Figure 2.3: Settlement Hierarchy

Showing comments and forms 1 to 13 of 13

Object

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

Representation ID: 23313

Received: 18/03/2019

Respondent: Mr John Riley

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The population of Blackmore is listed as 829. However, the area that this covers (see diagram below) does not cover, amongst others, the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2,402; however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3,040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan.

Full text:

I consider the plan to be unsound and fails to comply with the Duty to Cooperate for the following reasons:
1. LDP Fig 2.3 Settlement Hierarchy. There are errors and omissions in the plan. For example, the population of Blackmore is listed as 829. However, the area that this covers (see diagram below) does not cover, amongst others, the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site.
The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers.
2. Duty to Cooperate. There has been insufficient consultation with other neighbouring authorities.
100 metres outside the parish boundary in Fingrith Hall Lane is the entrance to a development of 30 new (large) houses by Epping Forest District Council. These properties are 1.3 miles from Blackmore village centre and its amenities and more than 5 miles from any other town / village with similar amenities. This will exacerbate the adverse impact of the proposed 70 (40 + 30) new properties being proposed for Blackmore on the infrastructure and amenities.
3. Red Rose Lane is a narrow single track road and is not suitable for the extra volume of traffic generated by the proposed housing. Also, along with many other roads in and around the Blackmore area, it is used regularly by walkers, joggers, cyclists, dog-walkers and horse riders. It has no pavements and so the additional traffic will bring increased danger to these users. There are also very few street lights in Blackmore and none in Red Rose Lane which increases the risks.
4. Flood Risk. The Blackmore village centre of sits in a hollow and is prone to flooding. Prior to the major development of the village in the 1970s there were no reports of any significant flooding. Since then there have been a number of occurrences of flooding. In 1986 a major flood occurred where many houses and St Laurence church were flooded and badly damaged. Flooding has occurred numerous times since with the most recent being 3 years ago when several houses on the Green were flooded and many of the surrounding roads (including Red Rose Lane) were impassable.
At St Laurence Church graveyard in Church Street when graves are dug they fill with water immediately and need to be pumped out prior to the burial due to the high water table in the area.
The addition of 70 properties will further reduce the available open land to soak up water and therefore flooding occurrences will increase.. This flood in 2016 along the Blackmore Road caused extensive damage to the pavement which has not yet been repaired.
5. Policy NE06 FLOOD RISK states in 8.52:
Flood risk include risk from all sources of flooding, including from rivers, from rainfall, from rising groundwater, which can overwhelm sewers and drainage systems, and from reservoirs, canals, lakes and other artificial sources. Incidences of high rainfall are forecast to increase in intensity as a result of climate change. Developing inappropriately in areas at risk from flooding, can put property and lives at risk; therefore, this policy seeks to ensure this does not happen.
Blackmore is not just a high flood RISK area, flooding in Blackmore is actually an ISSUE. Therefore any development in Blackmore is clearly against this policy.
6. Infrastructure Requirements. There are no infrastructure requirements listed in policy R25 or R26. However, all amenities and services are already overstretched.
* The electricity, other utilities and in particular the sewerage system are unlikely to be able to cope an additional 70 properties without counting the 30 extra properties in Fingrith Hall road. The sewerage system is at maximum capacity already
* The local primary school is already full - new arrivals in the village are not able to get their children into the school and have to travel to schools in other areas
* Bus services are limited, infrequent and do not run into the evenings
* There is insufficient parking in the village centre causing people to regularly park on double yellow lines and there is no provision for disabled parking.
* The doctors surgery is at capacity and waiting time for appointments are already unacceptable
7. There is no clear housing strategy for the villages and general area in the north of the Borough. There are many options that have been suggested through this process and should have been considered but have not been.
8. A 'Housing Needs' survey should have been carried out which would have demonstrated why Blackmore has been specifically included in the LDP, and why other more suitable areas have not been included.
9. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
10. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using Green Belt land.
11. Other more suitable locations (e.g. areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal for the reasons given.
12. The proposed sites are important wildlife and natural habitats for many creatures to live undisturbed.
13. Policy HP08 seeks to regularise an illegal traveller site on the Chelmsford Road. The Borough Council has failed to undertake its duty to attempt to remove the travellers from the site since they first moved in some years ago. The Council have sat back and watched the site grow without taking any action and must re-visit this. In regularising the site the council is providing open invitation for other travellers to do the same as the council will be seen to be weak, capitulating and an easy target area.
14. Policy SP02 states that new development will be directed towards highly accessible locations along transit/growth corridors. Blackmore is not highly accessible and not along a transit / growth corridor.
Due to the many issues listed above it is clear that the sensible modification would be to remove sites R25 and R26 from the Plan. However, in view of the need to accommodate the need for housing generally, there may be a case for limited development in Blackmore. However, the type and number of dwellings are crucial considerations, as is the impact on the local infrastructure which is currently struggling. The village is prone to flooding, education and health service provision is stretched, on street parking is inadequate, public transport is sparse and electricity supply to parts of the village is unreliable. To render the LDP sound, I suggest the deficiencies in the local infra structure needs to be addressed before any development is allowed. Then, reducing the proposal to one site, limiting the development to no more than 25 dwellings with a mix of 4&5 bedrooms houses, starter homes and 2&3 bedroom retirement bungalows with access/exit as a cul de sac onto Red Rose Lane only.
I wish to participate in the oral part of the EiP To outline my concerns over the plan and articulate why the development in Blackmore asit is currently proposed would be extremely detrimental to the area.

Attachments:

Object

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

Representation ID: 23673

Received: 26/04/2019

Respondent: Gladman Developments

Agent: Gladman Developments

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Plan sets out within the Settlement Hierarchy in Table 2.3 that the development of brownfield land will be prioritised. This requirement has no support in National Policy as Para 117 of the Revised Framework (2019) simply states that substantial weight should be given to the value of using suitable brownfield land. This requirement should therefore be changed to reflect Government guidance.
The prioritisation of brownfield land is also repeated in the Spatial Development Principles section under Paragraph 3.23 which similarly needs amending.

Change suggested by respondent:

Change requirement in Settlement Hierarchy in Table 2.3 that the development of brownfield land will be prioritised changed to reflect Government guidance.

Full text:

Brentwood Local Plan
Pre-Submission Document

CONTENTS
1 Introduction 2
1.1 Introduction 2
1.2 Context 2
2 National Planning Policy 3
2.1 National Planning Policy Framework 3
2.2 Planning Practice Guidance 4
3 Legal Requirements 7
3.1 Duty to Cooperate 7
3.2 Sustainability Appraisal 8
4 Spatial Strategy 9
4.1 Vision and Strategic Objectives 9
5 Managing Growth 10
5.1 Policy SP02: Managing Growth 10
5.2 Policy SP04: Developer Contributions 11
6 Resilient Built Environment 12
6.1 Policy BE02: Sustainable Construction and Resource Efficiency 12
7 Housing Provision 13
7.1 Policy HP01: Housing Mix 13
7.2 Policy HP06: Standards for New Housing 13
8 Conclusion 15
8.1 Overall Conclusion 15

1 INTRODUCTION
1.1 Introduction
1.1.1 These representations are submitted by Gladman in response to the current consultation on the Brentwood Local Plan Pre-Submission Document. Gladman specialise in the promotion of strategic land for residential development with associated community infrastructure.
1.1.2 Gladman has considerable experience in the development industry across a number of sectors, including residential and employment development. From that experience, we understand the need for the planning system to provide local communities with the homes and jobs that are needed to ensure that residents have access to a decent home and employment opportunities.
1.1.3 Gladman also has a wealth of experience in contributing to the Development Plan preparation process, having made representations on numerous local planning documents throughout the UK and having participated in many Local Plan public examinations. It is on the basis of that experience that the comments are made in this representation.
1.1.4 Through this submission, Gladman have sought to highlight a number of issues with the Brentwood Local Plan. Gladman submit that the Council will need to carefully consider some of its policy choices and ensure that its evidence base is up-to-date and robust in light of changing circumstances and the changes brought about by the Revised National Planning Policy Framework (2019).
1.2 Context
1.2.1 The Revised Framework (2019) sets out four tests that must be met for Local Plans to be considered sound. In this regard, we submit that in order for it to be sound it is fundamental that the Thurrock Local Plan is:
* Positively prepared - providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
* Justified - an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
* Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
* Consistent with national policy - enabling the delivery of sustainable development in accordance with the policies in the Framework.

