Removal of proposed developments R25 and R26 from the plan and reallocation of the 70 dwellings to more suitable brownfield sites in the borough.

Inclusion of site allocations R25 and R26 in the LDP are inappropriate, unsound and not compliant with legal requirements on the following grounds: failure to prove that more suitable (brownfield) sites do not exist in the borough, or that other site allocations couldn't absorb the 70 dwellings proposed; inadequate consultation with Epping Forest District Council and failure to properly consider the impact of other nearby developments on Blackmore; failure to recognise the increased flood risk resulting from the proposed development; adverse impact on roads, noise levels and safety of existing road users from increased traffic; inadequate local amenities/services; other considerations per full representation.

It is not clear that growth on the scale required by central government of Local Authorities under present conditions is capable of being sustainable. Brentwood's certainly isn't.

This third point is also connected to the fundamental consideration of sustainability. The Plan's SP01 (Sustainable Development) paragraph D a.) talks of preserving and enhancing "the character and settlement setting of our borough of villages" - but the plan as proposed does not do this. Firstly it stifles all the borough's villages by proposing no development sites in them - even small ones, to allow the elderly to downsize and the young to find affordable properties - with the three exceptions of Blackmore (R25, R26), West Horndon (R02) and Kelvedon Hatch (R23, R24). Secondly it takes the ossification of villages as an excuse to pile unsustainable development proposals on the borough's main settlement areas - and does so in contradiction to itself. SP01 D d.) talks of ensuring "the transport network can satisfactorily accommodate the travel demand generated and traffic generation would not give rise to adverse highway conditions or highway safety concerns or unacceptable loss of amenity". But the town centre already suffers adverse highway conditions, highway safety concerns, and unacceptable conditions for residents (especially by reason of air pollution and congestion). Yet the decision has been made to cluster numerous residential sites, some of very significant sizes, in areas which already have these problems (R03 all the way through to R20). The selection of these sites already fails to adhere to the Plan's SP03 (Health Impact Assessments) A a.) " the location, density and mix of land use", b.) "street layout and connectivity", e.) "open and green space" and g.) "air quality and noise" even as far as existing residential dwellings and experience goes.

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Unsound because :
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Brentwood Council should: conduct a 'Housing Need survey' of Blackmore village to demonstrate that the development is justified; demonstrate that no other brownfield sites are available; highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken.

Brentwood Borough Council has not demonstrated a clear development strategy for the villages in the north of Brentwood Borough. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages objectively assessed needs.
- The LDP is required to be informed by agreements with other authorities. Brentwood Borough Council has not consulted adequately with the neighbouring authorities and considered the impact of developments in the neighbouring vicinity such as Epping Forest District Council.
- There are additional planned housing developments in Red Rose Farm and on Spriggs Lane near Blackmore which have not been taken into account, and these will again rely on Blackmore infrastructure and result in increased use of services.
- There are other more suitable and sustainable locations within Brentwood Borough Council with much better access to urban development, and locations such as Blackmore do not promote sustainable development. Blackmore is an isolated village with modest services and infrastructure - minimal bus services to Brentwood and Chelmsford, a primary school which is already full, a doctors surgery nearby which is severely overstretched with long waits for non-emergency GP appointments, narrow roads which are already over-full and parking congestion near the local shop. Further housing development would have a detrimental effect on all of these services. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- The proposed development sites are pristine Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Brentwood Borough Council has not demonstrated that no suitable brownfield alternative sites are available.
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of new houses proposed in the village. The proposed developments would result in an increase in houses in Blackmore of over 25%. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements which would result from the proposed development. Indeed the lane is signed 'unsuitable for heavy vehicles'. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and an adjacent field was rejected from the LDP proposals because of the high risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development will not be deliverable as planned.
- Site R26 is home to a number of protected species including turtle doves, skylarks, yellowhammers and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy.

