Remove sites R25 and R26 from the Local Plan

1. There are several other developments taking place in the North of the Borough in addition to those proposed for Blackmore. No consideration has been taken in respect of these additional developments which if taken into account could well fulfil the local housing requirements without building on Green Belt Land.
2. From the discussions at a recent meeting with council representatives they were not fully aware f these other developments for example in the region of 30 dwellings at the top of Fingrith Hall Lane which will also further add to the unacceptable impact of the village
3. The planning officers have not had sufficient detailed dialogue with other local boroughs to ensure that proposals take into account all local development and options for example the development taking place in the Fyfield Road out of Ongar. I cannot accept that Brentwood Council acts independently without due consideration to all local developments that would impact on what is a huge impact which cannot be sustained by Blackmore Village.
4. The principle of residential development off of Red Rose Lane is wrong - Blackmore is an isolated village with modest services and infrastructure and I would point out the current challenges we face living here:
* One village shop/Post Office with very restricted parking
* A Doctors surgery whereby I genuinely hope I do not need to request urgent care. If you want any form of response you have to continuously dial repeatedly to get assistance - comments on the website page highlights this.
* The local village school has very limited places and resources which was put under further pressure due to a large unapproved travelling community site with some 20-30 caravans and families is also impacting on the village resources available.
5. Red Rose Lane itself is entirely unsuitable for this volume of traffic movements. This lane is regularly used currently by large agricultural vehicles which have to by-pass the village due to their size. They are large "Tracked" Tractors units towing large trailers which take up the full width of the lane and this closes the road to oncoming traffic. If they meet any vehicles coming the other way have to reverse to one of two temporary "Passing Places". Additionally large school buses use this lane again creating serious safety risks. The risk of a further 70-80 vehicles accessing the planned site and village early and late periods has simply not been fully considered and will not be feasible.

Red Rose Lane regularly floods with the water coming down Nine Ashes Road like a river and into the lane. The ditches and limited drainage near to the junction simply cannot cope and a large area is regularly left under water during the winter months. Flooding has increasingly become an issue in recent years and has now started to erode the lane at the front of our house. This will also further impact the flooding risk in the village which has been an increasing problem.

I would also add that the recent and what I would say "convenient" excessive cutting back of the bushes and trees on either side will further contribute to the flooding risk this during winter months due to the foliage now lying in the verge and ditches.

Due to the above access on/off of Red Rose Lane is simply not a viable prospect and the width of the road restricts this.

6. As a local resident I find the whole review and consultation process has been carried out in an open transparent or logical way which I would have expected if due legal process had been followed. At the initial consultations meeting so many questions were asked that the persons present could not answer and it was only when challenged by our community that further discussions took place to fully explain what was being proposed. At the last meeting we challenged the council planners in respect of other options both in and around the village which they had not taken into consideration.
7. Brentwood Council has simply not demonstrated that they have taken into account other Brownfield sites that are available which surely must take priority over the development of Green Belt Lane between Red Rose Lane and Blackmore Village.
8. No housing needs survey has been carried out by the council to justify why Blackmore has been included in the Local Development Plan and they have failed to demonstrate that the required housing could not be met by increasing housing density on other (allocated) sites.
9. Blackmore has been "singled out" because there are more suitable locations for example further urban extension to Brentwood whereby there would be sufficient resources to sustain expansion - and the locations in Blackmore do not promote sustainable development.
The current proposed plan is simply not viable as all the options have not been investigated.

Remove sites R25 and R26 from the Local Plan

1. There are several other developments taking place in the North of the Borough in addition to those proposed for Blackmore. No consideration has been taken in respect of these additional developments which if taken into account could well fulfil the local housing requirements without building on Green Belt Land.
2. From the discussions at a recent meeting with council representatives they were not fully aware f these other developments for example in the region of 30 dwellings at the top of Fingrith Hall Lane which will also further add to the unacceptable impact of the village
3. The planning officers have not had sufficient detailed dialogue with other local boroughs to ensure that proposals take into account all local development and options for example the development taking place in the Fyfield Road out of Ongar. I cannot accept that Brentwood Council acts independently without due consideration to all local developments that would impact on what is a huge impact which cannot be sustained by Blackmore Village.
4. The principle of residential development off of Red Rose Lane is wrong - Blackmore is an isolated village with modest services and infrastructure and I would point out the current challenges we face living here:
* One village shop/Post Office with very restricted parking
* A Doctors surgery whereby I genuinely hope I do not need to request urgent care. If you want any form of response you have to continuously dial repeatedly to get assistance - comments on the website page highlights this.
* The local village school has very limited places and resources which was put under further pressure due to a large unapproved travelling community site with some 20-30 caravans and families is also impacting on the village resources available.
5. Red Rose Lane itself is entirely unsuitable for this volume of traffic movements. This lane is regularly used currently by large agricultural vehicles which have to by-pass the village due to their size. They are large "Tracked" Tractors units towing large trailers which take up the full width of the lane and this closes the road to oncoming traffic. If they meet any vehicles coming the other way have to reverse to one of two temporary "Passing Places". Additionally large school buses use this lane again creating serious safety risks. The risk of a further 70-80 vehicles accessing the planned site and village early and late periods has simply not been fully considered and will not be feasible.

Red Rose Lane regularly floods with the water coming down Nine Ashes Road like a river and into the lane. The ditches and limited drainage near to the junction simply cannot cope and a large area is regularly left under water during the winter months. Flooding has increasingly become an issue in recent years and has now started to erode the lane at the front of our house. This will also further impact the flooding risk in the village which has been an increasing problem.

I would also add that the recent and what I would say "convenient" excessive cutting back of the bushes and trees on either side will further contribute to the flooding risk this during winter months due to the foliage now lying in the verge and ditches.

Due to the above access on/off of Red Rose Lane is simply not a viable prospect and the width of the road restricts this.

