brentwood.gov.uk

Object

Representation ID: 30509

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

NPPF Para 16(a) requires Plans to be prepared with the objective of contributing to the achievement of sustainable development. Both R25 and, especially, R26 cannot be considered 'sustainable developments'. They will both be subject to, and also exacerbate, the significant flooding that regularly occurs in the Blackmore Village envelope, as well as the very narrow lanes leading into the Village. Para 159 underlines that development should be directed away from areas at risk of flooding, yet it's clear to everyone with knowledge of the Village (and the frequency / extent of flooding here) that development on R25 and R26 will also increase this flood risk to existing dwellings within the existing Village. There is absolutely no evidence presented to remotely suggest that this policy requirement can be met.
Indeed, Mr Shadarevian QC correctly made the point, at the Hearing on 12/02/2021, that 'there are very few rivers in the Brentwood Council area'. Why, then, would BBC belatedly (Reg 18 stage) include sites R25 and R26 within the LDP, when the two sites are within a Village through which flows the largest of all the Brentwood rivers? It is the River Wid, which floods Blackmore with great regularity, and floods in numerous other places en­ route to Chelmsford, where it becomes a major tributary of the River Chelmer.
BVHA, the Parish Council, our Lawyers (Holmes & Hills), and numerous Members/ Residents have flagged this significant issue throughout the entire LDP Process (Reg 18, Reg 19, the Focussed Consultation, in numerous Representations and, in person at the Examination in Public Hearings). It is surprising that these sites were allocated in the first place, and even more incredulous that they remain in the Plan, especially in the absence of any clear evidence that this inherently dangerous issue can be overcome. There needs to be more specific engagement with, including a detailed fluvial flooding risk assessment from, The Environment Agency.
- Essex CC has, to some extent, reported on the other significant flood risk issue, that of surface water run off (Blackmore sits in a bowl, in terms of topography). However, we do not feel that they have understood the full implications for this Village, especially when surface water AND fluvial flooding meet at e.g Red rose Lane, and the heart of the Village (the Conservation area around The Green, where the Ponds (fed by the River Wid) regularly overflow and effectively cut off the eastern side of the Village.
- To be clear, the River Wid rises just north of Blackmore Village, flows (in theory) under Redrose Lane (but the flooding is that deep when it occurs that it renders this lane totally impassable), continues down the eastern side of the Village, into the ponds, exits the ponds, and continues towards Mountnessing. When it floods, as it does with unerring regularity, not only does Redrose Lane get cut off, so too does the entrance to the Village from the Chelmsford Road. Picture Emergency Vehicles trying to access R26 from Chelmsford..... the potential dangers are enormous.
- There is reference made to 'Stondon Brook', which is a tributary of the Wid, flowing into it well south of Blackmore Village. Why is this referenced, and not Blackmore Village, where the proposed developments sit?
- So, insufficient due-diligence again, and therefore the Plan is unsound (not positively prepared)
- Furthermore, the Sustainability Appraisal (2.8.1) appears to 'gloss over' the reality of what occurs in Blackmore. This (i.e. the reality) is really well documented, including several albums full of photos, some of which are included at the end of this Representation.
- We also feel that the discussion at the Hearing on 12.02.2021 was not sufficiently robust, and the real and serious flood risk issues were not probed deeply enough. To suggest that the flood risk issue should be left for consideration at individual site Planning Application stage massively underplays the seriousness of the matter. In short, the River Wid actually exists, and actually floods Blackmore with great regularity and severity.
- Finally, on this matter, the impact of Climate Change is another very good reason to properly engage with The Environment Agency BEFORE this Plan is adopted and BEFORE moving on to the next Plan in a couple of years' time. BVHA is also taking up this matter with other parties who should be made aware of the seriousness of the flood risk issue in Blackmore. We are therefore attaching, as part of these Reps, an open letter to other bodies, including the Secretary of State, and the Environment Agency, in addition to BBC and the Planning Inspectorate, and we stand ready to engage further, in a constructive way.