2 NATIONAL PLANNING POLICY
2.1 National Planning Policy Framework
2.1.1 On 24th July 2018, the Ministry of Housing, Communities and Local Government (MHCLG) published the Revised National Planning Policy Framework which was subsequently updated in February 2019. These publications form the first revisions of the Framework since 2012 and implement changes that have been informed through the Housing White Paper, The Planning for the Right Homes in the Right Places consultation and the draft Revised Framework consultation.
2.1.2 The Revised Framework (2019) introduces a number of major changes to national policy and provides further clarification to national planning policy as well as new measures on a range of matters. Crucially, the changes to national policy reaffirms the Government's commitment to ensuring up-to-date plans are in place which provide a positive vision for the areas which they are responsible for to address the housing, economic, social and environmental priorities to help shape future local communities for future generations. In particular, paragraph 16 of the Revised Framework (2019) states that Plans should:
a) Be prepared with the objective of contributing to the achievement of sustainable development;
b) Be prepared positively, in a way that is aspirational but deliverable;
c) Be shaped by early, proportionate and effective engagement between plan-makers and communities, local organisations, businesses, infrastructure providers and operators and statutory consultees;
d) Contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals;
e) Be accessible through the use of digital tools to assist public involvement and policy presentation; and
f) Serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant).
2.1.3 To support the Government's continued objective of significantly boosting the supply of homes, it is important that the Local Plan provides a sufficient amount and variety of land that can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay .
2.1.4 In determining the minimum number of homes needed, strategic plans should be based upon a local housing need assessment, conducted using the standard method as set out in the PPG unless exceptional circumstances justify an alternative approach. It is imperative that the emerging Local Plan is formulated on the basis of meeting this requirement as a minimum.
2.1.5 Once the minimum number of homes that is required is identified, the planning authority should have a clear understanding of the land available in their area through the preparation of a strategic housing land availability assessment. In this regard, paragraph 67 sets out specific guidance that local planning authorities should take into account when identifying and meeting their housing need. It states:
"Strategic policy-making authorities should have a clear understanding of the land available in their areas through the preparation of a strategic housing land availability assessment. From this planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability. Strategic plans should identify a supply of:
a) specific, deliverable sites for years one to five of the plan , and
b) specific, developable sites or broad locations for growth, for years 6-10 and, where possible, for years 11-15 of the plan.
2.1.6 Once a local planning authority has identified its housing needs, these needs should be met in full, unless any adverse impacts would significantly and demonstrably outweigh the benefits of doing so . Local planning authorities should seek to achieve each of the economic, social and environmental dimensions of sustainable development, resulting in net gains across all three. Adverse impacts on any of these dimensions should be avoided, where significant adverse impacts are unavoidable, suitable mitigation measures should be proposed or, where this is not possible, compensatory measures should be considered.
2.1.7 To be considered sound at Examination the emerging Local Plan will need to meet all four of the soundness tests set out in paragraph 35 of the Revised Framework (2019).
2.2 Planning Practice Guidance
2.2.1 The Government published updates to its Planning Practice Guidance (PPG) on 13th September 2018. The updated PPG provides further clarity on how specific elements of the Revised Framework should be interpreted when preparing Local Plans. In particular, the updated Housing Needs Assessment chapter of the PPG confirms that the Revised Framework expects local planning authorities to follow the standard method for assessing local housing needs, and that the standard method identifies the minimum housing need figure and not a final housing requirement .
2.2.2 The calculation of objectively assessed needs (OAN) for housing has been a subject of much debate as part of Local Plan Examinations and s.78 appeals since its initial introduction through the Framework in 2012 with interested parties grappling with the issue of OAN with varying outcomes depending on local circumstances. To simplify the assessment the Government, through the Revised Framework has introduced the standardised method which should be undertaken through the 3-stage process outlined at paragraph 005 of the PPG .
2.2.3 Notwithstanding the above, it is important to note that whilst the standard methodology to assessing housing needs has been introduced, it is likely that this will be subject to further change. In this regard, it is currently anticipated that the standard method will be adjusted to ensure that the starting point in the plan-making process is consistent with the Government's proposals in Planning for the Right Homes in the Right Places consultation, to ensure that 300,000 homes are built per annum by the mid-2020s. This follows the release of the 2016 based household projections in September 2018, which forecast a lower level of household growth than previously envisaged.
2.2.4 It is therefore important that future iterations of the Local Plan take account of any changes to the standard method for calculating housing needs during the course of their preparation.
2.2.5 Whilst the PPG advises that the standard method is not mandatory, there is a possibility that other methods can be used in exceptional circumstances based on robust evidence in order to deviate from the standard method. Indeed, the PPG is clear that the standard method only identifies the minimum number of homes required to meet population needs and does not take into account the variety of factors which may influence the housing required in local areas such as changing economic circumstances or other factors which may change demographic behaviour. Where additional growth above historic trends are likely to occur, then local planning authorities should include an appropriate uplift to the housing numbers to meet the need in full. It is important that this uplift is undertaken prior to and separate from the consideration of the demographic baseline assessment of need and how much of this need can be accommodated in a housing requirement figure. Circumstances where the need to apply an uplift may be appropriate include, but are not limited to:
- Where growth strategies are in place, particularly where those growth strategies identify that additional housing above historic trends is needed to support growth or funding is in place to promote and facilitate growth (e.g. housing deals);
- Where strategic infrastructure improvements are planned that would support new homes;
- Where an authority has agreed to take on unmet need, calculated using the standard method from neighbouring authorities, as set out in a statement of common ground;
- Historic delivery levels where previous delivery has exceeded the minimum need identified it should be considered whether the level of delivery is indicative of greater housing need; and
- Where recent assessments such as Strategic Housing Market Assessments suggest higher levels of need than those proposed by a strategic policy making authority, an assessment of lower need should be justified.
2.2.6 In addition, it is important for local planning authorities to consider the implications of the standard method on delivering affordable housing need in full. The PPG is clear that the total affordable housing need should be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, taking into account the probable percentage of affordable housing to be delivered by open market housing development. If it becomes clear that affordable housing need will not be delivered in full, then an increase to the total housing figures included in the plan should be considered where it could help to deliver the required number of the affordable homes.
2.2.7 In the event that an alternative approach is used it should only be considered sound if it exceeds the minimum starting point. The PPG is clear that any alternative approach with results in lower housing need figure than the standard method should be considered unsound as it does not meet the minimum housing need required.  
3 LEGAL REQUIREMENTS
3.1 Duty to Cooperate
3.1.1 The Duty to Cooperate (DtC) is a legal requirement established through section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The DtC requires local planning authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues through the process of ongoing engagement and collaboration.
3.1.2 The Revised Framework (2019) has introduced a number of significant changes for how local planning authorities are expected to cooperate including the preparation of Statement(s) of Common Ground (SOCG) which are required to demonstrate that a plan is based on effective cooperation and has been based on agreements made by neighbouring authorities where cross boundary strategic issues are likely to exist. The Revised Framework (2019) sets out that local planning authorities should produce, maintain, and update one or more Statement(s) of Common Ground (SOCG), throughout the plan making process . The SOCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with e.g. unmet housing needs.
3.1.3 As demonstrated through the outcome of the Coventry, Mid Sussex, Castle Point and St Albans examinations, if a Council fails to satisfactorily discharge its DtC a Planning Inspector must recommend non-adoption of the Plan. This cannot be rectified through modifications.
3.1.4 Gladman welcome the South Essex Authorities' commitment to the preparation of a Joint Strategic Plan (JSP) covering Basildon, Brentwood, Castle Point, Rochford, Southend-on-Sea and Thurrock. All of these authorities have significant strategic issues to contend with not least, the delivery of substantial housing and economic growth and the need to review Green Belt boundaries at a strategic scale.
3.1.5 It is however disappointing, that the JSP will not allocate specific sites which will be left for the individual Local Plans to take forward. The level of housing need in South Essex is significant and delivery has fallen substantially behind need for a long period of time. There is therefore an immediate need to address this situation; and for Local Plans to have to await the adoption of the JSP before sites are taken through the Local Plan process and finally released from the Green Belt, is simply going to result in inevitable further delay.
3.1.6 The JSP could release the strategic sites for development in partnership with the constituent authorities leaving a certain proportion of housing need to be addressed by the Local Plans on non-strategic sites. This would allow the release of Green Belt for development as early in the process as possible, thus meeting urgent need in an expedient manner.
3.1.7 The JSP also needs to follow a statutory plan preparation process with requisite consultation and examination to ensure that it has full weight in the planning process and to guide the preparation of the Local Plans on a formal basis. If the JSP is simply a non-statutory document, then there is the potential for changes over time in the other authorities to cause significant issues.
3.1.8 Beyond this commitment, there is very little evidence available setting out how Brentwood has discharged its Duty to Cooperate and what outcomes have been achieved through this process. This is especially pertinent because of the need to address unmet housing needs across the HMA.
3.2 Sustainability Appraisal
3.2.1 In accordance with Section 19 of the Planning and Compulsory Purchase Act 2004, policies set out in Local Plans must be subject to a Sustainability Appraisal (SA), and also incorporate the requirements of the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA regulations).
3.2.2 The SA/SEA is a systematic process that should be undertaken at each stage of the Plan's preparation, assessing the effects of the emerging Local Plan Review proposals on sustainable development when judged against all reasonable alternatives. The Council should ensure that the future results of the SA clearly justify its policy choices. In meeting the development needs of the area, it should be clear from the results of this assessment why some policy options have progressed, and others have been rejected. This must be undertaken through a comparative and equal assessment of each reasonable alternative, in the same level of detail for both chosen and rejected alternatives. The Council's decision-making and scoring should be robust, justified and transparent.