6. As a local resident I find the whole review and consultation process has been carried out in an open transparent or logical way which I would have expected if due legal process had been followed. At the initial consultations meeting so many questions were asked that the persons present could not answer and it was only when challenged by our community that further discussions took place to fully explain what was being proposed. At the last meeting we challenged the council planners in respect of other options both in and around the village which they had not taken into consideration.
7. Brentwood Council has simply not demonstrated that they have taken into account other Brownfield sites that are available which surely must take priority over the development of Green Belt Lane between Red Rose Lane and Blackmore Village.
8. No housing needs survey has been carried out by the council to justify why Blackmore has been included in the Local Development Plan and they have failed to demonstrate that the required housing could not be met by increasing housing density on other (allocated) sites.
9. Blackmore has been "singled out" because there are more suitable locations for example further urban extension to Brentwood whereby there would be sufficient resources to sustain expansion - and the locations in Blackmore do not promote sustainable development.
The current proposed plan is simply not viable as all the options have not been investigated.

remove sites R25 and R26 from the Local Plan

As attached

remove sites R25 and R26 from the Local Plan

As attached

Remove sites R25 and R26 from the Local Plan

As attached

remove sites R25 and R26 from the Local Plan

As attached

remove sites R25 and R26 from the Local Plan

As attached

Remove sites R25 and R26 from the Local Plan

As attached.

Remove sites R25 and R26 from the Local Plan

As attached.

Remove sites R25 and R26 from the Local Plan

As attached.

Remove sites R25 and R26 from the Local Plan

As attached.

The proposed development in Blackmore should be removed from that plan, and any necessary development should be targeted at areas with suitable infrastructure (capacity). Sites R25 and R26 should be removed from the plan and the planes should refer to the BVHA neighbourhood plan which clearly sets our the Blackmore local housing needs.

Sections 9 (site allocations)
Policy R25 - 9.197-9.200
Policy R26, 9.201-9.205
Section 4 (managing growth)
Policy SP01-D(a) D (f)
Para 4.9,4.2
Policy SP02
Section 8 (natural environment
Policy NE 06, 8.5-8.8.64 - para 8.85 (iv), 8.90, 8.101
Policy NE13

Unsound
Infrastructure and resources fully stretched at present so no capacity for further development in Blackmore
Blackmore has been disproportionately targeted with a 30% increase in the current population proposed.
There must be more suitable brownfield sites within the borough that having to build on Green Belt in Blackmore
The Blackmore sites of R25 and R26 are entirely unsuitable for large scale development

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

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.

The issues listed shows that the modification would be to remove sets R25 and R26 from the plan. Blackmore Village Heritage Association has produced a plan which should be referred to by the planners. The Plan sets out our local housing needs for our community.

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 9.197 -9.200
Policy R26 paras 9.201 - 9.204
LPP Fig 2.3 settlement hierarchy. There are errors in the plan, population states 829 but does not include houses past Red Rose Lane or the residents in Chelmsford Road and Traveller site.
Duty to cooperate. Not enough consultation with neighbouring authorities.
Red Rose Lane is single track and wont cope with more traffic
Flood Risk
Policy NE06 Flood Risk 8.52
Infrastructure requirements - no infrastructure improvements have been listed in R25 or R25. The local school is at capacity with no room for more children.
The doctors is too at capacity, waiting times are bad already.
Electricity and services wont be able to cope with 70 extra houses.

Refer to BHVA Neighbourhood Plan - remove sites R25 and R26 from plan

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.

See BHVA neighbourhood plan which I support (remove sites R25 and R26 from plan)

Local plan unsound.
On Green Belt
Developer led which is against national guidelines
Inadequate access, Red Rose Lane too narrow and floods frequently
Local amenities unable to cope with existing residents
Would result in large increase in traffic which is already increased dramatically in last 12 months

Remove sites R25 & R26 from the Local Plan. Planners should refer to the BVHA 'neighbourhood plan' which sets out our local housing needs and that the Blackmore community is already sustainable.

The Local GP services are struggling to cope as is more homes increases the demand but there is no consideration in increasing GP services. The school size as is well be unable to accept more children.
The access roads to the proposed building areas are not adequate to take the increased volume that the extra homes will bring.
When there is heavy rain in the area, flooding is a risk factor, building more homes can only aggregate this.
Green Belt should be kept as it is. There are more areas that should be left, other sites need to be looked into more.
The sites R25 and R26 should be removed from LDP and that planners should refer to the BVHA 'neighbourhood plan' which clearly sets out our local housing needs, as the Blackmore community is already sustainable.

Should consider alternative sites (not Green Belt) ideally brownfield sites
Remove R25 and R26 from the LDP plan
Refer to BHV Neighbourhood Plan which sets out local housing needs

Section 4 Policy SP01, D (a) D (f) Para 4.4; Policy SP01
Section 8 Policy NE 06, 8.5-8.64,
Section 8 Para 8.85, 8.90. 8.101; Policy NE13
Section 9 Policy R25, 9.97-9.200; Policy R26, 9.201-9.205
Local Plan, unsound, failure to consult with Epping Forest District Council. Re:- 30 houses being built on Fingrith Hall Lane which will already impact on the village
Village prone to flooding
No clear strategy for the village, no infrastructure
The school is full and not able to cope with any additional houses / families.
The preschool is full and not able to accommodate any further children at this stage, it is in the village hall with no possibility of being able to increase child number
Doctors filled to capacity. Residents already have to wait 4 weeks for a routine appointment. If additional houses are built this would make this service reach breaking point
Bus service is not sufficient enough
Wildlife destroyed
Green Belt land, unacceptable to build on
Volume of traffic would ruin village, make it unsafe for school children

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

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

An adequate housing needs survey requires to be undertaken. This has not happened in Blackmore. To assess the impact on traffic flows through the village, a projected traffic survey requires to be undertaken.
To ensure that Blackmore does not become an urban suburb of Brentwood, a greater and wide consultation is required with those who are impacted by the development of the village 

See attached

The plan overall is not the issue- I am challenging policies R25 and R26/Blackmore's inclusion in the LDP solely. Please refer to the attached village survey of July 2018, which is hereby re-submitted. Blackmore Village Heritage Association will have an updated "Neighbourhood Plan" available.

