Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 24611
Received: 12/06/2019
Respondent: Mr Pete Vince
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Flood issues on sites R25 and R26. Object to the inclusion of R25 and R26 as: Plan is unsound as not properly prepared: didn't assess objectively areas local need; R25 and R26 not consulted on until 2018; no clear strategy or consultation on sites or with other boroughs; no evidence of impact assessment alone or with other borough development.
Not justified
Unsound as not properly prepared: didn't assess objectively areas local need or consultation on affordable housing need; R25 and R26 not consulted on until 2018; failed to consider other locations particularly not in Green Belt; no proportionate evidence to justify decisions of allocations.
Not consistent with national policy: Blackmore does not have sustainable infrastructure or access, is contrary to NPPF section 13 Green Belt.
The Blackmore sites R25 and R26 should be removed from the plan until there has been 1. A full housing need survey for Blackmore; 2. A proper consultation, including BBC taking into account alternative sites; 3. A properly formulated strategy from BBC in relation to protecting the heritage and character of the villages within the Borough
See attached.
Section 4
Policy SP01 - D(a), D(f)
Paragraphs 4.2and 4.9
Policy SP02
Section 08
Policy NE06 8.5-8.64
Para 8.85 (iv)
Para 8.90
Para 8.101
Policy NE13
Section 09
Policy R25, 9.197-9.200
Policy R26, 9.201-204
The Plan is unsound because it fails to comply with the requirements set out in the National Planning
Policy Framework ("NPPF") para 35 as follows:
a) It has not been properly prepared:
* Brentwood Borough Council ("BBC') has failed to objectively assess the area's housing
needs in particular in reference to the proposed development of housing in the village of
Blackmore (Site Policy Numbers R25 and R26.
* The Blackmore Sites suddenly appeared in the draft plan in January 2018 but had not
been in the earlier drafts of the plan which were consulted on during the course of 2016.
* No clear strategy for the villages in the Borough has been consulted on publicly, nor has
there been any consultation evidenced with the bordering Local Authorities (Epping
Forest DC and Chelmsford City Council), whose boundaries both adjoin Blackmore Parish and whose residents' needs directly impact Blackmore Village in respect of housing
provision, transport and other services. For example, there is already a development of
30 houses (approved by Epping Forest, without any evidence of consultation with BBC or
Blackmore Parish Council) in progress at the top of Fingrith Hall Road which will impact
the infrastructure, amenities and other facilities of Blackmore.
* No evidence has been provided in the Local Development Plan of how these
developments have been assessed to be sustainable in light of the impact the BBC
proposals, plus the Epping Forest development and how they will impact the local
infrastructure and character of the village of Blackmore.
b) It is not justified on the following grounds:
* There has been no evidence put forward by BBC, such as a local housing need
assessment for the village of Blackmore which would justify expanding the village
housing stock by around a third. There has been no consultation in the village of its
housing needs. In or around 2016 or 2017 there was a local meeting arranged to review if affordable housing was required in the village. This proposal was abandoned
due to the negative feedback from villagers.
* The BBC have failed to consider other more suitable locations for development which
would not (a) encroach and irrevocably damage greenbelt land (contrary to Section
13 of the NPPF) (b) negatively impact the character, rural nature and restricted
amenities on offer in the village of Blackmore and (c) would make use of existing
suitable infrastructure and amenities, such as Brownfield sites, or sites with public
transport and those other existing sites in the plan where the local infrastructure
could easily bear an increased density in numbers of housing
* No proportionate evidence (or any at all) has been included in the plan to justify the
proposed developments in Blackmore or how issues such as access to these proposed
sites which are serviced currently by small narrow lanes or how other local
infrastructure such as drainage, increased traffic flow on what are narrow country
roads around Blackmore, schools, doctors surgeries will be dealt with.
c)
It is not consistent with national policy:
*
It does not enable the delivery of sustainable development as the proposed
developments in Blackmore village as the infrastructure will not support an increase in
traffic on the single track roads and lack of parking at the school and village shop, school
places in a school that is already at capacity with a large waiting list, additional pressure
on the already crowded only doctor's surgery in Doddinghurst.
* Under the NPPF section 13 conservation of the Green Belt is set out and the Plan states that the BBC "will continue to resist strongly pressure to allow development in these clusters". The proposal to grow what is a historic, rural village such as Blackmore by a third is not consistent with either the national policy of keeping greenbelt land open and BBC's own policy to avoid irrevocable damage to the character of the Green Belt.