4 SPATIAL STRATEGY
4.1 Vision and Strategic Objectives
4.1.1 Gladman has concerns with certain elements of the Spatial Strategy that is being pursued through the Brentwood Local Plan (BLP).
4.1.2 The Plan sets out that one of the overarching driving factors behind the BLP is meeting the housing needs of the borough. However, the Council are using the 2016 Household Projections to calculate the housing needs of the borough which the Government have now confirmed is the incorrect data set to rely upon. Use of the 2014 Household Projections is likely to yield a higher housing requirement and therefore, the Council will need to address this issue before the Plan gets to Examination.
4.1.3 They also set out within the Settlement Hierarchy in Table 2.3 that the development of brownfield land will be prioritised. This requirement has no support in National Policy as Para 117 of the Revised Framework (2019) simply states that substantial weight should be given to the value of using suitable brownfield land. This requirement should therefore be changed to reflect Government guidance.
4.1.4 The prioritisation of brownfield land is also repeated in the Spatial Development Principles section under Paragraph 3.23 which similarly needs amending.
4.1.5 It is also disappointing that in the Vision and the Strategic Objectives, no mention is made of providing housing to meet the needs of the local population or of addressing one of the key challenges facing Brentwood, that of tackling housing affordability. It is therefore suggested that given the emphasis being placed by the Government on fixing the broken housing market, a further Strategic Objective is added to the Plan that specifically relates to the delivery of housing.

5 MANAGING GROWTH
5.1 Policy SP02: Managing Growth
5.1.1 The Council sets out in the pre-amble to Policy SP02 that they consider the housing need figure using the Standard Methodology is 350 dwellings per annum using the 2016 Household Projections published by ONS.
5.1.2 However, since the Local Plan was published, the Government has clearly set out that the 2016 Household Projections should not be used for the purposes of establishing the housing need figure under the standard methodology and that the 2014 Household Projections should be used instead.
5.1.3 The Council therefore needs to recalculate the housing need figure using the correct set of data so that it accords with the Framework and is not immediately found unsound on this basis.
5.1.4 It must also be recognised that the standard method only identifies the minimum number of homes required to meet population needs and does not take into account the variety of factors which may influence the housing required in a local area such as changing economic circumstances or other factors which may change demographic behaviour. Where additional growth above historic trends is likely to occur, then local planning authorities should include an appropriate uplift to the housing numbers to meet the need in full. It is important that this uplift is undertaken prior to and separate from, the consideration of how much of this need can be accommodated in the housing requirement.
5.1.5 The Council are seeking to provide an uplift to the base level of housing needs established through the Standard Method but this is intended to provide a buffer in the housing supply to ensure that the housing requirement is met or surpassed. It is not an uplift to take account of the circumstances listed in the PPG (see paragraph 3.1.5 above).
5.1.6 Gladman support the Council's inclusion of a 20% buffer in order to provide flexibility in supply as this will allow the Local Plan to adapt to changes in circumstances such as stalled sites, delay in delivery and sites which do not come forward as envisaged. This is especially important where Local Plans are predicated on the delivery of a small number of large-scale strategic sites.
5.1.7 However, we also consider that the housing requirement included within the Local Plan is not representative of the full housing needs of the area and that factors such as the high housing affordability ratio (11.23 in 2017), continuing economic growth and proximity to London should lead the Council to uplift the housing requirement figure above the minimum identified through the Standard Method. The Council would then still need to include a 20% buffer above this figure, in order to provide the flexibility needed to ensure the housing requirement is met or surpassed.
5.1.8 Gladman also has concerns regarding the Sequential Land Use approach which is set out in Paragraph 4.22 of the Local Plan. This is intended to be used as a Development Management tool to appraise proposals against a sequential land use hierarchy. However, we consider that this goes beyond the guidance set out in National Policy which seeks to maximise the use of brownfield land where possible and where it does not conflict with other policies in the Framework. It is also difficult to see how this approach would work in a Development Management context as applicants would have to demonstrate that there are no other suitable alternative sites which could accommodate the proposed development.
5.1.9 Policy SP02 also sets out a stepped approach to housing delivery within Brentwood which would equate to 310 dwellings per annum 2016-2023 and 584 dwellings per annum from 2023 onwards. Given that Brentwood has struggled to deliver homes over recent years and has in fact, failed to meet the requirements of the recently published Housing Delivery Test, resulting in the need for a 20% buffer to be applied, coupled with the fact that housing affordability in the borough is severe, must lead the Council to the conclusion that it has to address the backlog of housing needs as quickly as possible.
5.1.10 Implementing a stepped approach to the housing requirement will only lead to people having to wait longer for their housing needs to be met which, in the face of the Government's push to address the housing crisis, must be unacceptable.
5.1.11 The Council point to the fact that given the level of Green Belt constraint facing the borough, it is extremely difficult to achieve a five-year housing land supply. However, if the Council allocate a sufficient range and type of site in various locations across the borough, including small scale Green Belt releases, then there is no reason why housing needs cannot be met quicker thus maintaining a 5-year housing land supply.
5.1.12 Gladman do not consider that the Council has sufficient evidence to justify the implementation of a stepped approach to housing delivery and therefore consider the Local Plan to be unsound in this respect.
5.2 Policy SP04: Developer Contributions
5.2.1 Whilst Gladman has no specific comments on the content of Policy SP04, we would wish to voice concern over the myriad of policies contained in the Local Plan which may have implications for development viability. Many of the policies such as Policy SP05, BE01, BE02, BE03, BE09, BE10 etc have requirements within them that will impact on the viability of development schemes. It is unclear from the evidence provided whether the cumulative impact of all of these requirements has been considered through the Viability Study, which is a requirement set out at Paragraph 34 of the Framework to ensure that such policies do not undermine the deliverability of the Plan. This gap in evidence needs to be addressed by the Council to ensure that these policies are justified.

6 RESILIENT BUILT ENVIRONMENT
6.1 Policy BE02: Sustainable Construction and Resource Efficiency
6.1.1 Gladman are concerned with part (f) of Policy BE02 as it is too onerous and goes beyond National Policy. Part (f) requires all proposals to include commercial and domestic scale renewable energy and decentralised energy as part of new development. This is an extremely onerous requirement, particularly for small schemes where it may not be technically feasible. It could also have a huge impact on development viability.
6.1.2 Paragraph 153 of the Framework allows for planning policies to require development to include decentralised energy supply. However, it also provides a caveat that this is only where it is viable and feasible. Part (f) of Policy BE02 should therefore be amended to reflect this guidance.

7 HOUSING PROVISION
7.1 Policy HP01: Housing Mix
7.1.1 Policy HP01 contains a number of development requirements which would be applied to all new development including housing mix, accessible and adaptable dwellings and self and custom build homes.
7.1.2 If the Council wishes to adopt the discretionary accessible and adaptable homes standards as a policy requirement, then this should only be done in accordance with the Revised Framework footnote 46 i.e. where this would address an identified need for such properties and where the standards can be justified. The Written Ministerial Statement (WMS) dated 25th March 2015 stated that "the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG".
7.1.3 All new homes are built to Building Regulations Part M Category 1 Standards which include such adaptions as level approach routes, accessible front doors and wider internal doors and corridors. If the Government had intended that evidence of an aging population alone justified the adoption of the higher Part M Category 2 or 3 optional standard, then these would have been incorporated as mandatory into the Building Regulations.
7.1.4 We have been unable to locate where the evidence of a need for these standards is contained within the evidence base. Without this evidence, these requirements should be removed from the Local Plan.
7.1.5 Whilst the concept of Self Build and Custom Build Housing is supported, the inclusion of plots on large scale sites does not add to the supply of houses overall (it merely changes the housing mix from one product to another). It is also difficult to assess how it will be implemented given issues around working hours, site access, health and safety etc. that are associated with large scale development sites. The percentage of provision on sites should also be determined on detailed evidence of need and the provision of these plots should also be subject to viability testing.
7.2 Policy HP06: Standards for New Housing
7.2.1 Policy HP06 requires all residential development to have to comply with the Nationally Described Space Standards (NDDS).
7.2.2 If the Council wishes to adopt the NDSS as a policy requirement, then this should only be done in accordance with the Revised Framework footnote 46 i.e. where this would address an identified need for such properties and where the standards can be justified. The WMS dated 25th March 2015 stated that "the optional new national technical standards should only be required through any new Local Plan policies if they address a clearly evidenced need, and where their impact on viability has been considered, in accordance with the NPPG".
7.2.3 We have been unable to locate where the evidence of a need for these standards is contained within the evidence base. Without this evidence, these requirements should be removed from the Local Plan.


