Object

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

Representation ID: 23010

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The village primary school is already full. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- Brentwood Borough Council has failed to demonstrate that the required housing
could not be met by increasing housing density on other allocated sites within the
LDP. The LDP is therefore not based on proportionate evidence.
There has been no 'Housing needs Survey' undertaken to demonstrate why
Blackmore is included in the LDP, and there is no justification of the numbers of
dwellings proposed in the village. The LDP is therefore not based on proportionate
evidence.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this will also increase the
flood risk in the village which has been subject to severe flooding in the past. Red
Rose Lane itself has flooded many times in the past, and a neighbouring field was
rejected from the LDP proposals because of the risk of flooding. The proposed
development is therefore not sustainable, and if ponds and extra drainage are
required to alleviate the risk of flooding, then the development may not be
deliverable.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.
- Brentwood Borough Council should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

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