Section 4
Policy SP01 - D(a), D(f)
Paragraphs 4.2and 4.9
Policy SP02

Section 08
Policy NE06 8.5-8.64
Para 8.85 (iv)
Para 8.90
Para 8.101

Policy NE13

Section 09
Policy R25, 9.197-9.200
Policy R26, 9.201-204


The plan is deficient in respect of Blackmore village and unsound on all 4 tests in particular:

1. There is no clear 'strategy ' for the villages including Blackmore, in the north of the borough.
2. BBC has not consulted adequately with Epping Forest District Council. Over houses being constructed and/or planned close to Blackmore village.
3. The principle of residential development off of Redrose Lane is wrong, Blackmore is an isolated village with modest services and infrastructure (The school is full, the doctors surgery is Doddinghurst is already over subscribed inadequate bus service, narrow lanes and already dangerous parking, sewerage system is overloaded already etc).
4. There are more suitable and or sustainable locations, eg urban extensions of Brentwood (eg Honeypot Lane), and the locations in Blackmore so not promote sustainable development.
5. BBC has not demonstrated that there are other brownfield sites that are available and which should take priority over the Greenfield/Green Belt land off of Redrose Lane.
6. BBC has failed to demonstrate that the required housing could not be met by increasing housing density on other (allocated) sites.
7. There has been no 'housing needs survey' to demonstrate why Blackmore village is included in the LDP.
8. The access off/from Redrose Lane is entirely unsuitable for this volume of traffic movements.
9. The entire village is prone to severe flooding, and sites R25 and R26 are both liable to flood. Building on this land will only increase the flood risk elsewhere in the village.
10. Both fields (R25 and R26) are teeming with wildlife - hundreds of birds nest in the hedgerows within and around the fields. We have photographic evidence (stills and videos) of certain protected species (bats, Barn Owls, Great Crested Newts).

Proposed modifications

The plan overall is not the issue- I am challenging policies R25 and R26/Blckmore's inclusion in the LDP solely.
Please refer to the attached village survey of July 2018, which is herby re-submitted.
Blackmore Village Heritage Association will have an updated "Neighbourhood Plan" available.

Why attend Examination in person?
As Chairman of he "Blackmore Village Heritage Association", I wish to present our own vision for our village based on what Blackmore actually needs.
There will be a form of "Neighbourhood Plan" available, which will significantly update the attached village survey dated 2018.

The Blackmore sites R25 and R26 should be removed from the plan until there has been 1. A full housing need survey for Blackmore; 2. A proper consultation, including BBC taking into account alternative sites; 3. A properly formulated strategy from BBC in relation to protecting the heritage and character of the villages within the Borough

See attached.
Section 4
Policy SP01 - D(a), D(f)
Paragraphs 4.2and 4.9
Policy SP02

Section 08
Policy NE06 8.5-8.64
Para 8.85 (iv)
Para 8.90
Para 8.101

Policy NE13

Section 09
Policy R25, 9.197-9.200
Policy R26, 9.201-204

The Plan is unsound because it fails to comply with the requirements set out in the National Planning
Policy Framework ("NPPF") para 35 as follows:
a) It has not been properly prepared:
* Brentwood Borough Council ("BBC') has failed to objectively assess the area's housing
needs in particular in reference to the proposed development of housing in the village of
Blackmore (Site Policy Numbers R25 and R26.
* The Blackmore Sites suddenly appeared in the draft plan in January 2018 but had not
been in the earlier drafts of the plan which were consulted on during the course of 2016.
* No clear strategy for the villages in the Borough has been consulted on publicly, nor has
there been any consultation evidenced with the bordering Local Authorities (Epping
Forest DC and Chelmsford City Council), whose boundaries both adjoin Blackmore Parish and whose residents' needs directly impact Blackmore Village in respect of housing
provision, transport and other services. For example, there is already a development of
30 houses (approved by Epping Forest, without any evidence of consultation with BBC or
Blackmore Parish Council) in progress at the top of Fingrith Hall Road which will impact
the infrastructure, amenities and other facilities of Blackmore.
* No evidence has been provided in the Local Development Plan of how these
developments have been assessed to be sustainable in light of the impact the BBC
proposals, plus the Epping Forest development and how they will impact the local
infrastructure and character of the village of Blackmore.
b) It is not justified on the following grounds:
* There has been no evidence put forward by BBC, such as a local housing need
assessment for the village of Blackmore which would justify expanding the village
housing stock by around a third. There has been no consultation in the village of its
housing needs. In or around 2016 or 2017 there was a local meeting arranged to review if affordable housing was required in the village. This proposal was abandoned
due to the negative feedback from villagers.
* The BBC have failed to consider other more suitable locations for development which
would not (a) encroach and irrevocably damage greenbelt land (contrary to Section
13 of the NPPF) (b) negatively impact the character, rural nature and restricted
amenities on offer in the village of Blackmore and (c) would make use of existing
suitable infrastructure and amenities, such as Brownfield sites, or sites with public
transport and those other existing sites in the plan where the local infrastructure
could easily bear an increased density in numbers of housing
* No proportionate evidence (or any at all) has been included in the plan to justify the
proposed developments in Blackmore or how issues such as access to these proposed
sites which are serviced currently by small narrow lanes or how other local
infrastructure such as drainage, increased traffic flow on what are narrow country
roads around Blackmore, schools, doctors surgeries will be dealt with.
c)
It is not consistent with national policy:
*
It does not enable the delivery of sustainable development as the proposed
developments in Blackmore village as the infrastructure will not support an increase in
traffic on the single track roads and lack of parking at the school and village shop, school
places in a school that is already at capacity with a large waiting list, additional pressure
on the already crowded only doctor's surgery in Doddinghurst.
* Under the NPPF section 13 conservation of the Green Belt is set out and the Plan states that the BBC "will continue to resist strongly pressure to allow development in these clusters". The proposal to grow what is a historic, rural village such as Blackmore by a third is not consistent with either the national policy of keeping greenbelt land open and BBC's own policy to avoid irrevocable damage to the character of the Green Belt.