8 CONCLUSION
8.1 Overall Conclusion
8.1.1 Critical to the success of the South Essex area will be the timely production of the JSP which will define the major growth areas to meet the housing and employment needs across the area and will inform the preparation of the individual Local Plans.
8.1.2 It is essential that through this process, the full needs for housing and employment are met in the areas that people want to live. It is also imperative that the major policy constraint of Green Belt is reviewed in a strategic manner which allows full need to be met and ensures that the new boundaries endure beyond the JSP plan period.
8.1.3 The impact of London will have a heavy influence on the future developments needs of the area and this must also be taken fully into account through the preparation of the JSP.
8.1.4 It is also considered that in order to give the JSP the weight it needs to ensure that the constituent Local Plans deliver its outcomes, the JSP should be a statutory plan which follows the requisite plan preparation process of consultation and subsequent examination.
8.1.5 Gladman have some fundamental concerns with the BLP, particularly with the identification of the level of housing need in the Plan and the implementation of a stepped approach to housing delivery, which would render the BLP unsound if they are not addressed.
8.1.6 Gladman therefore request the right to participate in any forthcoming Local Plan Examination to discuss these concerns orally.

Attachments:

Support

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

Representation ID: 23790

Received: 19/03/2019

Respondent: Hermes Fund Managers Limited

Agent: McGough Planning Consultants

Representation Summary:

West Horndon as a large village within settlement Category 2.

Full text:

We write further to the above consultation on the above on behalf of our clients, Hermes Investment Management and Hermes Property Unit Trust ("Hermes"), the asset manager and owner of the West Horndon Industrial Estate, Station Road, West Horndon (your site refs 021 & 022). You may recall, Hermes acquired Threadneedle's interest (approximately covered by your site ref 020) last year, so they now own the bulk of the larger West Horndon Industrial Estate which includes your site refs 020 and 021. Their discussions to acquire the land shown by your site ref 152 are well advanced and will be subject to planning permission for the residential-led, mixed use redevelopment of the land which is allocated by R02 in the Pre-submission draft of the Local Plan. As you know form the last consultation in March 2018, our preparation of a planning application for residential led mixed-use development on the western portion of the industrial estate (including land identified as site refs 152, 021 and part of 020) was well advanced, and we had expected to submit the planning application sometime last year. However, following the acquisition of Threadneedle's interest and taking account of the views of Brentwood's officers and West Horndon Parish Council, Hermes took the decision to expand the planning application to include the whole of the land identified as R02. This has resulted in additional work and will require further pre-application discussions and consultations (with Brentwood BC, Essex CC and West Horndon Parish Council). Our revised aim is to make the hybrid planning application for the whole site later this year (around September/ October). Hermes has made representations to the various drafts of the local plan over the time of its ownership. It is not our intention to repeat any of those in relation to the Pre-submission draft of the Local Plan. Instead, our representations will focus solely on matters that affect the draft allocation R02. Please note, in expressing support or comment on the matters set out below, Hermes is affirming they consider the Pre-submission draft of the Local Plan to be sound. Page 22 Settlement Category - SUPPORT: West Horndon as a large village within settlement Category 2. Page 24 para 2.14 - SUPPORT for improvements to access to West Horndon station arising from and facilitated by Dunton Hill Garden Village. Page 39 para 3.21 (b) - SUPPORT. Page 92 Policy BE11 (B ii) - SUPPORT Strategic Transport Infrastructure designed to improve access to West Horndon station; arising from and facilitated by Dunton Hill Garden Village. Page 95 para 5.96 (c) - SUPPORT Page 96 para5.105 - SUPPORT Page 103 para 5.121 - SUPPORT Page 114 para 5.155 - SUPPORT Page 177 Policy PC03 Employment Land Allocations include 2.0 hectares of R02 - SUPPORT & COMMENT: insofar as this includes the employment to be retained on the site, as well as the new employment opportunities created by the new village centre (which will include retail and non-retail uses). Page 181 para 7.30 - SUPPORT Page 185 Policy PC07 Retail and Commercial Leisure Growth - SUPPORT & COMMENT: it is important to note the Brentwood Retail and Commercial Leisure Study (Dec2014) by NLP. The emerging West Horndon master plan includes a new village centre which incorporates shops and non-retail uses, such as potential health facilities. NLP suggested an additional 2000sqm of retail may be appropriate as part of the redevelopment of the industrial estate. Our latest masterplan shows around 2700sqm, but this includes non-retail uses. Page 186 para 7.53 - SUPPORT Page 187 Policy PC08 - SUPPORT& COMMENT: the new village centre for West Horndon is likely to include an additional 2700sqm of retail and non-retail accommodation. Page 231 Policy NE10 Green Belt - COMMENT: West Horndon is not within green belt, so it is unclear what purpose reference to it in this policy serves. Page 244 para 9.7 - SUPPORT the reference to R02 on the list of Strategic Housing Allocations. Page 254 Policy R01 (II) d- SUPPORT Page 269 Policy R02: LAND AT WEST HORNDON INDUSTRIAL ESTATE & supporting paragraphs - SUPPORT & COMMENT: Hermes' draft masterplan for the whole site includes a variety of dwelling types, including flats (making up the proposed village centre, nearest to the Station Road entrance and West Horndon station) and 2, 3 & 4 bed houses. At present, the R02 site measures 17.6 hectares gross, which nets down to 15hectares (after allowing for 15% POS and landscaping) in the latest draft of the masterplan. The current layout is nearer 750 dwellings, which is well over the figure of "around 580 new homes" set out in the policy. Page 309 Appendix 1 Housing Trajectory - SUPPORT & COMMENT: the timing of the supply of houses accords with the proposed phasing and Hermes' management of the existing leases on the estate. Please note comments in relation to the numbers of new dwellings the site can accommodate. Page 318 Residential Lead Sites - SUPPORT & COMMENT: it is unclear how Brentwood BC have worked out the gross (17.06ha) and net (10.23ha) figures as set out in the table accompanying the site allocation plan. It is also the case that the draft Local Plan's gross to net calculations given for all the larger residential allocation sites varies, sometimes considerably. At present, the R02 site measures 17.6 hectares in total, which nets down to 15 hectares (after allowing for 15% POS and landscaping) in the latest draft of the masterplan. The current layout is showing the number of dwellings to be nearer to 750, well over the figure of "around 580 new homes" set out in the policy. It is also noted that the density of development is lower in the Hermes' latest masterplan (50dph) than that suggested by draft Local Plan (56.7dph), although it is accepted that this depends entirely on the chosen base. Please let me know if anything is unclear. We would ask that you acknowledge receipt of these representations.

Attachments:

Support

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

Representation ID: 23791

Received: 19/03/2019

Respondent: Hermes Fund Managers Limited

Agent: McGough Planning Consultants

Representation Summary:

West Horndon as a large village within settlement Category 2.

Full text:

We write further to the above consultation on the above on behalf of our clients, Hermes Investment Management and Hermes Property Unit Trust ("Hermes"), the asset manager and owner of the West Horndon Industrial Estate, Station Road, West Horndon (your site refs 021 & 022). You may recall, Hermes acquired Threadneedle's interest (approximately covered by your site ref 020) last year, so they now own the bulk of the larger West Horndon Industrial Estate which includes your site refs 020 and 021. Their discussions to acquire the land shown by your site ref 152 are well advanced and will be subject to planning permission for the residential-led, mixed use redevelopment of the land which is allocated by R02 in the Pre-submission draft of the Local Plan. As you know form the last consultation in March 2018, our preparation of a planning application for residential led mixed-use development on the western portion of the industrial estate (including land identified as site refs 152, 021 and part of 020) was well advanced, and we had expected to submit the planning application sometime last year. However, following the acquisition of Threadneedle's interest and taking account of the views of Brentwood's officers and West Horndon Parish Council, Hermes took the decision to expand the planning application to include the whole of the land identified as R02. This has resulted in additional work and will require further pre-application discussions and consultations (with Brentwood BC, Essex CC and West Horndon Parish Council). Our revised aim is to make the hybrid planning application for the whole site later this year (around September/ October). Hermes has made representations to the various drafts of the local plan over the time of its ownership. It is not our intention to repeat any of those in relation to the Pre-submission draft of the Local Plan. Instead, our representations will focus solely on matters that affect the draft allocation R02. Please note, in expressing support or comment on the matters set out below, Hermes is affirming they consider the Pre-submission draft of the Local Plan to be sound. Page 22 Settlement Category - SUPPORT: West Horndon as a large village within settlement Category 2. Page 24 para 2.14 - SUPPORT for improvements to access to West Horndon station arising from and facilitated by Dunton Hill Garden Village. Page 39 para 3.21 (b) - SUPPORT. Page 92 Policy BE11 (B ii) - SUPPORT Strategic Transport Infrastructure designed to improve access to West Horndon station; arising from and facilitated by Dunton Hill Garden Village. Page 95 para 5.96 (c) - SUPPORT Page 96 para5.105 - SUPPORT Page 103 para 5.121 - SUPPORT Page 114 para 5.155 - SUPPORT Page 177 Policy PC03 Employment Land Allocations include 2.0 hectares of R02 - SUPPORT & COMMENT: insofar as this includes the employment to be retained on the site, as well as the new employment opportunities created by the new village centre (which will include retail and non-retail uses). Page 181 para 7.30 - SUPPORT Page 185 Policy PC07 Retail and Commercial Leisure Growth - SUPPORT & COMMENT: it is important to note the Brentwood Retail and Commercial Leisure Study (Dec2014) by NLP. The emerging West Horndon master plan includes a new village centre which incorporates shops and non-retail uses, such as potential health facilities. NLP suggested an additional 2000sqm of retail may be appropriate as part of the redevelopment of the industrial estate. Our latest masterplan shows around 2700sqm, but this includes non-retail uses. Page 186 para 7.53 - SUPPORT Page 187 Policy PC08 - SUPPORT& COMMENT: the new village centre for West Horndon is likely to include an additional 2700sqm of retail and non-retail accommodation. Page 231 Policy NE10 Green Belt - COMMENT: West Horndon is not within green belt, so it is unclear what purpose reference to it in this policy serves. Page 244 para 9.7 - SUPPORT the reference to R02 on the list of Strategic Housing Allocations. Page 254 Policy R01 (II) d- SUPPORT Page 269 Policy R02: LAND AT WEST HORNDON INDUSTRIAL ESTATE & supporting paragraphs - SUPPORT & COMMENT: Hermes' draft masterplan for the whole site includes a variety of dwelling types, including flats (making up the proposed village centre, nearest to the Station Road entrance and West Horndon station) and 2, 3 & 4 bed houses. At present, the R02 site measures 17.6 hectares gross, which nets down to 15hectares (after allowing for 15% POS and landscaping) in the latest draft of the masterplan. The current layout is nearer 750 dwellings, which is well over the figure of "around 580 new homes" set out in the policy. Page 309 Appendix 1 Housing Trajectory - SUPPORT & COMMENT: the timing of the supply of houses accords with the proposed phasing and Hermes' management of the existing leases on the estate. Please note comments in relation to the numbers of new dwellings the site can accommodate. Page 318 Residential Lead Sites - SUPPORT & COMMENT: it is unclear how Brentwood BC have worked out the gross (17.06ha) and net (10.23ha) figures as set out in the table accompanying the site allocation plan. It is also the case that the draft Local Plan's gross to net calculations given for all the larger residential allocation sites varies, sometimes considerably. At present, the R02 site measures 17.6 hectares in total, which nets down to 15 hectares (after allowing for 15% POS and landscaping) in the latest draft of the masterplan. The current layout is showing the number of dwellings to be nearer to 750, well over the figure of "around 580 new homes" set out in the policy. It is also noted that the density of development is lower in the Hermes' latest masterplan (50dph) than that suggested by draft Local Plan (56.7dph), although it is accepted that this depends entirely on the chosen base. Please let me know if anything is unclear. We would ask that you acknowledge receipt of these representations.

Attachments:

Object

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

Representation ID: 24435

Received: 03/06/2019

Respondent: Mrs Vicky Mumby

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

IDP Fig 2.3 settlement hierarchy: there are errors in the plan eg the population of Blackmore is listed as 829 but this does not cover the residents in Nine Ashes Road past Red Rose Lanes and Chelmsford Road which includes a mobile home park and illegal travellers site.

Change suggested by respondent:

Remove sites R25 and R26 from plan, refer to the Blackmore Village Heritage Association (BVHA) 'Neighbourhood Plan' for housing need.

Full text:

Including the following sections:
LDP Fig 2.3 Settlement hierarchy
LDP Section 04 (management growth)
Policies:
SP01 - D
Paras 4.6 4.9 4.20
Policy SP02
Policy SP04 - A
LDP Section 06 (housing provision)
Policy HP 08

Section 08
Natural Environment
Policy NE 06 paras 8.51 -8.64
Para 8.85 (IV)
Para 8.90
Para 8.101
Policy NE13
Section 09 site allocation
Policy R25 para 9.87 -9.200
Policy R26 paras 9.201 - 9.204

I consider the plan to be unsound and fails to comply with the Duty to Cooperate for the following reasons:
1. IDP Fig 2.3 settlement hierarchy: there are errors in the plan eg the population of Blackmore is listed as 829 but this does not cover the residents in Nine Ashes Road past Red Rose Lanes and Chelmsford Road which includes a mobile home park and illegal travellers site.

2. Duty to cooperate: there has not been sufficient consultation with other neighbouring authorities. There us a development of 30 new, large houses by Epping Forest DC 100m outside the parish boundary in Fingrith Hall Lane. These properties are 1/3 miles from Blackmore Village and 5 miles from any other town/village. This will exacerbate the impact of the proposed 70 new properties being considered for Blackmore in the infrastructure and amenities.

3 Red Rose lane is a single track and not suitable for the extra volume of traffic generated by the proposed housing. It is used by walkers, joggers, cyclists; dog walkers and horseriders and has no pavement. The additional traffic will bring increased danger to these users along with the lack of street lights.

4. Flood Risk: Blackmore sites in a dip and is prone to flooding which has occurred a number of times over the years. The planned 70 homes will reduce the available land to soak up water, therefore flooding will increase.

5. Policy NE06 states that in 8.52: Developing inappropriately in high risk areas can put property and lives at risk; this policy seeks to ensure this does not happen.

6. infrastructure Requirements: There are no infrastructure requirements listed in policy R25 or R26, however all amenities and services are already stretched inc the local primary school, electricity, sewerage system, doctors surgery etc.

7. There is no clear housing strategy for the villages and general area in the north of the borough. There are many other options that have been suggested through this process but have not been considered.

8. A 'housing needs' survey should have been carried out which would have demonstrated why Blackmore has been specifically included on the LDP and why other more suitable areas have not been included.

9. The borough Council have not shown that the required additional houses for the borough could not be delivered by increasing the housing density on the other allocated sites in the plan.

10. There are brownfield sites available nearby but there is no evidence these have been considered in preference to using Green Belt land.

11. Other more suitable locations eg areas around Doddinghurst which have better transport links would have been a far better proposal that the development in Blackmore which is not a sustainable development proposal for the reasons given.

12. The proposed sites are important to wildlife and natural habitats.
Policy HP08 seeks to regularise an illegal travellers site on the Chelmsford Road. The borough Council has failed to undertake its duty to attempt to remove the travellers since they moved in some years ago. The Council has watched the site grow without taking any action!

My family moved to Blackmore 2 years ago from Epping for a quiet village life. The village does not have the capacity for 70 new homes.

Attachments:

Object

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

Representation ID: 24471

Received: 05/06/2019

Respondent: Mr Frederick Piper

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

This is a small village which should never have been classed as category 3 it is category 4. Green field sites being proposed when there is alternative brownfield sites available. Amenities would not be able to cope, School is full, doctor appointments already up to 1 month & this will worsen with residents of old Norton Heath site descend on the village

Change suggested by respondent:

Refer to BHVA neighbourhood plan - remove R25 and R26 from plan

Full text:

Section 09, 04 and 08.Unsound: Green field sites being proposed when there is alternative brownfield sites available in the borough ie Stondon Massey & south weald
Amenities would both be able to cope, doctor appointments already up to 1 month & this will get worse when the residents of old Norton Heath site descend on the village
School is full
This is a small village which should never have been classed as category 3 it is category 4.
Plus there are various other planning applications going through for the village on Spriegs Lane & Chelmsford Road 20 properties are proposed on 4 applications.

Attachments:

Object

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

Representation ID: 25125

Received: 19/03/2019

Respondent: Valerie Godbee

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Why is Blackmore, population 829, in Settlement Category 3 along with Doddinghurst, population 2,550, rather than Settlement Category 4?
The definition of Category 4 is 'Remote and small rural villages and hamlets, with poor public transport, limited shops, jobs and community facilities; some of these settlements rely on nearby settlements for services' which is more pertinent to the village of Blackmore.