The Brentwood Bus and Rail Users' Association represents the interests of users of public transport in the Brentwood district.
Its aims and objectives are fourfold:
* To make representations on behalf of Brentwood's bus and rail users on the local services that are currently available and to campaign for new services to be .
* To campaign for more investment in local bus and rail services.
* To have regular dialogue with the local transport providers and Essex County Council.
* To work with other organisations and individuals to improve and develop local bus and rail services in our area.
In pursuit of these aims and objectives it wishes to comment on the implications of the Local Development Plan as amended by the Extraordinary Council Meeting on 8th November 2018.
The Plan will clearly have far-reaching implications for Brentwood's public transport network. First, it changes significantly the size and distribution of the borough's population and the consequent additional requirements for ways to access work, health and education, shopping and leisure. Secondly it will add to the already problematic traffic congestion issues at known pinch-points in the borough, which are already making it very difficult for bus operators to maintain a regular and efficient service.
It is therefore a matter of extreme concern for the Association that there are only four references to public transport in the document citing preferred allocations.
Most are in the aspirational vein of the Strategic Objectives
* Improve public transport infrastructure and ensure development sites are well
connected to bus and/or rail connections.
* Secure the delivery of new infrastructure to support a lower carbon future including
electric vehicles charging points and other measures.
* Improve cycling and walking facilities across the Borough and establish a grid or
network of green transport corridors.
This contrasts with health and school capacity, which are dealt with in some detail.
There are no references to traffic congestion, to which the Plan will clearly contribute. There are three references to bus services, one in the strategic objective and two in relation to one preferred site for an employment site which "has the potential" for development of bus services i.e. there are none at the moment.
It is difficult to see how a plan can be called strategic without proper consideration of public transport (i.e. buses as rail transport relates to travel in and out of the borough) within the borough. There is no mention of how congestion, which already inhibits travel within the borough and is predicted to increase even without the additional housing and business development.
There is limited scope for road improvements in the borough and additional developments are
outside the control of the planning authority. Increased congestion will impact on the ability of bus
operators to provide a regular and efficient service, reducing the extend to which they will be taken
up by users and increasing the likelihood that they will prove uneconomic and be withdrawn.
The impact of the proposed allocations
Central Area
The Ford Offices are excluded from this section and allocated to the Outer Area in the table below as
the site, although served by buses, is too far for most people to consider the station walkable while
Brentwood High St most certainly is not.
It is assumed that most people would find it possible to walk to Brentwood station and to the High
Street. A regular bus service is available from Warley (Council Depot) and from close to the Shenfield
sites (Priests Lane is walkable to Brentwood High Street but probably closer to Shenfield Station).
Outer Area
The sites in the outer area (beyond reasonable walking distance) present some difficulty. Some (Sow
& Grow and the three Warley sites (Ford Offices, Mascalls Lane and Pastoral Way) are close to bus
routes to Brentwood Station and High Street. For convenience, residents may choose to drive rather
than wait for the regular bus services (to which they have to walk). Brook Street has a regular bus
service to the High Street but not to the station and people are likely to drive there rather than
change buses in the High Street.
Ingatestone
The Ingatestone developments are just about walkable from the station and the limited number of
shops in Ingatestone High Street. The train service from Ingatestone is less frequent than from
Shenfield and people are therefore likely to drive there rather than use their local station. There is a
half-hourly bus service into Brentwood but many people are likely to opt to drive.
Northern Villages
Existing bus services are not sufficiently attractive to residents to persuade them to use them rather
than to drive. The addition of 169 additional units is unlikely to change the economics until bus
companies can justify later evening services for returning commuters and socialising residents. It is
likely than buses will remain very much the less favoured option. The consequence is higher volumes
of traffic on feeder roads into Brentwood such as the already-congested A128 and Doddinghurst
Road.
Dunton Garden Village
It is likely that residents of the proposed Dunton Garden Village will look towards Basildon and
Lakeside for their shopping and leisure activities, meaning that the injection of consumer spend in
the core settlement of Brentwood is likely to be minimal. The demand for public transport will
reflect this, with the benefit of increased capacity and potential new routes spread laterally along
the A127/A13 corridor than northwards into the rest of the borough.
Congestion
Any additional or enhanced bus services into Brentwood will have to cope with increased congestion
in the mornings on the A128 through Herongate and Ingrave - in fact it is difficult to see how much
more traffic can be accommodated on this section of road even without additional developments.
Brentwood's centre is already heavily congested at peak times, especially since the County Council's
revised school transport policy has left many parents from the Northern Villages in particular reliant
on private transport. The congestion is acute on the A128 from Pilgrims Hatch into Brentwood and
from Herongate/Ingrave, with consequent congestion on Shenfield and London Roads. There are
other bottlenecks in Kings Road and around the cluster of schools in Sawyers Hall Lane.
All of this will only get worse as the number of vehicles follows the predicted increase and the
addition of more than 2,000 homes around Brentwood but outside walking distance (and excluding
Ingatestone and Dunton) will only make things worse.
There will be consequences for parking (already barely adequate at peak times), pollution with the
levels of gases and particulates increasing to the detriment of people's health, and for the viability of
commercial bus services as their reliability and regularity is challenged.
All this makes the Plan's strategic objective ("to improve public transport infrastructure and ensure
development sites are well connected to bus and/or rail connections") a massive challenge.
Commercial partners will not join until the revenue benefits are clear and the costs defined. It is
unlikely this will precede the developments. In some cases (Northern Villages) the proposed
developments are too small to make more than a marginal difference to the economics of public
transport but they will suffer most if the road system is catastrophically congested.
The Other Strategic Objective
The Plan offers the following objective: "to improve cycling and walking facilities across the Borough
and establish a grid or network of green transport corridors".
Cycling and walking are technically possible in the central and outer areas now. In practice
Brentwood is a hostile environment for both cyclists and pedestrians. For the former, pavements are
in a degraded state across the borough and the County Council's belated allocation of £700,000
across the County in reality allows little scope for massive improvement. Opportunities to negotiate
crossings in the High Street and immediate area are few and far between, with the priority always
seeming to be swung towards motorised traffic and the mantra of keeping traffic flows constant.
For cyclists, Brentwood is a potential death trap, with the residual potholes that fail to meet ECC
criteria for repair a constant and potentially lethal hazard. The general absence of cycle lanes
militates against safe use of the main roads; junctions are structured for vehicles and not bicycles.
For the outer areas, the high speed of traffic on the main routes, the narrowness of lanes and the
absence of cycle lanes militates against their use.
Conclusion
The Brentwood Bus and Rail Users recognises the imperative on Brentwood Borough Council to
provide additional housing in the area. It is, however, deeply concerned that the number and
distribution of proposed new dwellings will, if car ownership remains unchanged, place an
impossible burden on the existing road system and in particular on the existing network of bus
services. Delays to buses caused by congestion will not encourage greater use - and we fear the
reverse, with proportionately more people using private transport.
With no reference in the Plan to innovative solutions such as park-and-ride, and only lip service paid
to the encouragement of cycling and walking as an alternative, the Association fails to see how the
requirement that delivery of the Plan is environmentally sustainable can be met.
David Jobbins
Vice Chair, Brentwood Bus and Rail Users' Association

