Object

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

Representation ID: 26322

Received: 12/03/2019

Respondent: Mrs Sandra Wood

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

No Housing Need Survey produced for the Blackmore area, therefore no justification as to why Blackmore has been selected for development.

Change suggested by respondent:

Site R25 and R26 should be removed from the LDP. Blackmore Village Heritage Association in cooperation with the local Parish Councils will be producing a local needs plan that will look at the actual needs within the local area for what is already a sustainable community rather than producing a plan that just seeks to help the Borough Council meet its housing quota, and planners should instead refer to this and produce an updated plan in cooperation with the local community.

Full text:

There is no clear strategy for Blackmore and other villages in the north of the borough. Brentwood Borough Council does not appear to have taken into consideration the proposals of neighbouring authorities e.g. Epping Forest District Council is proposing to construct 30 dwellings at the top of Fingrith Hall Lane - the residents of these houses will almost certainly use Blackmore as a local shopping place adding both to the traffic along Fingrith Hall Lane and the parking congestion in the centre of Blackmore village. Both policies R25 and R26 are based upon development off Red Rose Lane which according to the plan will be the main vehicular access. In total the plan as it currently stands s to add 70 homes across the two allocations - Red Rose Lane is a narrow lane most of which is not wide enough to allow two cars to pass one another, but given Blackmore's relatively poor public transport connections we can expect an average of at least two additional cars per household and assuming a minimum of two journeys each day (one in and one out) that is 280 extra cars per day along this narrow lane which has no pavements. In addition, Red Rose Lane signs at each end stating that it is unsuitable for heavy goods vehicles (see photos embedded below) and yet this will be the access route for all the construction traffic for the two sites. Red Rose Lane has drainage ditches running down either side of it which are important for local drainage and widening the road is not a viable option without further increasing the flood risk for the rest of the village. Please also see further comments below concerning the flood risk within the village. Both of these sites are green belt land. Section 2 in paragraph 2.8 of the plan classes Blackmore Settlement Category 3 Which to quote the table under paragraph 2.10 are "Villages in a spare rural setting that provide day to day needs for local residents. Brownfield redevelopment opportunities and limited urban extensions will be encouraged to meet local needs where appropriate. Development should be appropriate to the rural setting of the area. "Adding 70 homes on green belt land in a village with a population of 829 is neither appropriate to the rural setting nor is it brownfield redevelopment. This does not in any way seem to comply with Policy SP01: Sustainable Development which states in paragraph 4.9 "For a scheme to be acceptable, development will require to make satisfactory arrangements for vehicular, cycle and pedestrian access into the site and for parking and servicing within the site. Any traffic generated by the development should be capable of being satisfactorily accommodated by the transport network and not give rise to inaccessible highway conditions, safety and amenity concerns". The LDP proposes that 1% of the net homes should be on green belt land "large villages", a total of 123 homes, and yet 70 of these are proposed for one village - this appears to contradict paragraph 8.101. There is also no justification as to why Blackmore, amongst a number of other settlements should be "excluded from the Green Belt" (paragraph 8.90). In addition the village primary school is already fully subscribed and the local doctor's surgery (which is located in Doddinghurst) is very busy and it can take up to two weeks to obtain an appointment. There is nothing within the development plan to mitigate for this. There is very limited parking in the centre of the village both outside the village shop and the two public houses and tea shops with cars regularly parked along both sides of Fingrith Hall Lane and around Horse Fayre Green and it can be expected that this only will only spread further into the surrounding residential areas and along to the village green with the additional cars that the proposed developments will bring. There does not appear to have been any housing needs survey to demonstrate why Blackmore requires such extensive development. The proposed sites are liable to flooding and building on these and concreting them over will increase the flood risk to the rest of the village. Blackmore lies in a shallow bowl of land at the top of a gentle valley with the River Wid emerging from the south side of The Moat. So, surface water drains from the west, north and east into the village and then around The Moat to become the River Wid. This is ok in normal conditions but when rainfall is extreme the streams and drainage pipes are overwhelmed with flooding of roads which is common and sometimes with danger to homes. There was flooding of roads in the village in June 2016 after heavy rain and I am aware that the home of one of our neighbours was flooded by waters rising from the stream that runs underneath their house in Church Street. Having more hard impermeable surfaces such as roofs, dives, and roads which increase the speed of run-off of surface water will further increase the risk of overwhelming the drainage systems. This seems to totally contradict policy NE06. There is therefore no indication within the LDP as to how the proposed Policy R25 and R26 developments around Blackmore will be "repaired through significant benefits to the new and existing communities" (paragraph 8.114) - in fact due to the size of the proposals it would seem to be to the detriment of the existing community through the addition traffic, congestion and flood risk that would result from these policies.