Full text:

Brentwood Borough Council must provide 7800 houses a third of which have been allocated to Dunton Hills and the rest scattered over the borough. Blackmore has been allocated 70 which represents 60% of land released in villages in what is described in the LDP as a 'borough of villages'. This is totally disproportionate. Brownfield sites have not been properly considered before the green belt and green field sites. The LDP has not shown that the 70 houses could not be built by increasing density on the more urban sites. Denton Village could easily absorb this amount for example. In addition there are other sites within the Blackmore boundaries that have been submitted to Brentwood Planning for development as well as building by Epping Council on our borders. All of which will be using our services and infrastructure adding to further congestion in an already busy village.
There is a large, illegal, travellers site in Chelmsford road that additionally impacts all the roads, parking, infrastructure, school, doctor's surgery, services etc.
No Housing Needs Survey has been made, except by Blackmore Village Heritage Association, to ascertain local needs and to show why Blackmore has been included.
The infrastructure cannot support this additional build which could mean upwards of 200 people, 140 cars, 250 car journeys. The doctors' surgery is overwhelmed. It is not possible to get an appointment for weeks. At time of writing this was until at least the end of April. The local primary school, that is listed as an asset in the plan, is oversubscribed with a waiting list. Traffic and parking is already a problem and will only get worse as planning departments in Brentwood and Epping continue to approve building plans Why is Blackmore, population 829, in Settlement Category 3 along with Doddinghurst, population 2,550, rather than Settlement Category 4?
The definition of Category 4 is 'Remote and small rural villages and hamlets, with poor public transport, limited shops, jobs and community facilities; some of these settlements rely on nearby settlements for services' which is more pertinent to the village of Blackmore.
A clear plan needs to be implemented for Blackmore and the other villages in the north of the Borough
* There doesn't appear to have been much, if any, consultation with Epping & Chelmsford Borough Councils. 30 properties have been built in Fingrith Hall Lane which will impact the village and the inhabitants will further impact the local services, schools, doctors etc
* Blackmore is a remote village with scarce services, public transport, doctors' appointments are already at a premium and there is a long waiting list for the local primary school.
* More sustainable locations with better infrastructure, more schools, & surgeries, etc etc such as the urban areas of Brentwood are available.
*Brownfield sites have not been properly considered before the green belt and green field sites and promoting the land off Red Rose Lane.
* The LDP has not shown that the 70 houses could not be built by increasing density on the more urban sites. Denton Village could easily absorb this amount for example.
* No Housing Needs Survey has been made, except by Blackmore Village Heritage Association, to ascertain local needs and to show why Blackmore has been included in the LDP.
* Red Rose Lane is a narrow road with drainage ditches either side. Two cars cannot pass without one pulling over. This is the only access from the proposed site so is totally unsuitable for the amount of additional traffic which would be upwards of 150 cars. Phil Drane has quoted that 'Red Rose Lane is an inappropriate access road'
* Essex CC and Councillor Lesley Wagland agrees with the road and infrastructure issues.
* Building 70 plus houses there would not create any jobs for the area.
* Both sites are frequently subject to flooding. Building on these fields would also increase the flood risk elsewhere in the village in particular by the village pond which is currently a flood hazard. A cursory look at the Essex CC web site https://flood.essex.gov.uk/know-your-flood
risk/check-if-you-re-at-risk-of-flooding/ would clearly show the high risk of flooding
Blackmore is under.
* Stondon Massey would welcome additional housing to ensure viability of their village and there are sufficient brownfield sites to accommodate such growth.

Attachments:

Object

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

Representation ID: 25744

Received: 19/03/2019

Respondent: Mr Douglas Piper

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Blackmore should be category 4.

Change suggested by respondent:

Blackmore should be category 4.

Full text:

See attached.

Attachments:

Object

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

Representation ID: 25841

Received: 12/03/2019

Respondent: Mr John Hughes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

There are errors and omissions in the plan. The population of Blackmore is listed as 829; however, the area that this covers does not cover the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers.

Change suggested by respondent:

Due to the many issues listed above it is clear that the sensible modification would be to remove sites R25 and R26 from the Plan. Blackmore Village Heritage Association (BVHA) has produced a 'neighbourhood plan' which should be referred to by the Planners. This clearly sets out our local housing needs for our already sustainable community.

Full text:

I consider the plan to be unsound and fails to comply with the Duty to Cooperate for the following reasons: 1. LDP Fig 2.3 Settlement Hierarchy. There are errors and omissions in the plan. For example, the population of Blackmore is listed as 829. However, the area that this covers (see diagram attached) does not cover, amongst others, the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers. 2. Duty to Cooperate. There has not been sufficient consultation with other neighbouring authorities. 100 metres outside the parish boundary in Fingrith Hall Lane is the entrance to a development of 30 new (large) houses by Epping Forest District Council. These properties are 1.3 miles from Blackmore village centre and its amenities and more than 5 miles from any other town/ village with similar amenities. This will exacerbate the impact of the proposed 70 (40 + 30) new properties being proposed for Blackmore on the infrastructure and amenities. 3. Red Rose Lane is a single track road and is not suitable for the extra volume of traffic generated by the proposed housing. Also, Red Rose Lane, along with many other roads in and around the Blackmore area, is used regularly by walkers, joggers, cyclists, dog-walkers and horse riders. Red Rose Lane has no pavements and so the additional traffic will bring increased danger to these users. There are also very few street lights in Blackmore and none in Red Rose Lane which adds more risk. 4. Flood Risk. The village centre of Blackmore sits in a dip and is prone to flooding. Prior to the major development of the village in the 1970s there were no reports of any significant flooding. Since then there have been a number of occurrences of flooding. In 1986 a major flood occurred where many houses and St Laurence church were flooded and badly damaged. Flooding has occurred numerous times since with the most recent being 3 years ago when several houses on the Green were flooded and many of the surrounding roads (including Red Rose Lane) were impassable. At St Laurence Church graveyard in Church Street when graves are dug they fill with water immediately and need to be pumped out prior to the burial due to the high water table in the area. The addition of 70 properties will further reduce the available open land to soak up water and therefore flooding occurrences will increase. (See photos showing the Blackmore Road area near Meadow Rise from summer 2016). This flood caused extensive damage to the pavement which has not yet been repaired. 5. Policy NE06 FLOOD RISK states in 8.52: Flood risk include risk from all sources of flooding, including from rivers, from rainfall, from rising groundwater, which can overwhelm sewers and drainage systems, and from reservoirs, canals, lakes and other artificial sources. Incidences of high rainfall are forecast to increase in intensity as a result of climate change. Developing inappropriately in areas at risk from flooding, can put property and lives at risk; therefore, this policy seeks to ensure this does not happen. Blackmore is not just a high flood RISK area, flooding in Blackmore is actually an ISSUE. Therefore any development in Blackmore is clearly against this policy. 6. Infrastructure Requirements. There are no infrastructure requirements listed in policy R25 or R26. However, all amenities and services are already stretched. * The electricity, other utilities and in particular the sewerage system are unlikely to be able to cope an additional 70 properties without counting the 30 extra properties in Fingrith Hall road. The sewerage system is at maximum capacity already. * The local primary school is already full- new arrivals in the village are not able to get their children into the school and have to travel to schools in other areas. * Bus services are limited, infrequent and do not run into the evenings. * There is insufficient parking in the village centre causing people to regularly park on double yellow lines. * The doctors surgery is at capacity and waiting time for appointments are already unacceptable. 7. There is no clear housing strategy for the villages and general area in the north of the Borough. There are many options that have been suggested through this process and should have been considered but have not been. 8. A 'Housing Needs' survey should have been carried out which would have demonstrated why Blackmore has been specifically included in the LDP, and why other more suitable areas have not been included. 9. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan. 10. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land. 11. Other more suitable locations (e.g. areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal for the reasons given. 12. The proposed sites are important wildlife and natural habitats for many creatures to live undisturbed. 13. Policy HP08 seeks to regularise an illegal traveller site on the Chelmsford Road. The Borough Council has failed to undertake its duty to attempt to remove the travellers from the site since they first moved in some years ago. The Council have sat back and watched the site grow without taking any action and must re-visit this. In regularising the site the council is providing open invitation for other travellers to do the same as the council will be seen to be weak, capitulating and an easy target area. 14. Policy SP02 states that new development will be directed towards highly accessible locations along transit/growth corridors. Blackmore is not highly accessible and not along a transit I growth corridor.

Attachments:

Object

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

Representation ID: 25856

Received: 12/03/2019

Respondent: Mr Thomas Hughes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

There are errors and omissions in the plan. The population of Blackmore is listed as 829; however, the area that this covers does not cover the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers.

Change suggested by respondent:

Due to the many issues listed above it is clear that the sensible modification would be to remove sites R25 and R26 from the Plan. Blackmore Village Heritage Association (BVHA) has produced a 'neighbourhood plan' which should be referred to by the Planners. This clearly sets out our local housing needs for our already sustainable community.

