Object

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

Representation ID: 24629

Received: 19/03/2019

Respondent: Terence Dearlove

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The Sustainability Appraisal refers to improvement of services and facilities in rural areas but that is completely undermined by the impact that proposed developments R25 and R26 will have on residents of Blackmore and those in the surrounding areas reliant on Blackmore facilities. Blackmore Village is categorised as Cat. 3 (large village) however this is outdated as the village now consists of just one small village shop (inclusive of a Post Office counter) and one small primary school. The SA includes an objective to reduce flood risk. Blackmore already has significant challenges. Further development will almost certainly make a bad situation worse and hereby also conflict with the SA.

Change suggested by respondent:

Sites R25 and R26 should be removed from the LDP and planners should refer to the Blackmore Village Heritage Association 'Neighbourhood Plan', which clearly sets out the local housing needs for our already sustainable community.

Full text:

I consider the Plan to be unsound, not legally compliant and fails to comply with the duty to cooperate for the following reasons: The Sustainability Appraisal (January 2019) refers to improvement of services and facilities in rural areas but that is completely undermined by the impact that proposed developments R25 & R26 will have on residents of Blackmore and those in surrounding areas reliant on Blackmore facilities. Blackmore village is categorised as Cat. 3 (large village) however this is outdated as the village now consists of just one small village shop (inclusive of a Post Office counter) and one small primary school. Parking to access these facilities is extremely limited thereby causing significant issues for existing residents, whilst Public transport to and from Blackmore village is already inadequate for existing residents of the village and surrounding communities. The challenges facing Blackmore village, as set out above, are already heightened by the current (EFDC) development of 30 houses in Fingrith Hall Lane and by a proposed development of affordable housing in Nine Ashes Road (EFDC). The nearest doctors surgery is in Doddinghurst and despite development / enlargement of the surgery with the last few years that continues to struggle to cope with existing demands from Blackmore, Doddinghurst and other surrounding villages. Furthermore, the proposed developments of R23 & R24 will also add to the burden. Given the potential impact on local infrastructure, services and facilities I am extremely concerned to have seen no reference to adequate consultation between BBC and EFDC. Blackmore village is comprised of circa 330 dwellings with a population of 829. The Local Plan has the potential to add close to one quarter to this and that takes no account of EFDC developments referred to above. The Sustainability Appraisal (SA) 2019 includes an objective to reduce flood risk. Blackmore already has significant challenges and instances of flooding are a matter of photographic record. Further development will almost certainly make a bad situation worse and hereby also conflict with the SA. No Housing needs survey has been conducted that demonstrates why Blackmore should be included in the LDP, furthermore, the decision to include Blackmore contradicts the LDP (2016) which stated that growth in rural north and rural south areas of BB would be limited in order to retain 'local character'. BBC has failed to demonstrate that there are other brownfield sites that are available and these should take priority over the greenfield land off of Red Rose Lane. The proposed developments in Blackmore do not promote 'sustainable development' and other more suitable / sustainable locations should be considered such as urban extension to Brentwood and further additions to the 'Dunton Hills Garden Village' project. On a final note there is no evident clear strategy for the villages in the north of the Borough, Blackmore being just one example. As a consequence it appears that decisions have been made within the Local Plan that take no account of the challenges that are already faced, the impact that the plan would have on these challenges and instead the decision to add 70 plus homes to what is a small village community seems to be based on 'targets need to be met for new houses - where we can put them'.