The Blackmore sites R25 and R26 should be removed from the plan until there has been 1. A full housing need survey for Blackmore; 2. A proper consultation, including BBC taking into account alternative sites; 3. A properly formulated strategy from BBC in relation to protecting the heritage and character of the villages within the Borough

Section 4
Policy SP01 - D(a), D(f)
Paragraphs 4.2and 4.9
Policy SP02

Section 08
Policy NE06 8.5-8.64
Para 8.85 (iv)
Para 8.90
Para 8.101

Policy NE13

Section 09
Policy R25, 9.197-9.200
Policy R26, 9.201-204
The Plan is unsound because it fails to comply with the requirements set out in the National Planning
Policy Framework ("NPPF") para 35 as follows:
a) It has not been properly prepared:
* Brentwood Borough Council ("BBC') has failed to objectively assess the area's housing
needs in particular in reference to the proposed development of housing in the village of
Blackmore (Site Policy Numbers R25 and R26.
* The Blackmore Sites suddenly appeared in the draft plan in January 2018 but had not
been in the earlier drafts of the plan which were consulted on during the course of 2016.
* No clear strategy for the villages in the Borough has been consulted on publicly, nor has
there been any consultation evidenced with the bordering Local Authorities (Epping
Forest DC and Chelmsford City Council), whose boundaries both adjoin Blackmore Parish and whose residents' needs directly impact Blackmore Village in respect of housing
provision, transport and other services. For example, there is already a development of
30 houses (approved by Epping Forest, without any evidence of consultation with BBC or
Blackmore Parish Council) in progress at the top of Fingrith Hall Road which will impact
the infrastructure, amenities and other facilities of Blackmore.
* No evidence has been provided in the Local Development Plan of how these
developments have been assessed to be sustainable in light of the impact the BBC
proposals, plus the Epping Forest development and how they will impact the local
infrastructure and character of the village of Blackmore.
b) It is not justified on the following grounds:
* There has been no evidence put forward by BBC, such as a local housing need
assessment for the village of Blackmore which would justify expanding the village
housing stock by around a third. There has been no consultation in the village of its
housing needs. In or around 2016 or 2017 there was a local meeting arranged to review if affordable housing was required in the village. This proposal was abandoned
due to the negative feedback from villagers.
* The BBC have failed to consider other more suitable locations for development which
would not (a) encroach and irrevocably damage greenbelt land (contrary to Section
13 of the NPPF) (b) negatively impact the character, rural nature and restricted
amenities on offer in the village of Blackmore and (c) would make use of existing
suitable infrastructure and amenities, such as Brownfield sites, or sites with public
transport and those other existing sites in the plan where the local infrastructure
could easily bear an increased density in numbers of housing
* No proportionate evidence (or any at all) has been included in the plan to justify the
proposed developments in Blackmore or how issues such as access to these proposed
sites which are serviced currently by small narrow lanes or how other local
infrastructure such as drainage, increased traffic flow on what are narrow country
roads around Blackmore, schools, doctors surgeries will be dealt with.
c)
It is not consistent with national policy:
*
It does not enable the delivery of sustainable development as the proposed
developments in Blackmore village as the infrastructure will not support an increase in
traffic on the single track roads and lack of parking at the school and village shop, school
places in a school that is already at capacity with a large waiting list, additional pressure
on the already crowded only doctor's surgery in Doddinghurst.
* Under the NPPF section 13 conservation of the Green Belt is set out and the Plan states that the BBC "will continue to resist strongly pressure to allow development in these clusters". The proposal to grow what is a historic, rural village such as Blackmore by a third is not consistent with either the national policy of keeping greenbelt land open and BBC's own policy to avoid irrevocable damage to the character of the Green Belt.

Sites R2S and R26 should be removed from the LDP. Blackmore Village Heritage Association in
cooperation with the local Parish Councils will be producing a local needs plan that will look at the
actual needs within the local area for what is already a sustainable community rather than producing
a plan that Just seeks to help the Borough Council meet its housing quota, and planners should
instead refer to this and produce an updated plan In cooperation with the local community.

Section 4 (Managing Growth)
Paragraphs 4.9, 4.20
Policy SP02
Section 8 (Natural Environment)
Policy NE06-8.51-8.64
Paragraphs 8.85, 8.90, 8.101
Policy NE13
Section 9 (Site Allocations)
Allocation R25 - paragraphs 9.197-9.200
Allocation R26- paragraphs 9.201-9.204

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

Sites R2S and R26 should be removed from the LDP. Blackmore Village Heritage Association in
cooperation with the local Parish Councils will be producing a local needs plan that will look at the
actual needs within the local area for what is already a sustainable community rather than producing
a plan that Just seeks to help the Borough Council meet its housing quota, and planners should
instead refer to this and produce an updated plan In cooperation with the local

All of the points should be reassessed with local involvement.
Blackmore does need some small scale development especially for the older population. Downsizing would be an option that would free up existing larger properties.

The plan Is unsound.
a) There has been no evidence produced to show that there is a need for this size of development in Blackmore
b) There has been no discussion or cooperation with any local bodies 30 houses have just been built just outside the village In EFDC area that will Impact on the village
c) There are many aspects that do not comply with the NPPF Guidance.
Protection of Green Belt
Development located to minimize travel
Local community not consulted
No proven local need
All of the above points should be reassessed with local involvement.
Blackmore does need some small scale development especially for the older population. Downsizing would be an option that would free up existing larger properties.