Full text:

I consider the plan to be unsound and fails to comply with the Duty to Cooperate for the following reasons: 1. LDP Fig 2.3 Settlement Hierarchy. There are errors and omissions in the plan. For example, the population of Blackmore is listed as 829. However, the area that this covers (see diagram attached) does not cover, amongst others, the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers. 2. Duty to Cooperate. There has not been sufficient consultation with other neighbouring authorities. 100 metres outside the parish boundary in Fingrith Hall Lane is the entrance to a development of 30 new (large) houses by Epping Forest District Council. These properties are 1.3 miles from Blackmore village centre and its amenities and more than 5 miles from any other town/ village with similar amenities. This will exacerbate the impact of the proposed 70 (40 + 30) new properties being proposed for Blackmore on the infrastructure and amenities. 3. Red Rose Lane is a single track road and is not suitable for the extra volume of traffic generated by the proposed housing. Also, Red Rose Lane, along with many other roads in and around the Blackmore area, is used regularly by walkers, joggers, cyclists, dog-walkers and horse riders. Red Rose Lane has no pavements and so the additional traffic will bring increased danger to these users. There are also very few street lights in Blackmore and none in Red Rose Lane which adds more risk. 4. Flood Risk. The village centre of Blackmore sits in a dip and is prone to flooding. Prior to the major development of the village in the 1970s there were no reports of any significant flooding. Since then there have been a number of occurrences of flooding. In 1986 a major flood occurred where many houses and St Laurence church were flooded and badly damaged. Flooding has occurred numerous times since with the most recent being 3 years ago when several houses on the Green were flooded and many of the surrounding roads (including Red Rose Lane) were impassable. At St Laurence Church graveyard in Church Street when graves are dug they fill with water immediately and need to be pumped out prior to the burial due to the high water table in the area. The addition of 70 properties will further reduce the available open land to soak up water and therefore flooding occurrences will increase. (See photos showing the Blackmore Road area near Meadow Rise from summer 2016). This flood caused extensive damage to the pavement which has not yet been repaired. 5. Policy NE06 FLOOD RISK states in 8.52: Flood risk include risk from all sources of flooding, including from rivers, from rainfall, from rising groundwater, which can overwhelm sewers and drainage systems, and from reservoirs, canals, lakes and other artificial sources. Incidences of high rainfall are forecast to increase in intensity as a result of climate change. Developing inappropriately in areas at risk from flooding, can put property and lives at risk; therefore, this policy seeks to ensure this does not happen. Blackmore is not just a high flood RISK area, flooding in Blackmore is actually an ISSUE. Therefore any development in Blackmore is clearly against this policy. 6. Infrastructure Requirements. There are no infrastructure requirements listed in policy R25 or R26. However, all amenities and services are already stretched. * The electricity, other utilities and in particular the sewerage system are unlikely to be able to cope an additional 70 properties without counting the 30 extra properties in Fingrith Hall road. The sewerage system is at maximum capacity already. * The local primary school is already full- new arrivals in the village are not able to get their children into the school and have to travel to schools in other areas. * Bus services are limited, infrequent and do not run into the evenings. * There is insufficient parking in the village centre causing people to regularly park on double yellow lines. * The doctors surgery is at capacity and waiting time for appointments are already unacceptable. 7. There is no clear housing strategy for the villages and general area in the north of the Borough. There are many options that have been suggested through this process and should have been considered but have not been. 8. A 'Housing Needs' survey should have been carried out which would have demonstrated why Blackmore has been specifically included in the LDP, and why other more suitable areas have not been included. 9. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan. 10. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land. 11. Other more suitable locations (e.g. areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal for the reasons given. 12. The proposed sites are important wildlife and natural habitats for many creatures to live undisturbed. 13. Policy HP08 seeks to regularise an illegal traveller site on the Chelmsford Road. The Borough Council has failed to undertake its duty to attempt to remove the travellers from the site since they first moved in some years ago. The Council have sat back and watched the site grow without taking any action and must re-visit this. In regularising the site the council is providing open invitation for other travellers to do the same as the council will be seen to be weak, capitulating and an easy target area. 14. Policy SP02 states that new development will be directed towards highly accessible locations along transit/growth corridors. Blackmore is not highly accessible and not along a transit I growth corridor.

Attachments:

Object

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

Representation ID: 25863

Received: 12/03/2019

Respondent: Mrs Gail Hughes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

There are errors and omissions in the plan. The population of Blackmore is listed as 829; however, the area that this covers does not cover the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers.

Change suggested by respondent:

Due to the many issues listed above it is clear that the sensible modification would be to remove sites R25 and R26 from the Plan. Blackmore Village Heritage Association (BVHA) has produced a 'neighbourhood plan' which should be referred to by the Planners. This clearly sets out our local housing needs for our already sustainable community.

Full text:

I consider the plan to be unsound and fails to comply with the Duty to Cooperate for the following reasons: 1. LDP Fig 2.3 Settlement Hierarchy. There are errors and omissions in the plan. For example, the population of Blackmore is listed as 829. However, the area that this covers (see diagram attached) does not cover, amongst others, the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers. 2. Duty to Cooperate. There has not been sufficient consultation with other neighbouring authorities. 100 metres outside the parish boundary in Fingrith Hall Lane is the entrance to a development of 30 new (large) houses by Epping Forest District Council. These properties are 1.3 miles from Blackmore village centre and its amenities and more than 5 miles from any other town/ village with similar amenities. This will exacerbate the impact of the proposed 70 (40 + 30) new properties being proposed for Blackmore on the infrastructure and amenities. 3. Red Rose Lane is a single track road and is not suitable for the extra volume of traffic generated by the proposed housing. Also, Red Rose Lane, along with many other roads in and around the Blackmore area, is used regularly by walkers, joggers, cyclists, dog-walkers and horse riders. Red Rose Lane has no pavements and so the additional traffic will bring increased danger to these users. There are also very few street lights in Blackmore and none in Red Rose Lane which adds more risk. 4. Flood Risk. The village centre of Blackmore sits in a dip and is prone to flooding. Prior to the major development of the village in the 1970s there were no reports of any significant flooding. Since then there have been a number of occurrences of flooding. In 1986 a major flood occurred where many houses and St Laurence church were flooded and badly damaged. Flooding has occurred numerous times since with the most recent being 3 years ago when several houses on the Green were flooded and many of the surrounding roads (including Red Rose Lane) were impassable. At St Laurence Church graveyard in Church Street when graves are dug they fill with water immediately and need to be pumped out prior to the burial due to the high water table in the area. The addition of 70 properties will further reduce the available open land to soak up water and therefore flooding occurrences will increase. (See photos showing the Blackmore Road area near Meadow Rise from summer 2016). This flood caused extensive damage to the pavement which has not yet been repaired. 5. Policy NE06 FLOOD RISK states in 8.52: Flood risk include risk from all sources of flooding, including from rivers, from rainfall, from rising groundwater, which can overwhelm sewers and drainage systems, and from reservoirs, canals, lakes and other artificial sources. Incidences of high rainfall are forecast to increase in intensity as a result of climate change. Developing inappropriately in areas at risk from flooding, can put property and lives at risk; therefore, this policy seeks to ensure this does not happen. Blackmore is not just a high flood RISK area, flooding in Blackmore is actually an ISSUE. Therefore any development in Blackmore is clearly against this policy. 6. Infrastructure Requirements. There are no infrastructure requirements listed in policy R25 or R26. However, all amenities and services are already stretched. * The electricity, other utilities and in particular the sewerage system are unlikely to be able to cope an additional 70 properties without counting the 30 extra properties in Fingrith Hall road. The sewerage system is at maximum capacity already. * The local primary school is already full- new arrivals in the village are not able to get their children into the school and have to travel to schools in other areas. * Bus services are limited, infrequent and do not run into the evenings. * There is insufficient parking in the village centre causing people to regularly park on double yellow lines. * The doctors surgery is at capacity and waiting time for appointments are already unacceptable. 7. There is no clear housing strategy for the villages and general area in the north of the Borough. There are many options that have been suggested through this process and should have been considered but have not been. 8. A 'Housing Needs' survey should have been carried out which would have demonstrated why Blackmore has been specifically included in the LDP, and why other more suitable areas have not been included. 9. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan. 10. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land. 11. Other more suitable locations (e.g. areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal for the reasons given. 12. The proposed sites are important wildlife and natural habitats for many creatures to live undisturbed. 13. Policy HP08 seeks to regularise an illegal traveller site on the Chelmsford Road. The Borough Council has failed to undertake its duty to attempt to remove the travellers from the site since they first moved in some years ago. The Council have sat back and watched the site grow without taking any action and must re-visit this. In regularising the site the council is providing open invitation for other travellers to do the same as the council will be seen to be weak, capitulating and an easy target area. 14. Policy SP02 states that new development will be directed towards highly accessible locations along transit/growth corridors. Blackmore is not highly accessible and not along a transit I growth corridor.

Attachments:

Object

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

Representation ID: 25870

Received: 12/03/2019

Respondent: Mr Adam Hughes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

There are errors and omissions in the plan. The population of Blackmore is listed as 829; however, the area that this covers does not cover the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers.

Change suggested by respondent:

Due to the many issues listed above it is clear that the sensible modification would be to remove sites R25 and R26 from the Plan. Blackmore Village Heritage Association (BVHA) has produced a 'neighbourhood plan' which should be referred to by the Planners. This clearly sets out our local housing needs for our already sustainable community.