The Brentwood Bus and Rail Users' Association represents the interests of users of public transport in the Brentwood district.
Its aims and objectives are fourfold:
* To make representations on behalf of Brentwood's bus and rail users on the local services that are currently available and to campaign for new services to be .
* To campaign for more investment in local bus and rail services.
* To have regular dialogue with the local transport providers and Essex County Council.
* To work with other organisations and individuals to improve and develop local bus and rail services in our area.
In pursuit of these aims and objectives it wishes to comment on the implications of the Local Development Plan as amended by the Extraordinary Council Meeting on 8th November 2018.
The Plan will clearly have far-reaching implications for Brentwood's public transport network. First, it changes significantly the size and distribution of the borough's population and the consequent additional requirements for ways to access work, health and education, shopping and leisure. Secondly it will add to the already problematic traffic congestion issues at known pinch-points in the borough, which are already making it very difficult for bus operators to maintain a regular and efficient service.
It is therefore a matter of extreme concern for the Association that there are only four references to public transport in the document citing preferred allocations.
Most are in the aspirational vein of the Strategic Objectives
* Improve public transport infrastructure and ensure development sites are well
connected to bus and/or rail connections.
* Secure the delivery of new infrastructure to support a lower carbon future including
electric vehicles charging points and other measures.
* Improve cycling and walking facilities across the Borough and establish a grid or
network of green transport corridors.
This contrasts with health and school capacity, which are dealt with in some detail.
There are no references to traffic congestion, to which the Plan will clearly contribute. There are three references to bus services, one in the strategic objective and two in relation to one preferred site for an employment site which "has the potential" for development of bus services i.e. there are none at the moment.
It is difficult to see how a plan can be called strategic without proper consideration of public transport (i.e. buses as rail transport relates to travel in and out of the borough) within the borough. There is no mention of how congestion, which already inhibits travel within the borough and is predicted to increase even without the additional housing and business development.
There is limited scope for road improvements in the borough and additional developments are
outside the control of the planning authority. Increased congestion will impact on the ability of bus
operators to provide a regular and efficient service, reducing the extend to which they will be taken
up by users and increasing the likelihood that they will prove uneconomic and be withdrawn.
The impact of the proposed allocations
Central Area
The Ford Offices are excluded from this section and allocated to the Outer Area in the table below as
the site, although served by buses, is too far for most people to consider the station walkable while
Brentwood High St most certainly is not.
It is assumed that most people would find it possible to walk to Brentwood station and to the High
Street. A regular bus service is available from Warley (Council Depot) and from close to the Shenfield
sites (Priests Lane is walkable to Brentwood High Street but probably closer to Shenfield Station).
Outer Area
The sites in the outer area (beyond reasonable walking distance) present some difficulty. Some (Sow
& Grow and the three Warley sites (Ford Offices, Mascalls Lane and Pastoral Way) are close to bus
routes to Brentwood Station and High Street. For convenience, residents may choose to drive rather
than wait for the regular bus services (to which they have to walk). Brook Street has a regular bus
service to the High Street but not to the station and people are likely to drive there rather than
change buses in the High Street.
Ingatestone
The Ingatestone developments are just about walkable from the station and the limited number of
shops in Ingatestone High Street. The train service from Ingatestone is less frequent than from
Shenfield and people are therefore likely to drive there rather than use their local station. There is a
half-hourly bus service into Brentwood but many people are likely to opt to drive.
Northern Villages
Existing bus services are not sufficiently attractive to residents to persuade them to use them rather
than to drive. The addition of 169 additional units is unlikely to change the economics until bus
companies can justify later evening services for returning commuters and socialising residents. It is
likely than buses will remain very much the less favoured option. The consequence is higher volumes
of traffic on feeder roads into Brentwood such as the already-congested A128 and Doddinghurst
Road.
Dunton Garden Village
It is likely that residents of the proposed Dunton Garden Village will look towards Basildon and
Lakeside for their shopping and leisure activities, meaning that the injection of consumer spend in
the core settlement of Brentwood is likely to be minimal. The demand for public transport will
reflect this, with the benefit of increased capacity and potential new routes spread laterally along
the A127/A13 corridor than northwards into the rest of the borough.
Congestion
Any additional or enhanced bus services into Brentwood will have to cope with increased congestion
in the mornings on the A128 through Herongate and Ingrave - in fact it is difficult to see how much
more traffic can be accommodated on this section of road even without additional developments.
Brentwood's centre is already heavily congested at peak times, especially since the County Council's
revised school transport policy has left many parents from the Northern Villages in particular reliant
on private transport. The congestion is acute on the A128 from Pilgrims Hatch into Brentwood and
from Herongate/Ingrave, with consequent congestion on Shenfield and London Roads. There are
other bottlenecks in Kings Road and around the cluster of schools in Sawyers Hall Lane.
All of this will only get worse as the number of vehicles follows the predicted increase and the
addition of more than 2,000 homes around Brentwood but outside walking distance (and excluding
Ingatestone and Dunton) will only make things worse.
There will be consequences for parking (already barely adequate at peak times), pollution with the
levels of gases and particulates increasing to the detriment of people's health, and for the viability of
commercial bus services as their reliability and regularity is challenged.
All this makes the Plan's strategic objective ("to improve public transport infrastructure and ensure
development sites are well connected to bus and/or rail connections") a massive challenge.
Commercial partners will not join until the revenue benefits are clear and the costs defined. It is
unlikely this will precede the developments. In some cases (Northern Villages) the proposed
developments are too small to make more than a marginal difference to the economics of public
transport but they will suffer most if the road system is catastrophically congested.
The Other Strategic Objective
The Plan offers the following objective: "to improve cycling and walking facilities across the Borough
and establish a grid or network of green transport corridors".
Cycling and walking are technically possible in the central and outer areas now. In practice
Brentwood is a hostile environment for both cyclists and pedestrians. For the former, pavements are
in a degraded state across the borough and the County Council's belated allocation of £700,000
across the County in reality allows little scope for massive improvement. Opportunities to negotiate
crossings in the High Street and immediate area are few and far between, with the priority always
seeming to be swung towards motorised traffic and the mantra of keeping traffic flows constant.
For cyclists, Brentwood is a potential death trap, with the residual potholes that fail to meet ECC
criteria for repair a constant and potentially lethal hazard. The general absence of cycle lanes
militates against safe use of the main roads; junctions are structured for vehicles and not bicycles.
For the outer areas, the high speed of traffic on the main routes, the narrowness of lanes and the
absence of cycle lanes militates against their use.
Conclusion
The Brentwood Bus and Rail Users recognises the imperative on Brentwood Borough Council to
provide additional housing in the area. It is, however, deeply concerned that the number and
distribution of proposed new dwellings will, if car ownership remains unchanged, place an
impossible burden on the existing road system and in particular on the existing network of bus
services. Delays to buses caused by congestion will not encourage greater use - and we fear the
reverse, with proportionately more people using private transport.
With no reference in the Plan to innovative solutions such as park-and-ride, and only lip service paid
to the encouragement of cycling and walking as an alternative, the Association fails to see how the
requirement that delivery of the Plan is environmentally sustainable can be met.
David Jobbins
Vice Chair, Brentwood Bus and Rail Users' Association

Bellway Homes and Crest Nicholson representations Brentwood Regulation 19 Pre-Submission Local Plan (February 2019)
Merits of our client's landholdings and the Dunton Hills Garden Village
Bellway Homes and Crest Nicholson's landholdings (part of allocation R01) are unconstrained, suitable, deliverable and available. As such the landholding can be brought forward as part of the wider Dunton Hills Garden Village allocation.
Our clients are housebuilders, not land promoters, and are seeking delivery at the earliest opportunity pending suitable access. Crest Nicholson and Bellway Homes will continue to work with officers and Councillors (and other landowners/developers) to help bring forward this key site for meeting local housing needs in South Essex. It is absolutely right that the allocation should not be anchored to the work that will be carried out as part of the Association of South Essex Local Authorities (ASELA) and the emerging Joint Strategic Plan (JSP).
The identification of strategic scale sites to meet Brentwood's housing needs is supported, as is the principle of a new settlement via the Dunton Hills Garden Village Strategic Allocation (Policy R01) and its ambition for the delivery of additional homes beyond the plan period. The allocation represents an efficient use of greenfield land adjudged to be sustainable. Similarly we commend the Council for taking the decision to bring forward strategic greenbelt release alongside a comprehensively planned new settlement.
Our clients would support improved integration with Basildon alongside a landscape solution/approach agreed via a Statement of Common Ground and complementary policy positions (and/or supporting text) in both the Brentwood and Basildon Local Plans. This would help to deliver Dunton Hills Garden Village and the future expansion of West Basildon whilst maintaining separation physically through the provision of publicly accessible green infrastructure and improving connectivity for new and existing residents. Our clients do not support the position taken by Basildon Borough Council and have submitted representations objecting to the draft Basildon Local Plan.
Policy SP02: Managing Growth
Paragraphs 4.11 - 4.21 of the draft plan set out Brentwood's housing need position based upon the application of the standard methodology for calculating a minimum Local Housing Need figure; and the identification of a 20% buffer of housing sites for the first five years of the plan. The plan, at paragraph 1.38, also states that:
"..it may be necessary to review the Brentwood Local Plan, at least in parts, to ensure any opportunities for further growth and infrastructure provision in the Borough identified in the Joint Strategic Plan can be realised."
Our clients support this approach. Brentwood is seeking to meet their identified housing needs in full plus a sufficient buffer in the early part of the plan period. Crucially the draft plan is not using the JSP as a reason for deferring difficult planning decisions. As such, the draft plan is not reliant upon the emerging JSP to meet Brentwood's needs up to 2033. There has been no consultation to date on the JSP (as at March 2019) and it would be wholly unsound to rely upon a future JSP to meet identified needs up to 2033. Our clients support the pragmatic approach set out by Brentwood which is in accordance with the National Planning Policy Framework (paragraphs 11, 16 and 26 - a 'positively' prepared plan that seeks 'opportunities to meet the development needs' of their area and is 'sufficiently flexible to adapt to rapid change').
Our clients would advocate delaying submission of the publication plan until the 2018 affordability ratio data is released by the Office for National Statistics (the data used in the standard methodology for calculating housing need), due for publication in March/April 2019. This would allow time for factual updates to be made to Policy SP02 and housing target. Should submission come before the publication of the affordability ratio data, Brentwood should consider over allocating sites to increase the buffer of sites over for the whole plan period - sufficient to provide flexibility in respect of any increases brought about by the new affordability data published prior to or shortly after submission.
aecom.com
7/14
The recent release of the Housing Delivery Test (HDT) in February 2019 confirmed that Brentwood and all the other ASELA authorities (with the exception of Thurrock) have to identify a 20% buffer to their five year housing land supply and prepare a HDT Action Plan by August 2019. The minimum Local Housing Need figure (produced by the new standard methodology) will be applied to all authorities from 2018/19 for the purposes of the HDT (unless there is a plan that is less than 5 years old). As such Brentwood (and Basildon) will both be subject to HDT assessment on the basis of the minimum Local Housing Need figures until such time that their plans are adopted.
Table 1 (below) shows the HDT results published by MHCLG (19th February 2019) for all Councils that make up the ASELA. This shows housing delivery has only been achieved in one of the past three monitoring years (2016/17) for Basildon and it was never achieved by Brentwood. The HDT results evidence a persistent under delivery of housing in the South Essex region. Brentwood and Basildon are at risk of failing the HDT thresholds in 2019 and 2020. At present, Brentwood is in danger of falling below the 45% threshold this November 2019. This would leave the authority open to the presumption in favour of sustainable development (the 'tilted balance') and susceptible to speculative applications outside of the identified draft allocations. For Basildon there is a real risk that they will also be captured by the presumption in favour of sustainable development (75% threshold) as early as November 2020. Basildon's position is even more precarious given that they have not identified sufficient land to meet their minimum Local Housing Need, let alone a 20% buffer for the first five years, in their previous consultation draft plan.
Table 1 South Essex HDT results (MHCLG, February 2019)
[see attachment]
This illustrates the severity of the housing crisis in South Essex and the pressing requirement for all ASELA authorities to identify sufficient land supply (to meet their needs and a 20% buffer for the first five years) and maintain the plan-led approach. Basildon's failure to allocate sufficient sites to meet housing needs will impact the other ASELA partners (e.g. increased unmet needs in the region).
Duty to Cooperate
The above issues should be addressed as a matter of urgency through Brentwood and Basildon's Duty to Cooperate Statements of Common Ground. A Duty to Cooperate position statement is welcome, although the MOU with the ASELA is insufficient to evidence the detailed Duty to Cooperate matters that need to be addressed with Basildon. A Statement of Common Ground that outlines areas of uncommon ground would be just as valuable in advance of submission of both plans and the forthcoming examinations.
This will help to avoid creating inconsistencies or prejudice any future plan making as part of the ASLEA JSP. If Basildon and Brentwood both wish to avoid the appearance of sprawl along the A127, this can be achieved through a simple Statement of Common Ground and via identical high-level policies (or supporting guidance) in each Local Plan. At present the current policy position does not ensure an integrated approach to delivery of the Garden Village and adjacent sites to the West of Basildon. It is our client's view that a failure to tackle this issue head-on now could stall delivery on Dunton Hills Garden Village. The JSP is not the appropriate vehicle for resolving a planning issue within the emerging Basildon and Brentwood plans; this matter must be resolved prior to submission, of both Local Plans (ideally via a Statement of Common Ground).
Policy NE13: Site Allocations in Green Belt / Policy HP18: Designing Landscape and the Public Realm
Our clients support the strategic release of greenbelt sites in sustainable locations. Dunton Hills Garden Village has followed a robust Green Belt review; Sustainability Appraisal; and site selection process. The draft plan does not allocate land between Dunton Hills Garden Village and West Horndon; therefore it maintains physical separation and avoids the coalescence of the new settlement and existing built up area of West Horndon. To date there is no evidence that it would be possible to meet the Borough's acute housing needs without amending the Green Belt boundaries as proposed in the draft plan.
The Stage III Green Belt Review January 2019 (GBR3) continues the work of the previous two stages. Again the methodology used appears sound and has been consistently applied. GBR3 assesses the DHGV site, Parcel 200, as being Not Contained, exhibiting Significant Separation Reduction between settlements, as being Functional Countryside and of Limited Relationship to Historic Towns. This results in an overall conclusion of Parcel 200 making a moderate to high contribution to the Green Belt. As with the LSCA the scale of DHGV inevitably results in elevated scores.
The Dunton Hills Garden Village allocation (shaded yellow) and wider Green Belt parcel incorporating land West of Basildon in Basildon Borough (shaded red) shown on Figure 1 (below) is an area bounded by the A127, the A128, a railway line and the western edge of Basildon - there are few (if any) examples nationally of more contained and defensible boundary in Green Belt terms.
Figure 1 Green Belt Context: Land West of Basildon (red) and Dunton Hills Garden Village (yellow)
[see attachment]
There would be clear separation maintained between Dunton Hills Garden Village and West Horndon in Brentwood Borough. Paragraph 9.12 is also supported as it recognises that "The B148 (West Mayne) is the eastern road beyond the borough boundary separating the site from the built-up area of Basildon". If Dunton Hills Garden Village and the land West of Basildon (in Basildon Borough) are both allocated it is only logical to remove all of this land from the Green Belt based upon the strong defensible boundaries that exist for both areas. Landscape approach, design principles and physical separation can (as previously discussed) be dealt with via a Statement of Common Ground and complementary Local Plan policies (and guidance) in the respective plans. Policy R01 includes a detailed statutory policy to ensure the new settlement is comprehensively planned via landscape-led approach. This will ensure the development is not simply ribbon development along the A127 and instead an autonomous Settlement Category 2 Garden Village that will complement the existing settlement hierarchy and is well related to the existing communities of Basildon and Laindon and West Horndon.
The Landscape Sensitivity and Landscape Capacity Study: Potential and Strategic Allocation Options October 2018 (LSCA) assigns a landscape capacity to the potential allocations. The methodology used appears sound and has been consistently applied. The LSCA identifies the DHGV site, Parcel 200, as being of high landscape sensitivity, medium - low landscape value and medium - medium low landscape capacity. It is noted that the scale of the strategic options considered make comparison with smaller sites difficult. The scale of DHGV inevitably results in elevated scores.
The site is not the subject of any landscape quality designations that would prevent development. Our clients consider that Policy HP18: Designing Landscape and the Public Realm, in combination with Policy R01(I) clause C, provide an adequate policy framework for guiding a future landscape scheme - including the provision of green infrastructure between R01 and the development of the West of Basildon.