* A clear need for the proposals to be reconsidered as part of a new 'strategy' for the Villages (Including Blackmore) in the North of the borough/North of Brentwood town.
* Proper and appropriate consultation with Epping Fortes District Council to ensure that these developments on the boundaries or the two boroughs are appropriately addressed with capable, sustainable integrated plans. [30+ houses in Fingrith Hall lane+ 4 pairs of semi's on former Nine Ashes Farm affect Blackmore I And more are being developed In King Street on the pub site]
* Proper consideration to alternative sites in the Village- Brown field Red Rose Farm, or the area -Stondon or re-Inclusion of Honey Pot Lane. These are either more suitable or more sustainable or both.
* Housing needs In the area do not require this density development- assign more to other areas
.* Perform a proper and appropriate Housing Need Survey and rely on the outcome of that.
* Do not propose access to/egress from sites (such as R25 and R26 on roads entirely unsuitable for it.
.* Do not propose developments In a place (Blackmore R25 and R26) where there Is already a severe flooding problem which h the development will worsen and no mitigation proposal in the plans.
* Respect results of prior planning enquiries which found that Traveller pitches Plot 3 oak Tree Farm were not appropriate. Likewise no not recognise Plots 1 and 2 which were previously not approved for entirely appropriate reasons.

Section 4
Policy SP01
Policy SP02
Policy SP03

Section 07
Policy PC 14

Section 08
Policy NE06
Policy NE13

Section 09
Policy R25
Policy R26


I have lived in Blackmore since mid 1984 and strongly supported the community in making and keeping this a happy and pleasure place to live in: fighting to maintain the library, The continued designation of the Bull as a Public House-(now a Community Asset) and the denial of planning agreement for the Travellers on the Oak Tree Farm Plot 3 and Wenlock Meadow.
I - like many others - could recognise the validity of the 2016 LOP proposals but the latest (Reg 19) proposals run contrary to that in both the proposals for Plots R25 and R26 and the suggestion to recognise Plots - Oak Tree Farm. NONE-OF THIS IS JUSTIFIED OR APPROPRIATE.
It is therefore UNSOUND in addition to being not justified and - In view of other very local developments in Epping Forest (in Nine Ashes Road and Fingrith H.-11 Lane-all of which use and overstress facilities in Blackmore - not compliant with the duty to cooperate.
Additionally
1) The removal of Blackmore from the designated Green Belt areas is unsound and the very suggestion that it be counted with Mountnesslng and lngrave in being suitable for additional development is unsound and frankly perverse in that there are poor public transport and only minor roads (several of which have notices to say they are unsuitable for heavy traffic) and other infrastructure in Blackmore village compared to these other towns on A roads with all day frequent bus services.
2) The LOP proposal has substantially changed the way it treats Blackmore from earlier plans to considered right up to Reg 18, with no proper debate or explanation of why some sites have SUDDENLY been included after Initially being 'promised' to be excluded e.g. Blackmore R25/26 and Oak Tree Farm traveller pitches.
3) Some eminently suitable sites have been removed disappeared from the LOP eg Honeypot Lane. 4) The late changes to the plan and administration/conduct of the November Council meeting prevented discussion of these key elements at the meeting and inappropriately curtailed the amount of time available to properly consider and challenge it. [In fact - when Reg 18 was debated in the BBC chamber a) Items were Included without any prior warning or debate eg Formal inclusion of Traveller Site Status In Chelmsford Road, and b) major concerns and alternative proposals were totally and deliberately avoided by using of a guillotine motion-seemingly aimed to stop any Blackmore concerns being raised].
5) Little of what Is In the Reg 19 Draft Plan (aside from with Dunton Hills and the South of the Borough ) appears properly Integrated- or to have been addressed to fulfil the *0uty to Cooperate*. The developments assigned to Villages to the North of Brentwood with poor infrastructure, amenity (full schools, GP surgery under pressure already etc.) and transport links (and concentrated principally on Blackmore in the Green Belt) falls most tests of rationality or lack coherent Justification. "Least worst" Is not an acceptable rationale when thoroughly acceptable alternatives are being denied.
6) The earlier (circa 2016) LOP drafts contained significant reference ta quality of life', 'maintaining sustainable communities', 'Improving residents' existence' for the future and 'working for the people' was a recurring theme. I feel that these recent omissions are due to the fact that the plans no longer fit these criteria and are aimed solely to meet the dwellings and traveller site numbers criteria. Such rationale makes the plans unacceptable and unsound.
7) The formal comments process Issued to Residents -THIS FORM - is not one which most residents will be able to approach sensibly or compete accurately: - It needs a degree specialist knowledge or explanation by Councillors and others with intimate knowledge of planning ,natters. [It Is so complex and confusing for almost anyone who is not a professional planner. It has prevented large numbers of ordinary residents from responding even though they have major concerns. It Is difficult not to see this as a deliberate ploy to avoid hearing genuine concerns.
I
8) The 'Duty to Cooperate' (work With adjacent Councils/Planning Groups appears to have been poor to non-existent with Epping Forest (EF) - the near neighbour to Blackmore. Epping Forest is not - as far as I can see from reading the LDP - mentioned *as having been consulted at all!!! EF are erecting some 30 houses within about a mile of Blackmore (Former 'Roding Stables at Norton Heath) and has recently allowed completion of 4 pairs of 4 bed semi- detached houses on the former Nine Ashes Farm * all of which will use Blackmore facilities, school, roads, local su11ery etc ** This MUST be taken into account.
9) Other private developments in and around Blackmore are not being counted and properly agreed as mitigation on the numbers being suggested.
10) I would contend that small amounts which C.I.L required from developers would raise will be grossly Insufficient to do an adequate Job of protecting the local community- even if it was actually directed at the village Impacted by the development It was related to (which is rarely the case).
11) Our Parish Council and Borough Councillor(s) confirm that no relevant "Housing Needs Survey has been completed for Blackmore -. SO there Is no evidence that the proposed sites are required for the benefit of Blackmore nor that they will fulfil the needs of the local community sites (eg Red *Rose Farm for one) that are available and should take precedence over the Green * Belt Sites R25 and R26 which are proposed.
13) More logical sites on the outskirts of major towns eg Honeypot Lane have been removed from the latest proposals. Substitute these, please !!
14) It Is unsound to arbitrarily place disproportionate growth on one existing* community which will cause It harm, leaving others with nothing at an when they would actually like some development to Improve their sustainability. e.g. Blackmore v Stondon (who have already approached Brentwood Planning and, I understand, been turned down!)
15) It ls unsound, unjustified and wholly Inappropriate, wrong and flawed to propose a 30% Increase in dwellings for any community which is already challenged with transport links, schools, health care etc. when others do not reach double figure increa5'5. [The% Increase Is more like 50% if related developments [from Epping Forest- already built or In construction) were* to be considered. (see 8 above).
16) No appropriate consideration appears to have has been given to Counties "Protected Lanes" & "Quiet lanes" policies. See 9-.41 page 134. "Certain lanes have historic and landscape value and they are Important to the character of the county. It Is the policy of Essex County Council to preserve their traditional character by avoiding disturbance to the banks, ditches and verges wherever possible. Some verges contain unusual plant species, which should be safeguarded and encouraged through appropriate management. The protection of lanes and verges, including trees and hedges alongside them, will be pursued in co-operation with adjoining landowners and the Highways Authority, using traffic management measures where this is appropriate" & C10 Protected lanes DEVELOPMENT PROPOSALS THAT WOULD ADVERSELY AFFECT THE PHYSICAL APPEARANCE OF THE PROTECTED LANES OF HISTORIC OR LANDSCAPE VALUE OR GIVE*RISE TO A MA'TERIAL INCREASE IN THE AMOUNT OF TRAFFIC USING THESE LANES AND ROADS WILL NOT BE PERMITTED.
17) When questioned at public meetings and at other times, the BBC Planning Team have avoided responsibility for any solutions to Infrastructure and other Issues by suggesting that these will be addressed by Developers. So far, no surveys have been undertaken to ascertain If a problem exists with the development proposed. This means that the proposal Is made with outstanding unresolved issues and no meaningful solutions. This seems unsound, unjustified, ineffective and flawed.
18) A multiplicity of shortfalls are present In the proposals for R25 and R26 Including
a) lack of employment viability;
b) Lack of transport links;
c) lack of infrastructure;
d) lack of medical facilities;
e) lack of education facilities;
f) Severe flooding problems;
g) lack of roads to build the development and subsequently deal with the substantial increase In traffic movement;
h) loss of Green Belt and
I) damage to natural habitats.
When problems are this significant, solutions must be proposed before including in the Listed Sites. Failure to do this is unsound, unjustified, Ineffective and flawed.
* A clear need for the proposals to be reconsidered as part of a new 'strategy' for the Villages (Including Blackmore) in the North of the borough/North of Brentwood town.
* Proper and appropriate consultation with Epping Fortes District Council to ensure that these developments on the boundaries or the two boroughs are appropriately addressed with capable, sustainable integrated plans. [30+ houses in Fingrith Hall lane+ 4 pairs of semi's on former Nine Ashes Farm affect Blackmore I And more are being developed In King Street on the pub site]
* Proper consideration to alternative sites in the Village- Brown field Red Rose Farm, or the area -Stondon or re-Inclusion of Honey Pot Lane. These are either more suitable or more sustainable or both.
* Housing needs In the area do not require this density development- assign more to other areas
.* Perform a proper and appropriate Housing Need Survey and rely on the outcome of that.
* Do not propose access to/egress from sites (such as R25 and R26 on roads entirely unsuitable for it.
.* Do not propose developments In a place (Blackmore R25 and R26) where there Is already a severe flooding problem which h the development will worsen and no mitigation proposal in the plans.
* Respect results of prior planning enquiries which found that Traveller pitches Plot 3 oak Tree Farm were not appropriate. Likewise no not recognise Plots 1 and 2 which were previously not approved for entirely appropriate reasons.
The Residents of Blackmore have not had their case property heard In a general review and it still needs to be heard and reflected modifications of the plans and the removal of R25 and R26 from the plan -and removal of the previously unapproved Traveller pitches on oak Tree Farm.