Full text:

I consider the plan to be unsound and fails to comply with the Duty to Cooperate for the following reasons: 1. LDP Fig 2.3 Settlement Hierarchy. There are errors and omissions in the plan. For example, the population of Blackmore is listed as 829. However, the area that this covers (see diagram attached) does not cover, amongst others, the residents in Nine Ashes Road past Red Rose Lane or the residents in the Chelmsford Road which includes a mobile home park and the illegal Traveller site. The populations stated in the plan separately for Blackmore, Hook End and Wyatts Green add up to 2402, however the total population for the Parish of Blackmore, Hook End and Wyatts Green is actually 3040. The Plan numbers are misleading and therefore invalidate assumptions made in the Plan based on population numbers. 2. Duty to Cooperate. There has not been sufficient consultation with other neighbouring authorities. 100 metres outside the parish boundary in Fingrith Hall Lane is the entrance to a development of 30 new (large) houses by Epping Forest District Council. These properties are 1.3 miles from Blackmore village centre and its amenities and more than 5 miles from any other town/ village with similar amenities. This will exacerbate the impact of the proposed 70 (40 + 30) new properties being proposed for Blackmore on the infrastructure and amenities. 3. Red Rose Lane is a single track road and is not suitable for the extra volume of traffic generated by the proposed housing. Also, Red Rose Lane, along with many other roads in and around the Blackmore area, is used regularly by walkers, joggers, cyclists, dog-walkers and horse riders. Red Rose Lane has no pavements and so the additional traffic will bring increased danger to these users. There are also very few street lights in Blackmore and none in Red Rose Lane which adds more risk. 4. Flood Risk. The village centre of Blackmore sits in a dip and is prone to flooding. Prior to the major development of the village in the 1970s there were no reports of any significant flooding. Since then there have been a number of occurrences of flooding. In 1986 a major flood occurred where many houses and St Laurence church were flooded and badly damaged. Flooding has occurred numerous times since with the most recent being 3 years ago when several houses on the Green were flooded and many of the surrounding roads (including Red Rose Lane) were impassable. At St Laurence Church graveyard in Church Street when graves are dug they fill with water immediately and need to be pumped out prior to the burial due to the high water table in the area. The addition of 70 properties will further reduce the available open land to soak up water and therefore flooding occurrences will increase. (See photos showing the Blackmore Road area near Meadow Rise from summer 2016). This flood caused extensive damage to the pavement which has not yet been repaired. 5. Policy NE06 FLOOD RISK states in 8.52: Flood risk include risk from all sources of flooding, including from rivers, from rainfall, from rising groundwater, which can overwhelm sewers and drainage systems, and from reservoirs, canals, lakes and other artificial sources. Incidences of high rainfall are forecast to increase in intensity as a result of climate change. Developing inappropriately in areas at risk from flooding, can put property and lives at risk; therefore, this policy seeks to ensure this does not happen. Blackmore is not just a high flood RISK area, flooding in Blackmore is actually an ISSUE. Therefore any development in Blackmore is clearly against this policy. 6. Infrastructure Requirements. There are no infrastructure requirements listed in policy R25 or R26. However, all amenities and services are already stretched. * The electricity, other utilities and in particular the sewerage system are unlikely to be able to cope an additional 70 properties without counting the 30 extra properties in Fingrith Hall road. The sewerage system is at maximum capacity already. * The local primary school is already full- new arrivals in the village are not able to get their children into the school and have to travel to schools in other areas. * Bus services are limited, infrequent and do not run into the evenings. * There is insufficient parking in the village centre causing people to regularly park on double yellow lines. * The doctors surgery is at capacity and waiting time for appointments are already unacceptable. 7. There is no clear housing strategy for the villages and general area in the north of the Borough. There are many options that have been suggested through this process and should have been considered but have not been. 8. A 'Housing Needs' survey should have been carried out which would have demonstrated why Blackmore has been specifically included in the LDP, and why other more suitable areas have not been included. 9. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan. 10. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land. 11. Other more suitable locations (e.g. areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal for the reasons given. 12. The proposed sites are important wildlife and natural habitats for many creatures to live undisturbed. 13. Policy HP08 seeks to regularise an illegal traveller site on the Chelmsford Road. The Borough Council has failed to undertake its duty to attempt to remove the travellers from the site since they first moved in some years ago. The Council have sat back and watched the site grow without taking any action and must re-visit this. In regularising the site the council is providing open invitation for other travellers to do the same as the council will be seen to be weak, capitulating and an easy target area. 14. Policy SP02 states that new development will be directed towards highly accessible locations along transit/growth corridors. Blackmore is not highly accessible and not along a transit I growth corridor.

Attachments:

Object

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

Representation ID: 26095

Received: 12/03/2019

Respondent: Mr James Hughes

Legally compliant? Not specified

Sound? No

Duty to co-operate? No

Representation Summary:

The population of Blackmore is listed as 829, but this doesn't make provision for the residents of Nine Ashes road nor does it cover the Travellers living illegally within the village bounds which Brentwood Council still refuse to take action on - nor the residents living on the Chelmsford road, wo all use local amenities. The total of the separate population figures do not add up to the total population figure either- by a margin of around 600 people. Assumptions have been made based on these figures, calling into question the validity of the proposals.

Change suggested by respondent:

Due to issues I have made clear I believe it is the Council's duty to remove sites R25 and R26 from the LDP such that they do not overwhelm local amenities and services; such that they do not cause further flooding by removing crucial green spaces and such that they are not driving forward with plans that would adversely affect live in the surrounding areas. Blackmore if not an affordable area for young people trying to get on the 'property-ladder': so any attempt to provide affordable housing within that area is counter-intuitive.

Full text:

I consider the plan to be unsound and fails to comply with the Duty to Cooperate for the following reasons: 1. LDP Fig 2.3 Settlement Hierarchy. The population of Blackmore is listed as 829, but this doesn't make provision for the residents of Nine Ashes road nor does it cover the Travellers living illegally within the village bounds which Brentwood Council still refuse to take action on - nor the residents living on the Chelmsford road, wo all use local amenities. The total of the separate population figures do not add up to the totaI population figure either- by a margin of around 600 people. Assumptions have been made based on these figures, calling into question the validity of the proposals. 2. Duty to Cooperate. I would say that the development of the 30 huge houses by Epping District council very close to the boundary of Blackmore Parish means that the village amenities are already under pressure- and this has not been accounted for within any of the plans. 3. The single track road named "red Rose Lane" is not suitable for extra traffic without marked improvements to the road - including fixing pot holes and filling ditches on either side. It is also continually used by the public - on foot and on horseback - and is part of at least one major cycle route. There are no walkways so the extra traffic will increase the danger to road users. 4. Flood Risk. The village centre of Blackmore irrigation is almost non-existent- and actually in recent years the continual flooding has actually washed away pavements and seeped into low-lying houses on Church Street. Some of these pavements have yet to be repaired and propose considerable risk to the ageing population in the area. I also know of occasions where freshly dug graves in the churchyard have had to have water pumped out of them. Creating new houses on the proposed sites will dramatically reduce the amount of open land and large plant life able to soak up this water. Blackmore is at continual risk of flooding which makes the proposal unfit for purpose as it will create more of an issue. The council - if it wanted to build further homes in these parishes - would have to invest heavily the irrigation of the entire village to make these plans plausible. 5. Infrastructure The plan makes no provisions for the development of local amenities and infrastructure - and the local school and doctor's surgery are already at capacity­ and wait times are far too long for an increasingly ageing population. The internet connection is appalling, the sewage system is at tipping point, there are frequent power-cuts in the area already (so the board is unlikely to be able to cope with the addition of new properties), Public Transport is almost non-existent in the village (and the 61 bus, which I used for 2 years to get to work in Brentwood, was and continues to be under threat) and parking anywhere is a nightmare - especially on Sundays (church services) and during the yearly firework displays which are organised by the Parish Council. 6. A survey should have been carried out to demonstrate the need for housing - and in particular the need for 'type of housing'. I have already expressed my distaste for Epping Council's development of what I would call 'mansions'. Being 21 years of age, mortgaging a house anywhere in this area seems like a dream to me -one I hope to realise but one I have come to understand will be nearly impossible in my lifetime. 7. There are more suitable locations with better access to larger towns in the area: extensions to Brentwood or possibly increasing the size of the proposal for Dunton Hills would all have better transport links for commuters, on better kept roads. 8. Some of the proposed sites in Blackmore are incredibly vital to the survival of certain types of wildlife in the English countryside -we have seen a huge decline in the hedgehog population countrywide in the last few years and the green sites around Blackmore provide a safe haven for these creatures. 9. I have a particular problem with the regularisation of the Traveller site on Chelmsford Road as detailed in policy HP08. I served on the Parish Council for a year before I moved to Brentwood so I have experienced first-hand the failure of Brentwood Borough Council to exercise its duty to attempt to remove the Travellers from the site. I have sympathy obviously that the Travellers have had children who now attend the local school - but the very fact that they have been able to settle for that long just provides proof that they are no longer 'travelling'. Further prof has been sent to the Council in recent years of the fact that many 'Travellers' at that site actually own property elsewhere, which invalidates their 'Traveller' status. If this site is regularised, Brentwood is opening its doors to further illegal settlements. And on a personal note I feel this is an affront to honest people who are desperately trying to save to purchase a place to call their own legally - especially in an area of such high house/land prices. 10. Policy SP02 states that new development will be directed towards highly accessible locations along transit/growth corridors. Blackmore is neither of these things.

Attachments: