundness of the Plan in relation to Blackmore, can be encapsulated in the flawed presumption that Redrose Lane would ever be a satisfactory means of access.