Policy R01: Dunton Hills Garden Village Strategic Allocation
The policy would benefit from being shortened and simplified. Much of the detail could instead be covered in the supporting text. Our clients would recommend a less prescriptive policy in favour of a series of development principles. The policy also recognises the appropriate phasing of infrastructure and mechanisms for delivery. However, our clients have a number of detailed comments to help enhance the clarity and utility of the draft policy.
R01(I)
 Clause B uses the term "self-sustaining" - this is currently an undefined term in the context of the facilities that may be required by future residents. It is likely that services and schooling would also be accessed in Basildon and so the policy should also recognise the importance with connectivity to nearby allocations and settlements in Basildon Borough. Whilst appreciating the need for a garden village to be separate, it should also be appropriately connected and complimentary to nearby settlements.
 There is a slight inconsistency between policy clauses A and D in the use of "around 2,700 homes" and "at least 2,700 homes" in the plan period. Our clients would favour the more positive "at least" in light of the pressing housing needs in the area.
 Policy clause D(c) currently expresses a requirement for employment land as 5.5ha. An alternative approach would be to also reference a jobs figure, employment densities are not fixed and the policy will need to remain flexible to provide the optimum employment solution on the site up to 2033.
 Policy clause D(d) references a co-located Secondary school, but this term is not defined in terms of what facilities could be appropriately co-located or any indication on forms of entry etc. This clause could cross reference to the Infrastructure Delivery Plan that shall remain a living documented capable of being updated as the development of the site evolves.
 Policy clause D(h) states 50% of the "total land area", this term is not defined and may have implications for the net developable area. Without the benefit of a detailed masterplan and Environment Statement supporting an application this requirement appears needlessly onerous and will make the allocation less flexible. We would suggest removal of a specific percentage in advance of further masterplanning and consultation.
R01 (II)
 Policy clause C(f) states: "a green infrastructure buffer / wedge on the eastern boundary with Basildon Borough to achieve visual separation to help significantly improve the landscaped and habitat value thus reinforcing the beneficial purpose and use of the green belt in that zone." This matter needs careful consideration in advance of submission in light of Basildon's representations and their erroneous position on Green Belt coalescence and countryside encroachment in their draft plan (which fails to allocate sufficient land to meet needs). Brentwood should provide further clarity that this separation can be achieved without sterilising large tracts of the allocation. A modest multifunctional green gap running north-south in close proximity to the Borough boundary would be a proportionate response in this location.
 Policy clause D(c) states "pathways through the green and blue infrastructure (GBI) network will be made of permeable material and follow a coherent treatment throughout the village. The pathways will all connect into a circular walk, with interconnected shortcut routes and be signposted offering directions to key destination points". It is premature at this stage to place overly restrictive pathway design where they may be sound place-making reasons for not following this approach in all areas.
 Policy clause I(a) states that emphasis will be given to: "incorporating car sharing clubs and electric vehicle only development". Whilst the principle is supported, this may not be appropriate for all areas of this large allocation and would be overly restrictive.
 Policy clause L(b) includes a small typo for BREEAM. This clause should make clear that BREEAM is for certain types of building only.
R01 (III)
 Clause B states: "The development and phased delivery of DHGV must ensure the timely delivery of the required on-site and off-site infrastructure to address the impact of the new garden village". Whilst supported and the timely delivery on infrastructure is essential in the creation of a sense of community, off-site infrastructure may be beyond the control of the primary land owners/promoter, and risks stalling development if a Grampian condition is envisaged.
An explicit policy clause is urgently required to ensure for a no ransom position. The primary developer must build roads up to the boundary of Crest Nicholson and Bellway Homes landholding. Without this added clause the allocation would be ineffective based upon the tests of soundness.
The Site benefits from the involvement of volume housebuilders which, according to the Letwin Review (2018), leads to a variety in product and higher build out rates. An extensive analysis of national house builder annual reports, conducted by Turley on behalf of Bellway Homes, demonstrates that average delivery rates (per outlet) range from between 40-58 units pa1. There is potential for sites (normally larger sites) to see a number of outlets building new homes at any one time. Additional outlets are sometimes in the form of a different house builder, but it can also be in the form of different products sold from different marketing suites by the same house builder. Crest Nicholson and Bellway Home's landholdings are jointly promoted in order to deliver high quality sustainable developments at pace and will help to achieve the housing trajectory set out in Appendix 1 of the draft plan.
The plan's delivery trajectory relies on increased delivery in the later part of the plan period (partly reliant on infrastructure investment). This emphasises the importance of infrastructure equalisation and removing any ransom scenarios as far as practically possible through statutory policy. In addition, it would be prudent for the ASELA authorities to work together to lever in external funding for reinforcements such as the gas pipeline to enable an alternative access arrangements and internal connectivity that would release more development land for housing and public open space later in the plan period.
R01 Supporting text comments:
 Paragraph 9.30 includes a reference to 'Medium' density- but this is not defined. The allocation location is in close proximity to Basildon and West Horndon and the potential for sustainable modes of transport lends itself to higher densities in district and local centres.
Transport policies B11 - B17
The general approach taken to transport within the Local Plan with the Built Environment policies (BE11 to BE17) is supported and it can be seen that these policies are feeding through into the policies for the site specific allocations.
The evidence base for the Local Plan includes Brentwood Borough Local Plan Transport Assessment (Local Plan TA) dated (October 2018) prepared by PBA and the Infrastructure Delivery Plan (IDP) prepared by the Council. These documents together provides the transport element of the evidence base and support the Council's proposed development strategy including the proposed development at Dunton Hills. They are essential elements of the evidence base and their soundness is not questioned in these representation, however, the conclusions of the Local Plan TA and the IDP need to be better reflected in the Local Plan.
The Local Plan TA sets out the approach to the modelling work, results of modelling and junction assessment, highlights those worse performing junctions that may require mitigations, the sustainable measure proposed and the impact this has on the junction assessment to enable the development sites to come forward. The assessment covers key 27 junctions within Brentwood planning authority.
The assessment assumed that DHGV would provide 2,500 new homes in the Local Plan period along with 5.5ha of employment land. In addition, number of sites located within Basildon Borough Council and Havering Borough Council were included within the reference case scenario in order to accurately assess the impact of Brentwood Local Plan. The West Basildon Urban Extension was included within the reference case assuming provision of 1000 new homes as per 2016 Basildon Local Plan publication.
The Local Plan TA identifies a number of junctions that would need to be improved across the Borough to support the development proposed in the Local Plan. However, the Local Plan Submission Version does not include reference to these. As an example, the following table contains the identified improvements in the surrounding roads to Dunton Hills Garden Village.
Table 2 Results of PBA capacity assessment, Brentwood Local Plan Evidence Base
[see attachment]
While it is clear that some of these improvements would be provided via Essex County Council (ECC) or Highways England as the relevant highway authorities there is no reference made in the Local Plan to them. It would be expected that the evidence base would transfer through to the IDP to be clear on how and when these identified infrastructure improvements would be provided.
As each identified allocated site comes forward to a planning application stage it will define what highway improvements are needed through the Transport Assessment associated with the individual site. However, guidance should be given on what improvements have been identified as part of the Local Plan TA to ensure that the need for them is considered and if they are required then how would they be funded i.e. guidance is needed on the scope for any future Transport Assessments to support developments.
The IDP contains a similar table for highway infrastructure improvements and those relevant to Dunton Hills Garden Village are listed in Table 3 below:
Table 3 IDP Schedule extract.
In addition to four infrastructure requirements relating specifically to DHGV a number of requirements are set out in the IDP for new developments and site allocations coming forward in the Local Plan period. Key improvements to be delivered as part of DHGV development are:
 DHGV: Widening Connectivity - further feasibility studies required to improvements of pedestrian connectivity across the A127 and A128;
 DHGV: Walkways/ Cycleways - provision of a good footway and cycle way network;
 DHGV: Sustainable Transport Infrastructure - provision of cycle hub within the DHGV site; and
 DHGV: Public Realm and Village Square - subject to detailed masterplanning good quality pedestrian centres should be provided.
It is acknowledged within the proposed policy for Dunton Hills Garden Village that reference is made for the need for a Transport Assessment report to be undertaken and this is where the detailed assessment can be made of the highway infrastructure needed to support the proposed allocation. However, there should be some reference to the published evidence base to guide the scope of this work. This is not to say that the identified improvements will be needed, but they should be considered as they have been identified within the evidence base.
Attendance at the examination hearing sessions
Our clients request attendance at the relevant hearing sessions to make verbal submissions in response to matters and questions related to: the Duty to Cooperate; housing numbers and the spatial strategy, landscape, transport, infrastructure, deliverability and the strategic allocations. We reserve the right to make further representations at the examination hearing sessions, should work on Brentwood's Community Infrastructure Levy evolve in respect of any implications on strategic sites and their ability to deliver policy compliant schemes.

