Object

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

Representation ID: 23033

Received: 15/03/2019

Respondent: Miss Emily Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of Brentwood Borough. It lacks any provision for meeting the village's needs, which have not been objectively assessed.

Change suggested by respondent:

Brentwood Council should: conduct a 'Housing Need survey' of Blackmore village to demonstrate that the development is justified; demonstrate that no other brownfield sites are available; highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken.

Full text:

Brentwood Borough Council has not demonstrated a clear development strategy for the villages in the north of Brentwood Borough. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages objectively assessed needs.
- The LDP is required to be informed by agreements with other authorities. 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 additional planned housing developments in Red Rose Farm and on Spriggs Lane near Blackmore which have not been taken into account, and these will again rely on Blackmore infrastructure and result in increased use of services.
- 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. Blackmore is an isolated village with modest services and infrastructure - minimal bus services to Brentwood and Chelmsford, a primary school which is already full, a doctors surgery nearby which is severely overstretched with long waits for non-emergency GP appointments, narrow roads which are already over-full and parking congestion near the local shop. Further housing development would have a detrimental effect on all of these services. 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.
- The proposed development sites are pristine 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. Brentwood Borough Council has not demonstrated that no suitable brownfield alternative sites are available.
- 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 new houses proposed in the village. The proposed developments would result in an increase in houses in Blackmore of over 25%. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements which would result from the proposed development. Indeed the lane is signed 'unsuitable for heavy vehicles'. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites 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 an adjacent field was rejected from the LDP proposals because of the high 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 will not be deliverable as planned.
- Site R26 is home to a number of protected species including turtle doves, skylarks, yellowhammers 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.

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