brentwood.gov.uk

Remove R25 and R26 from plan

LOP Section 04: (Managing growth)
Policy SP0l - O(a) and O(f)
Para 4.9
Para 4.20
Policy SP02
LOP Section 08: (Natural Environment)
Policy NE06, 8.51- 8.64
Para 8.85 (iv)
Para 8.90
Para 8.101
Policy NE13
LDP Section 09: (Site Allocation)
- Policy R25, 9.197 - 9.200
- Policy R26, 9.201- 9.204
I consider the Local Plan to be unsound, not legally compliant and fails to comply with the Duty to
Cooperate on the following grounds:
1. Soundness: Local Planning Authorities must prepare a Local Plan based on relevant and appropriate evidence base.
a. In my opinion the evidence base has not considered a number of germane facts- or if it has it has not provided sufficient weight to the following:
i. Health - General Practice. Deal Tree Health Centre is already operating at figures
beyond the optimum number of patients per GP, as outlined in the Brentwood
Infrastructure Delivery Plan (IDP). New housing has already impacted this
further, with developments in Rookery Road and The Elms in Lower Road
Mountnessing, along with travellers who have occupied land on the Chelmsford
Road all squeezing Deal Tree Health Centre further. The addition of 70 new
properties in Blackmore under R25 and R26 will further exacerbate the problem.
ii. Primary Education: DODDINGHURST / KELVEDON HATCH (Group 3) primary
provision which includes Blackmore Primary School, has insufficient spaces on
several grounds:
1. In accordance with the National Audit Office report "Capital Funding for
New School Places' (2013) there should be a minimum 5% surplus that
the Department for Education assumes in its planning as necessary to
support operational flexibility (mid-year admissions) and facilitate
parental choice. A deficiency may thus be deemed to exist without the
certainty of every local place being filled". DODDINGHURST / KELVEDON
HATCH (Group 3) primary provision which includes Blackmore Primary
School, has only a 3% surplus.
2. Blackmore Primary School is currently full so has no surplus, let alone the
5% that the NAO recommends, or the 3% that is mentioned for Group 3
in the BBC paper.
3. In addition, 70 new properties in the Group 3 catchment is directly in
Blackmore, further compounding the poor situation. This includes
additional housing proposed by EFDC for the top end of Fingrith Hall
Lane. Although such housing is not in Brentwood Borough's plans, the
schooling for these houses will be assumed to be in Blackmore Primary
School.
iii. Services and the environment in Blackmore. There is a limited bus service with
the final bus from Brentwood Station leaving at 18:35. This will mean that new
residents will need to own one possibly two cars. With so little parking capacity
in Blackmore, this will have a detrimental impact on the village centre.
iv. Roads in Blackmore. There is no through road in the village, and plan to use Red
Rose Lane for the sites R25 and R26 is a major flaw in the planning. It is a single-
track road and marked as unsuitable for large vehicles. Therefore, the
construction of 70 properties and their subsequent use by the new residents will
present significant difficulties along Red Rose Lane.
v. Sewage and drainage. What are the plans for extending these if we are to avoid
the flooding and associated health risks which we have experienced in the past
few years? The presence of 70 properties will add to this problem, especially
with their run-off.
vi. Electricity, gas, telephone and internet. There will need to be additional facilities
installed to support the proposed 30% growth. Has this been considered?
2. Duty to Cooperate: Throughout the plan-making process discussions have taken place with various statutory consultees and neighbouring authorities.
a. In my opinion there has been insufficient engagement with neighbouring authorities, in particular with Epping Forest. This is reflected in the fact that the development planned for Fingrith Hall Lane of some 30 houses by EFDC will inevitably put a strain on Blackmore as described above for the following aspects:
i. Health
ii. Schooling
iii. Roads
iv. Services and the environment in Blackmore
3. Legally Compliant: Local Planning Authorities must prepare a Local Plan which adheres to the requirements as set out in the National Planning Policy Framework (NPPF), planning practice guidance, and a other relevant planning regulations
& legislation
a. In my opinion the Local Plan has not adhered to the NPPF because of its disregard of the following:
i. Green Belt. Central Government has said that Green Belt must be protected. It
appears that the BBC is disregarding the green belt status of the village.
ii. Maintaining the local ecology. The development of R25 and R26 will damage
important areas for our wildlife.
iii. Blackmore's heritage. Blackmore is a village with great history, some dating back
to Tudor times. It is incumbent on us all to retain our heritage. The growth of
30% to Blackmore with its knock-on impact on the lanes and roads around the
village will jeopardise this.
iv. Other inclusions. The BBC seems to have amended the status of the Travellers
Site in Chelmsford Road, and wrapped it into the Local Plan. Was it legal to do
so?
The BBC planners should perform the outstanding and incomplete tasks as outlined above. In addition, the planners should take notice of the neighbourhood plan (BVHA) which sets out the Blackmore local housing needs and how Blackmore can continue to support a sustainable community.
Sites R25 and R26 should be removed from the Local Plan.