brentwood.gov.uk

In view of my comments on how this would impact on the character of the village, I cannot see how any modifications could be made to the local plan that could rectify the whole situation. [Remove R25 and R26 from plan].

refer to attached scan of submission.
Summary
BBC has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites. The inclusion of sites R25 and R26 is not sound and cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.

The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.

If no previously developed land sites or urban areas or increase in densities on other proposed sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.

There are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because of inadequate access and narrowness of Red Rose Lane.


Sites R25 and R26 are inherently unsuitable and unsustainable developments because loss of "very good" agricultural land, of loss of biodiversity.

Sites R25 and R26 are inherently unsuitable and unsupported by relevant and up to date evidence base. Evidence regarding flooding shows the sites to be unsuitable.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because they don't fulfil the three sustainability objectives: economic, social or environmental. There is only limed employment in Blackmore so benefits would be limited and short term. Service are limited in the Village and children are being sent elsewhere for education. There is a reliance on the car, the sites are at risk of flooding, require the release of high grade agricultural land in the Green Belt. The access road is narrow and infrastructure works would harm the character of the area and loss of historic hedges and habitat. Other more sustainable locations should be allocated in preference - refer to SA. Nos: 038A,253, 277B, 297, 218B 053B, 189, 318, 288B, 153, 280, 024A and 130.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because it will result in disproportionate increase in the housing stock
Infrastructure and facilities within the village are already at capacity. (Shop, primary school, two village halls, a sports and social club, tennis courts, football and cricket pitches, a flood-lit Multi-Use Games Arena. Three pubs, Anglian Church, Baptist Church). There is a very limited bus service and s thus remote. It is over 6 miles to Brentwood and so residents are reliant on the car. There is social harm from some children being shipped out to other schools. There is only limited employment


Settlement hierarchy (heading before 2.8)
The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan). Therefore the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').

The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.

Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.


Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.


The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.

There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. The proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).
Red Rose Lane is signposted unsuitable for HGV traffic and Fingrith Hall Lane is too narrow. The choice of these sites seems random and unjustified.
In view of my comments on how this would impact on the character of the village, I cannot see how any modifications could be made to the local plan that could rectify the whole situation. [Remove R25 and R26 from plan].