Blackmore representatives time was cut short (and discussion guillotined) at a major meeting In November and there were late additions to the plan about development In Blackmore (notably 7 Traveller Plots) which had not been pre-notified., So I see this as the first time when the full case can be heard by a relevant authority. I am happy to be (at least one of) the people who pts to have a say on behalf of the village and surrounding area.

Since November 2018, several alternative sites to R25 R26 have been notified to the Brentwood Planners who appear unwilling to revise plans further despite having- In previous drafts and the 2016 plan 1) - excluded R25 and R26 and 2) excluded the unapproved {even at temporary level} Traveller plots for what local residents and our counsellors consider are relevant reasons eg Green Belt location, Traveller site permission previously refused but enforcement action not taken up by Brentwood Council.

* A clear need for the proposals to be reconsidered as part of a new 'strategy' for the Villages (Including Blackmore) in the North of the borough/North of Brentwood town.
* Proper and appropriate consultation with Epping Fortes District Council to ensure that these developments on the boundaries or the two boroughs are appropriately addressed with capable, sustainable integrated plans. [30+ houses in Fingrith Hall lane+ 4 pairs of semi's on former Nine Ashes Farm affect Blackmore I And more are being developed In King Street on the pub site]
* Proper consideration to alternative sites in the Village- Brown field Red Rose Farm, or the area -Stondon or re-Inclusion of Honey Pot Lane. These are either more suitable or more sustainable or both.
* Housing needs In the area do not require this density development- assign more to other areas
.* Perform a proper and appropriate Housing Need Survey and rely on the outcome of that.
* Do not propose access to/egress from sites (such as R25 and R26 on roads entirely unsuitable for it.
.* Do not propose developments In a place (Blackmore R25 and R26) where there Is already a severe flooding problem which h the development will worsen and no mitigation proposal in the plans.
* Respect results of prior planning enquiries which found that Traveller pitches Plot 3 oak Tree Farm were not appropriate. Likewise no not recognise Plots 1 and 2 which were previously not approved for entirely appropriate reasons.