Withdraw plan as it stands. Consider brown field sites, infills and derelict properties,
Use parish council to communicate with the residents,
Establish a realistic proposal via the residents/parish council

The plan is unsound, not legally compliant and fails to comply with the duty to cooperate. Yet again green belt is being developed on. Blackmore struggles to deal with the amount of traffic and parking and will not cope with the new development. Doctors surgeries, public amenities are already at breaking point, how will they cope.
Increased risk of flooding
Withdraw plan as it stands. Consider brown field sites, infills and derelict properties,
Use parish council to communicate with the residents,
Establish a realistic proposal via the residents/parish council

The use of brownfield sites to build a modest amount of houses would be much more acceptable to most people in the local areas.
DO NOT build on Green Belt or Green Field sites for the good of the environment and wildlife. [Remove sites R25 and R26 from plan].

The building of the proposed houses is totally unacceptable in this village. There doesnt seem to be any thought given to the local area. Especially with regard to local infrastructure i.e. schools, doctors surgery, shops The existing traffic is getting so heavy there will be an accident soon. Parking has become a nightmare and parking on the pavement seems to be the done thing.
Getting a doctors appointment is very difficult and the school is already full. Green Belt land should not be used for building houses. Redrose Lane is what it sound, a lane and 2 cars passing is not an option.
The use of brownfield sites to build a modest amount of houses would be much more acceptable to most people in the local areas.
DO NOT build on Green Belt or Green Field sites for the good of the environment and wildlife.

The only practical solution is to remove sites R25 and R26. Take heed of the BVHA neighbourhood plan which identifies the actual requirement of local residents and proposes better suited alternative sites.

The plan is unsound.
Infrastructure already fails local needs: flood risk, school and doctors surgery at over capacity & struggle to cope, poor (virtually non existent) bus service, roads not suitable, insufficient parking in village centre.
BBC has not consulted with neighbouring authorities (ie: Epping and Chelmsford). Sites mentioned not suitable, Alternative sites (that are better suited have been ignored. There has been no "housing needs" survey.
The only practical solution is to remove sites R25 and R26. Take heed of the BVHA neighbourhood plan which identifies the actual requirement of local residents and proposes better suited alternative sites.

Sites R25 and R26 need to be removed from the plan.
I suggest the planners need to read the BVHA neighbourhood plan which includes the Blackmore local housing requirements for what is clearly an existing sustainable community.

Sections 04 08 09
Policy R25 nd R26

As far as I am aware no "housing needs survey" has been performed to show why Blackmore is included in the LDP. Blackmore is an established village and it would appear that an increase in demand on the infrastructure is not viable. I understand that the village school s full and the Deal Tree medical centre is reported to have one of the highest patient to practitioner rations in certainly Essex.
The access onto and off Red Rose Lane will not be suitable for the anticipated increase in traffic.
The sites R25 and R26 have over the years suffered from persistent flooding.
I believe that around 30 houses are being or will be constructed at the top of Fingrith Hall Lane.
Sites R25 and R26 need to be removed from the plan.
I suggest the planners need to read the BVHA neighbourhood plan which includes the Blackmore local housing requirements for what is clearly an existing sustainable community.
The items I have referred to in my response were patently inadequately discussed in the prematurely shortened meeting chaired by the Mayor.

Remove sites R25 and R26. Consider what Blackmore really needs not what ticks a few boxes, and hat suits developers. The BHVA have worked hard to proposal alternative which are sustainable. They know the village better then the people behind the unsustainable proposal currently on the table.

Local plan Is unsound
The sites are unsuitable for building, they are liable to flood and the road is not suitable as it is too narrow & also it regularly floods, cars get trapped.
I am unaware if a housing need survey is being carried out.
The infrastructure is already at bursting point. Children turned away from the local school as full; Drs surgery over stretched already; no parking in village centre
Because we are on the Brentwood borders, no account has been taken of the development being undertaken by Epping & Chelmsford RIGHT ON OUR DOORSTEP, impacting on local facilities.
Alternative sites have been ignored, even when more suitable,
Inadequate public transport - you can't live here without a car. Most families have 2 or more.
Remove sites R25 and R26.
Consider what Blackmore really needs not what ticks a few boxes, and hat suits developers
The BHVA have worked hard to proposal alternative which are sustainable. They know the village better then the people behind the unsustainable proposal currently on the table.
These forms have been a nightmare to complete. I would suggest that this is the only way to get our case across, & people should be given a chance to express themselves in person.

Remove R25 and R26 from plan

Section 04
Section 08
Section 09
Policy R25
Policy R26
Doctors. The project needs to be cancelled because having more houses and people in Blackmore will have an effect on the local Doctors surgery, it is already busy and difficult to get appointments so more people will affect our health.
School. The local school is a small village school so more children attending will mean the school needing to be expanded and made bigger and there is no area for this to be done.
Green Belt Land. The area the houses are being built on Green Belt land so the beautiful village will become overcrowded and the countryside ruined, so it affects all the local wildlife and wild animals too.
Local transport - buses transport. There would be a need for more buses and local transport and this means roads where there are no footpaths will become dangerous for local residents and the council having to provide more services and the area becoming dangerous as its only a small village with roads being able to cope with a small amount of traffic so it will be dangerous on the footpaths and the roads.

R25 and R26 should be removed from the LDP and planners should refer to the Blackmore Village Heritage Association 'Neighbourhood Plan', which clearly sets out the local housing needs for our already sustainable community.

I consider the Plan to be unsound, not legally compliant and fails to comply with the duty to cooperate for the following reasons: The Sustainability Appraisal (January 2019) refers to improvement of services and facilities in rural areas but that is completely undermined by the impact that proposed developments R25 & R26 will have on residents of Blackmore and those in surrounding areas reliant on Blackmore facilities. Blackmore village is categorised as Cat. 3 (large village) however this is outdated as the village now consists of just one small village shop (inclusive of a Post Office counter) and one small primary school. Parking to access these facilities is extremely limited thereby causing significant issues for existing residents, whilst Public transport to and from Blackmore village is already inadequate for existing residents of the village and surrounding communities. The challenges facing Blackmore village, as set out above, are already heightened by the current (EFDC) development of 30 houses in Fingrith Hall Lane and by a proposed development of affordable housing in Nine Ashes Road (EFDC). The nearest doctors surgery is in Doddinghurst and despite development / enlargement of the surgery with the last few years that continues to struggle to cope with existing demands from Blackmore, Doddinghurst and other surrounding villages. Furthermore, the proposed developments of R23 & R24 will also add to the burden. Given the potential impact on local infrastructure, services and facilities I am extremely concerned to have seen no reference to adequate consultation between BBC and EFDC. Blackmore village is comprised of circa 330 dwellings with a population of 829. The Local Plan has the potential to add close to one quarter to this and that takes no account of EFDC developments referred to above. The Sustainability Appraisal (SA) 2019 includes an objective to reduce flood risk. Blackmore already has significant challenges and instances of flooding are a matter of photographic record. Further development will almost certainly make a bad situation worse and hereby also conflict with the SA. No Housing needs survey has been conducted that demonstrates why Blackmore should be included in the LDP, furthermore, the decision to include Blackmore contradicts the LDP (2016) which stated that growth in rural north and rural south areas of BB would be limited in order to retain 'local character'. BBC has failed to demonstrate that there are other brownfield sites that are available and these should take priority over the greenfield land off of Red Rose Lane. The proposed developments in Blackmore do not promote 'sustainable development' and other more suitable / sustainable locations should be considered such as urban extension to Brentwood and further additions to the 'Dunton Hills Garden Village' project. On a final note there is no evident clear strategy for the villages in the north of the Borough, Blackmore being just one example. As a consequence it appears that decisions have been made within the Local Plan that take no account of the challenges that are already faced, the impact that the plan would have on these challenges and instead the decision to add 70 plus homes to what is a small village community seems to be based on 'targets need to be met for new houses - where we can put them'.

Do not believe Green Belt land in Blackmore should be released for this development as part of BBC local plan due to all aforementioned reasons (and probably many others!)

Section 04
Section 08 - especially Re: Green Belt and Flood Risk
Section 09 Policy R25, Policy R26
A residential development such as has been submitted for Blackmore will further stretch infrastructure (roads, parking, schooling, doctors, etc). There are more sustainable locations in the borough. There are "brown field" sites available which should be prioritised over green field sites. This area of Blackmore is known to be a flood risk (23 June 2016). Do not believe Green Belt land in Blackmore should be released for this development as part of BBC local plan due to all aforementioned reasons (and probably many others!)

Remove sites R25 and R26

There is no clear strategy for the village BBC have not consulted adequately with neighbouring authorities. Blackmore is an isolated village with limited services. No space in the village school for our children. No adequate bus routes / parking / doctors. There is other suitable locations other than Blackmore Village. The access off / from redrose lane is entirely unsuitable for the volume of traffic. The sites are liable to flood and building on this land will also increase the flood risk elsewhere in the village.

Cancel the project. Blackmore and its environs are already in danger of forever being changed. There are plenty of other brownfield sites in Brentwood to consider, we have already had our fair share of new builds in Brentwood.

Section 04
Section 08
Section 09
Policy R25,
Policy R26

unsound and all unsound ticked.
Local services being overwhelmed: schools; doctors; transportation hubs; more crime ie: not enough police; more demand on firefighters. More cars on road leading to very dangerous conditions for young children on footpaths.

Cancel the project. Blackmore and its environs are already in danger of forever being changed. There are plenty of other brownfield sites in Brentwood to consider, we have already had our fair share of new builds in Brentwood.

Yes attend
It is important as many local views are expressed to allow the proponents of this plan to gauge the strength of local opinion.

Remove sites R25 and R26

There is no clear strategy for the village BBC have not consulted adequately with neighbouring authorities. Blackmore is an isolated village with limited services. No space in the village school for our children. No adequate bus routes / parking / doctors. There is other suitable locations other than Blackmore Village. The access off / from redrose lane is entirely unsuitable for the volume of traffic. The sites are liable to flood and building on this land will also increase the flood risk elsewhere in the village.

Sites R25 and R26 should be removed from the plan and that planners should refer to the BVHA neighbourhood plan which clearly sets out our local housing needs for our already sustainable community.

Sections: 04; 08; 09: see attached. Site allocations, disproportionate growth to Blackmore, flood risk, green belt. Blackmore infrastructure cannot cope now, without all the planned dwellings, We cant park in the village, our school is full, doctors waiting time is lengthy.

A sound local plan would require: 1. The assessment must take into account the modest and limited services in the village, including the shop, doctor surgery, primary school and parking. 2. The character and nature of the village must be carefully considered, and the current residents quality of life must be protected. 3. BBC needs to look at the many other suitable locations in the area which can sustain this type of development. 4. The problems with flooding need to be taken into account and current problems with flooding addressed.

Blackmore is a small isolated village with modest services and infrastructure. The large scale development plan being proposed will, without a doubt, negatively effect the quality of life of its residents. The plan is being proposed by a developer who holds no knowledge of the village itself, which has resulted in a proposal that is completely inappropriate. The facilities in Blackmore are limited and an influx of new residents would be detrimental. The following reasons clarify why: 1. The proposed plan would produce overcrowding, resulting in an unacceptable increase in traffic and noise, destroying the very nature of our village. 2. There is no clear 'strategy' for the village and there are many other more suitable and sustainable locations for development. 3. Parts of the village are liable to flood. Building on the proposed land would increase the flood risk everywhere in the village. 4. There is just one shop in our village, an overcrowded primary school, and a local doctor surgery where it is extremely difficult to get an appointment. Such an increase in residents is simply unmanageable. A sound local plan would require: 1. The assessment must take into account the modest and limited services in the village, including the shop, doctor surgery, primary school and parking. 2. The character and nature of the village must be carefully considered, and the current residents quality of life must be protected. 3. BBC needs to look at the many other suitable locations in the area which can sustain this type of development. 4. The problems with flooding need to be taken into account and current problems with flooding addressed.

I believe sites R25 and R26 should be removed from the LDP and planners should refer to the BVHA Neighbourhood Plan which sets out our Housing Needs for our already sustainable community.

The BBC has not consulted adequately with neighbouring authorities (Epping Council) who are in process of building c. 30 houses at top of Fingrith Hall Lane - the impact this has on the village where the infrastructure is not sound to incorporate extra traffic. There are other brownfield sites that are available and they must take priority over our precious greenbelt. The school is at full capacity and the doctors surgery would not be able to accommodate the extra numbers.

Sites R25 and R26 should be removed form the LDP and the planners should refer to the BVHA 'neighbourhood plan' which clearly sets out our local housing needs, for our already sustainable community.

Refer to attached form. The infrastructure is already stretched, and these additional developments would have a significant negative impact to the local community including provision for medical services and schooling. Bus services to larger employment locations (Brentwood Chelmsford, Epping) are totally inadequate. The designated sites have flooding issues, a problems across wider Blackmore footprint and development will cause further problems, increasing the flood rate.
There are other Brownfield sites within existing urban boundaries (and local infrastructure and transport grids) better suited to development, negating the need to destroy Green Belt environments. There has been no evidence that Blackmore has a housing need requiring such scale of development.
Sites R25 and R26 should be removed form the LDP and the planners should refer to the BVHA 'neighbourhood plan' which clearly sets out our local housing needs, for our already sustainable community.

We / I do not believe green belt land in Blackmore should be released for this development as part of BBC Local Plan due to all of the aforementioned reasons.

A residential development such as has been 1. submitted for Blackmore will further stretch the infrastructure (roads, parking, schools, doctors surgeries). 2. There are other more suitable locations in the borough. 3. There are brown field sites available which should be prioritised over green field sites. 4. The area of Blackmore is known to be a flood risk (23rd June 2016). 5. Access to and from the development site entirely unsuitable for increased traffic problems.

Consideration for local needs and infrastructure.

See attached.

Please refer to BVHA report - there are brownfield sites that should be considered first - there should be proper strategies for villages north of Brentwood.

I consider the Local Plan to be unsound for the following reasons: 1. making infrastructure issues - other roads are flooded in this area and I suspect building on this scale will add is the problems - infrastructure parking is often a problem in Blackmore, difficult to see and no school places at present. 2. we have been told in the past that Blackmore village would not be required to access additional housing numbers. 3. We often have walkers and cyclist and horse riders in those narrow roads so more traffic could be dangerous.

Sites R25 and R26 should be removed from the LDP and that planners should refer to the BVHA "neighbourhood plan" which clearly sets out the local planning needs for our already sustainable community.

1. Red Rose Lane is not suitable for urban development, Blackmore has modest services and infrastructure which are failing with the existing population. 2. Access to/from Red Rose Lane is unsustainable for the volume of traffic. 3. Red Rose Lane is prone to flooding and any construction on this site could push the problem onto current residents property.

Please refer to BVHA report - there are brownfield sites that should be considered first - there should be proper strategy for villages north of Brentwood.

I consider the Local Plan to be unsound for the following reasons: 1. Making infrastructure issues - other roads are flooded in this area and I suspect building on this scale would add is the problems - furthermore parking is often a problem in Blackmore, difficult to see appointment with the local GP service and no school places at present. 2. We have been told in the past that Blackmore village would not be required to access additional houses numbers. 3. We often have walkers and cycle and horse riders in those narrow roads so more traffic could be a danger.