brentwood.gov.uk

Object

Representation ID: 30510

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

NPPF (para 11) says that the titled balance (i.e. in favour of granting development where there is no up-to-date Local Plan) is disapplied where there are clear policies to reject. Footnote 7 to para 11 confirms that not only Green Belt, but also 'areas at risk of flooding' are some exceptions -­ R25 and R26 (currently) fall within both. Taking this further, para 11(b) confirms that objectively assessed needs (for housing and housing supply) do NOT need to be met by strategic policies where protective policies of the NPPF (as identified in footnote 7) provide a strong reason for restricting the overall scale of development, or any adverse impacts of meeting housing needs in full would significantly and demonstrably outweigh the benefits when assessed in the round.
- Turning to the existence (or absence) of 'exceptional circumstances' to justify Green Belt release (Solihull v Gallagher), site suitability for development is not sufficient reason alone to justify Green Belt Release. These sites (R25 and R26) are quality arable land, added to which Brentwood BC chose to ignore the availability/ suitability of the Brownfield site at Redrose Farm. This was flagged by us to BBC in July 2018, i.e. well ahead of Reg 19 decisions. The 12 houses now constructed on the brownfield site (which BVHA supported, and helped tailor to the needs of this Village - see letter from Stonebond, attached), now sharpens the focus on other concerns previously highlighted in our various Reps, e.g. Village infrastructure and resources......issues that should have been taken into account before allocating a further (around) 70 houses. BBC has simply taken the "brownfield 12" as windfall.
- In any event, 'exceptional circumstances' have not been adequately demonstrated, for example: in paragraph 8.81, 'good connectivity' is quoted. Again, Blackmore is remote. no main roads, mainly narrow lanes, inadequate bus services, and a long way from any of the Borough's main centres and railway stations.
- In the absence of BBC having undertaken a robust, strategic approach to the Green Belt and the housing needs I future sustainability of all of the villages, it chose instead to 'call for land' and acquiesce to pressure from developers...a complete volte-face from its stated position in 2016 when, and I quote, 'we have told the developers that R25 and R26 are unsuitable for development'. Had it actually thought strategically, BBC would have made better decisions, in line with the Council's own Strategic Objectives.
- There are clearly other, much larger settlements (with 'parades of shops'), also surrounded by Green Belt, with better connectivity and infrastructure / services. Doddinhurst is the best example....and with zero housing allocated.
- As proposed by BVHA, on multiple occasions, there must be a coherent strategy covering all the villages in the north of the Borough, rather than this random, developer-led approach that has been adopted thus far.