Section 4
Policy SP01
Policy SP02
Policy SP03

Section 07
Policy PC 14

Section 08
Policy NE06
Policy NE13

Section 09
Policy R25
Policy R26


I have lived in Blackmore since mid 1984 and strongly supported the community in making and keeping this a happy and pleasure place to live in: fighting to maintain the library, The continued designation of the Bull as a Public House-(now a Community Asset) and the denial of planning agreement for the Travellers on the Oak Tree Farm Plot 3 and Wenlock Meadow.
I - like many others - could recognise the validity of the 2016 LOP proposals but the latest (Reg 19) proposals run contrary to that in both the proposals for Plots R25 and R26 and the suggestion to recognise Plots - Oak Tree Farm. NONE-OF THIS IS JUSTIFIED OR APPROPRIATE.
It is therefore UNSOUND in addition to being not justified and - In view of other very local developments in Epping Forest (in Nine Ashes Road and Fingrith H.-11 Lane-all of which use and overstress facilities in Blackmore - not compliant with the duty to cooperate.
Additionally
1) The removal of Blackmore from the designated Green Belt areas is unsound and the very suggestion that it be counted with Mountnesslng and lngrave in being suitable for additional development is unsound and frankly perverse in that there are poor public transport and only minor roads (several of which have notices to say they are unsuitable for heavy traffic) and other infrastructure in Blackmore village compared to these other towns on A roads with all day frequent bus services.
2) The LOP proposal has substantially changed the way it treats Blackmore from earlier plans to considered right up to Reg 18, with no proper debate or explanation of why some sites have SUDDENLY been included after Initially being 'promised' to be excluded e.g. Blackmore R25/26 and Oak Tree Farm traveller pitches.
3) Some eminently suitable sites have been removed disappeared from the LOP eg Honeypot Lane. 4) The late changes to the plan and administration/conduct of the November Council meeting prevented discussion of these key elements at the meeting and inappropriately curtailed the amount of time available to properly consider and challenge it. [In fact - when Reg 18 was debated in the BBC chamber a) Items were Included without any prior warning or debate eg Formal inclusion of Traveller Site Status In Chelmsford Road, and b) major concerns and alternative proposals were totally and deliberately avoided by using of a guillotine motion-seemingly aimed to stop any Blackmore concerns being raised].
5) Little of what Is In the Reg 19 Draft Plan (aside from with Dunton Hills and the South of the Borough ) appears properly Integrated- or to have been addressed to fulfil the *0uty to Cooperate*. The developments assigned to Villages to the North of Brentwood with poor infrastructure, amenity (full schools, GP surgery under pressure already etc.) and transport links (and concentrated principally on Blackmore in the Green Belt) falls most tests of rationality or lack coherent Justification. "Least worst" Is not an acceptable rationale when thoroughly acceptable alternatives are being denied.
6) The earlier (circa 2016) LOP drafts contained significant reference ta quality of life', 'maintaining sustainable communities', 'Improving residents' existence' for the future and 'working for the people' was a recurring theme. I feel that these recent omissions are due to the fact that the plans no longer fit these criteria and are aimed solely to meet the dwellings and traveller site numbers criteria. Such rationale makes the plans unacceptable and unsound.
7) The formal comments process Issued to Residents -THIS FORM - is not one which most residents will be able to approach sensibly or compete accurately: - It needs a degree specialist knowledge or explanation by Councillors and others with intimate knowledge of planning ,natters. [It Is so complex and confusing for almost anyone who is not a professional planner. It has prevented large numbers of ordinary residents from responding even though they have major concerns. It Is difficult not to see this as a deliberate ploy to avoid hearing genuine concerns.
I
8) The 'Duty to Cooperate' (work With adjacent Councils/Planning Groups appears to have been poor to non-existent with Epping Forest (EF) - the near neighbour to Blackmore. Epping Forest is not - as far as I can see from reading the LDP - mentioned *as having been consulted at all!!! EF are erecting some 30 houses within about a mile of Blackmore (Former 'Roding Stables at Norton Heath) and has recently allowed completion of 4 pairs of 4 bed semi- detached houses on the former Nine Ashes Farm * all of which will use Blackmore facilities, school, roads, local su11ery etc ** This MUST be taken into account.
9) Other private developments in and around Blackmore are not being counted and properly agreed as mitigation on the numbers being suggested.
10) I would contend that small amounts which C.I.L required from developers would raise will be grossly Insufficient to do an adequate Job of protecting the local community- even if it was actually directed at the village Impacted by the development It was related to (which is rarely the case).
11) Our Parish Council and Borough Councillor(s) confirm that no relevant "Housing Needs Survey has been completed for Blackmore -. SO there Is no evidence that the proposed sites are required for the benefit of Blackmore nor that they will fulfil the needs of the local community sites (eg Red *Rose Farm for one) that are available and should take precedence over the Green * Belt Sites R25 and R26 which are proposed.
13) More logical sites on the outskirts of major towns eg Honeypot Lane have been removed from the latest proposals. Substitute these, please !!
14) It Is unsound to arbitrarily place disproportionate growth on one existing* community which will cause It harm, leaving others with nothing at an when they would actually like some development to Improve their sustainability. e.g. Blackmore v Stondon (who have already approached Brentwood Planning and, I understand, been turned down!)
15) It ls unsound, unjustified and wholly Inappropriate, wrong and flawed to propose a 30% Increase in dwellings for any community which is already challenged with transport links, schools, health care etc. when others do not reach double figure increa5'5. [The% Increase Is more like 50% if related developments [from Epping Forest- already built or In construction) were* to be considered. (see 8 above).
16) No appropriate consideration appears to have has been given to Counties "Protected Lanes" & "Quiet lanes" policies. See 9-.41 page 134. "Certain lanes have historic and landscape value and they are Important to the character of the county. It Is the policy of Essex County Council to preserve their traditional character by avoiding disturbance to the banks, ditches and verges wherever possible. Some verges contain unusual plant species, which should be safeguarded and encouraged through appropriate management. The protection of lanes and verges, including trees and hedges alongside them, will be pursued in co-operation with adjoining landowners and the Highways Authority, using traffic management measures where this is appropriate" & C10 Protected lanes DEVELOPMENT PROPOSALS THAT WOULD ADVERSELY AFFECT THE PHYSICAL APPEARANCE OF THE PROTECTED LANES OF HISTORIC OR LANDSCAPE VALUE OR GIVE*RISE TO A MA'TERIAL INCREASE IN THE AMOUNT OF TRAFFIC USING THESE LANES AND ROADS WILL NOT BE PERMITTED.
17) When questioned at public meetings and at other times, the BBC Planning Team have avoided responsibility for any solutions to Infrastructure and other Issues by suggesting that these will be addressed by Developers. So far, no surveys have been undertaken to ascertain If a problem exists with the development proposed. This means that the proposal Is made with outstanding unresolved issues and no meaningful solutions. This seems unsound, unjustified, ineffective and flawed.
18) A multiplicity of shortfalls are present In the proposals for R25 and R26 Including
a) lack of employment viability;
b) Lack of transport links;
c) lack of infrastructure;
d) lack of medical facilities;
e) lack of education facilities;
f) Severe flooding problems;
g) lack of roads to build the development and subsequently deal with the substantial increase In traffic movement;
h) loss of Green Belt and
I) damage to natural habitats.
When problems are this significant, solutions must be proposed before including in the Listed Sites. Failure to do this is unsound, unjustified, Ineffective and flawed.
* A clear need for the proposals to be reconsidered as part of a new 'strategy' for the Villages (Including Blackmore) in the North of the borough/North of Brentwood town.
* Proper and appropriate consultation with Epping Fortes District Council to ensure that these developments on the boundaries or the two boroughs are appropriately addressed with capable, sustainable integrated plans. [30+ houses in Fingrith Hall lane+ 4 pairs of semi's on former Nine Ashes Farm affect Blackmore I And more are being developed In King Street on the pub site]
* Proper consideration to alternative sites in the Village- Brown field Red Rose Farm, or the area -Stondon or re-Inclusion of Honey Pot Lane. These are either more suitable or more sustainable or both.
* Housing needs In the area do not require this density development- assign more to other areas
.* Perform a proper and appropriate Housing Need Survey and rely on the outcome of that.
* Do not propose access to/egress from sites (such as R25 and R26 on roads entirely unsuitable for it.
.* Do not propose developments In a place (Blackmore R25 and R26) where there Is already a severe flooding problem which h the development will worsen and no mitigation proposal in the plans.
* Respect results of prior planning enquiries which found that Traveller pitches Plot 3 oak Tree Farm were not appropriate. Likewise no not recognise Plots 1 and 2 which were previously not approved for entirely appropriate reasons.
The Residents of Blackmore have not had their case property heard In a general review and it still needs to be heard and reflected modifications of the plans and the removal of R25 and R26 from the plan -and removal of the previously unapproved Traveller pitches on oak Tree Farm.

Blackmore representatives time was cut short (and discussion guillotined) at a major meeting In November and there were late additions to the plan about development In Blackmore (notably 7 Traveller Plots) which had not been pre-notified., So I see this as the first time when the full case can be heard by a relevant authority. I am happy to be (at least one of) the people who pts to have a say on behalf of the village and surrounding area.

Since November 2018, several alternative sites to R25 R26 have been notified to the Brentwood Planners who appear unwilling to revise plans further despite having- In previous drafts and the 2016 plan 1) - excluded R25 and R26 and 2) excluded the unapproved {even at temporary level} Traveller plots for what local residents and our counsellors consider are relevant reasons eg Green Belt location, Traveller site permission previously refused but enforcement action not taken up by Brentwood Council.

The above sites should be removed from the LDP and the planners should refer to the Blackmore Village Heritage Association Neighbourhood Plan. This clearly sets out the village's local housing needs for our already sustainable community.

The proposed developments of R25 and R26 of the Local Plan, in conjunction with the current development of 30 houses at Fingrith Hall Lane and a proposed development of affordable housing in Nine Ashes Road will put extreme pressure on the infrastructure and facilities currently being sustained by Blackmore Village.
There has been inadequate consultation between Brentwood BC and Epping Forest DC.
The categorisation of Category 3 (i.e. large village) given to Blackmore Village should be downgraded to a Category 4 (i.e. small village). Total population 829. Village consists of one village shop, which includes 1 desk for the Post Office and one small Primary School. The nearest Doctors Surgery in Doddinghurst, which is already experiencing appointment difficulties and this will be exacerbated by the proposed developments of R23 and R24.
The proposed sites are liable to flood and building on these sites will increase the flood risk elsewhere in the village, of which there is photographic evidence.
There has been no Housing Needs Survey to demonstrate why Blackmore has been included in the LDP and the decision contradicts the LDP which in 2016 stated that growth in Rural North and Rural South areas of the Borough would be limited to retain "local character".
The proposed developments in Blackmore do not promote sustainable development and other suitable/sustainable locations e.g. urban extension to Brentwood should be considered plus further addition to "The Dunton Hills Garden Village" project.

Proposed modifications
The above sites should be removed from the LDP and the planners should refer to the Blackmore Village Heritage Association Neighbourhood Plan. This clearly sets out the village's local housing needs for our already sustainable community.

Refer to Blackmore Heritage Village Association Neighbourhood Plan.

I consider the plan as unsound for a variety of reasons. It will put pressure on a rural infrastructure. The character of the village will be impacted, currently it is enjoyed by local people and others who come to walk, bike ride, horse ride and run. Additional traffic due to increased car journeys will put pressure on local lanes, parking etc, especially as bus routes will not suit everyone's daily routines.
Medical centre, shop and school also impacted adversely.
The village is in designated 100% Green Belt land, other sites i.e. brownfield are available should be considered first. There should be efforts to protect the countryside for the benefit of all as it is fast disappearing in this area.

Proposed modifications:
Refer to Blackmore Heritage Village Association Neighbourhood Plan.

Smaller and more dispersement (on preferably Brownfield sites) for any new builds in the surrounding area, rather than focusing such large development within an already stretched pretty village.

See attached.