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.

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.

Should consider alternative sites , not Green Belt, ideally brownfield sites. Remove R25 and R26 form plan. Refer to BVHA neighbourhood plan which sets out local housing need

There is no clear 'strategy ' for the villages including Blackmore, in the north of the borough. BBC has not consulted adequately with Epping Forest District Council. Over houses being constructed and/or planned close to Blackmore village. The principle of residential development off of Redrose Lane is wrong, Blackmore is an isolated village with modest services and infrastructure (The school and preschool 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). 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. 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. BBC has failed to demonstrate that the required housing could not be met by increasing housing density on other (allocated) sites. There has been no 'housing needs survey' to demonstrate why Blackmore village is included in the LDP. The access off/from Redrose Lane is entirely unsuitable for this volume of traffic movements. 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.

I believe that R25 and R26 should be removed from the LDP. Planners should refer to the Blackmore village Heritage Association "neighbourhood plan" which clearly sets out our local housing needs to avoid further development locally.  

Refer to attached form. Objection to Blackmore sites R25 and R26.

R25 and R26 should be taken out of the LDP> The 'Neighbourhood Plan' from the BVHA should be looked at by the planners. This clearly sets out the local housing needs.

See attached sheet

I believe BBC should remove Blackmore from the list of proposed sites and find a more suitable and sustainable "brownfield" site that could cope with the residential development and perhaps an urban extension to Brentwood where the infrastructure is already in place.
Necessary to build a refuse tip - al have been removed from local area, hence the increase in fly tipping etc.
Do a housing needs survey, to check schools, doctors, services, etc.

Refer to attached form

Both sites R25 and R26 should be removed from the LDP. Planners should look at the BVHA neighbourhood plan which clearly states the housing needs of the local community. Green Belt land should not be built on when brownfield sites are available. Housing needs survey should be done.

Refer to attached form

All of the above points should be reassessed with local involvement.
Local housing need to be assessed.
The size of the local school needs to be considered
The Doctors surgery is already oversubscribed and consideration needs to be given on to how address this.
Flooding is an issue and needs greater consideration. The Woollard Way field (R25) is often flooded.
Not an issue as a field but this surface water will need to go somewhere if the field is concreted over. (as a local villager my Father used this field and its ponds to water his horses).
Any development of this size needs to be located nearer to good transport links.
Small brownfield developments need to be considered.
Blackmore does need some small scale development especially for the older population. Downsizing would be an option that would free up existing larger properties.

Section 04: (Managing Growth)
Policy SP0l - D (a) and D (t) Para 4.9, Para 4.2, Policy SP02
Section 08: (Natural Environment)
Policy NE06, 8.5 - 8.64, Para 8.85 (iv), Para 8.90, Para 8.101,
Policy NE 13
Section 09: (Site Allocation)
Policy R25, 9.197 - 9.200
Policy R26, 9.201 - 9.204

The plan is unsound.
a) There is no proof that Blackmore needs this number of houses
b) There has been no discussion with the villagers.
c) No cooperation with any local neighbouring authorities. 30 houses have just been built outside
the village in EFDC area that will impact on the village. 8 houses recently built at what was
Nine Ashes Farm again in EFDC area.
d) The LDP does not comply with NPPF Guidance:
No protection of Green Belt
Development is not located to minimize travel
Local community not consulted
There is no proven local need
There has been no Flood Risk Assessment
The location does not 'minimize travel' as required

All of the above points should be reassessed with local involvement.
Local housing need to be assessed.
The size of the local school needs to be considered
The Doctors surgery is already oversubscribed and consideration needs to be given on to how address this.
Flooding is an issue and needs greater consideration. The Woollard Way field (R25) is often flooded.
Not an issue as a field but this surface water will need to go somewhere if the field is concreted over. (as a local villager my Father used this field and its ponds to water his horses).
Any development of this size needs to be located nearer to good transport links.
Small brownfield developments need to be considered.
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 significant reduction in the scale and number of houses to be built.

Policies: R25; R26; SP02; SP02; NE06; NE13
This will put intolerable pressure on GP services the local surgery fails to me demand. Blackmore is a small community based around a small number of roads that are not designed to meet the inevitable increase in traffic due to a wholly inadequate public transport service. It is the level and scale of this development that is excessive and inappropriate.
A significant reduction in the scale and number of houses to be built.

Remove sites R25 and R26 from plan

LOP Section 04: (Managing growth)
Policy SP0l - O(a) and O(f)
Para 4.9
Para 4.20
Policy SP02
LOP Section 08: (Natural Environment)
Policy NE06, 8.51- 8.64
Para 8.85 (iv)
Para 8.90
Para 8.101
Policy NE13
LDP Section 09: (Site Allocation)
- Policy R25, 9.197 - 9.200
- Policy R26, 9.201- 9.204
I consider the Local Plan to be unsound, not legally compliant and fails to comply with the Duty to
Cooperate on the following grounds:
1. Soundness: Local Planning Authorities must prepare a Local Plan based on relevant and appropriate evidence base.
a. In my opinion the evidence base has not considered a number of germane facts- or if it has it has not provided sufficient weight to the following:
i. Health - General Practice. Deal Tree Health Centre is already operating at figures
beyond the optimum number of patients per GP, as outlined in the Brentwood
Infrastructure Delivery Plan (IDP). New housing has already impacted this
further, with developments in Rookery Road and The Elms in Lower Road
Mountnessing, along with travellers who have occupied land on the Chelmsford
Road all squeezing Deal Tree Health Centre further. The addition of 70 new
properties in Blackmore under R25 and R26 will further exacerbate the problem.
ii. Primary Education: DODDINGHURST / KELVEDON HATCH (Group 3) primary
provision which includes Blackmore Primary School, has insufficient spaces on
several grounds:
1. In accordance with the National Audit Office report "Capital Funding for
New School Places' (2013) there should be a minimum 5% surplus that
the Department for Education assumes in its planning as necessary to
support operational flexibility (mid-year admissions) and facilitate
parental choice. A deficiency may thus be deemed to exist without the
certainty of every local place being filled". DODDINGHURST / KELVEDON
HATCH (Group 3) primary provision which includes Blackmore Primary
School, has only a 3% surplus.
2. Blackmore Primary School is currently full so has no surplus, let alone the
5% that the NAO recommends, or the 3% that is mentioned for Group 3
in the BBC paper.
3. In addition, 70 new properties in the Group 3 catchment is directly in
Blackmore, further compounding the poor situation. This includes
additional housing proposed by EFDC for the top end of Fingrith Hall
Lane. Although such housing is not in Brentwood Borough's plans, the
schooling for these houses will be assumed to be in Blackmore Primary
School.
iii. Services and the environment in Blackmore. There is a limited bus service with
the final bus from Brentwood Station leaving at 18:35. This will mean that new
residents will need to own one possibly two cars. With so little parking capacity
in Blackmore, this will have a detrimental impact on the village centre.
iv. Roads in Blackmore. There is no through road in the village, and plan to use Red
Rose Lane for the sites R25 and R26 is a major flaw in the planning. It is a single-
track road and marked as unsuitable for large vehicles. Therefore, the
construction of 70 properties and their subsequent use by the new residents will
present significant difficulties along Red Rose Lane.
v. Sewage and drainage. What are the plans for extending these if we are to avoid
the flooding and associated health risks which we have experienced in the past
few years? The presence of 70 properties will add to this problem, especially
with their run-off.
vi. Electricity, gas, telephone and internet. There will need to be additional facilities
installed to support the proposed 30% growth. Has this been considered?
2. Duty to Cooperate: Throughout the plan-making process discussions have taken place with various statutory consultees and neighbouring authorities.
a. In my opinion there has been insufficient engagement with neighbouring authorities, in particular with Epping Forest. This is reflected in the fact that the development planned for Fingrith Hall Lane of some 30 houses by EFDC will inevitably put a strain on Blackmore as described above for the following aspects:
i. Health
ii. Schooling
iii. Roads
iv. Services and the environment in Blackmore
3. Legally Compliant: Local Planning Authorities must prepare a Local Plan which adheres to the requirements as set out in the National Planning Policy Framework (NPPF), planning practice guidance, and a other relevant planning regulations
& legislation
a. In my opinion the Local Plan has not adhered to the NPPF because of its disregard of the following:
i. Green Belt. Central Government has said that Green Belt must be protected. It
appears that the BBC is disregarding the green belt status of the village.
ii. Maintaining the local ecology. The development of R25 and R26 will damage
important areas for our wildlife.
iii. Blackmore's heritage. Blackmore is a village with great history, some dating back
to Tudor times. It is incumbent on us all to retain our heritage. The growth of
30% to Blackmore with its knock-on impact on the lanes and roads around the
village will jeopardise this.
iv. Other inclusions. The BBC seems to have amended the status of the Travellers
Site in Chelmsford Road, and wrapped it into the Local Plan. Was it legal to do
so?
The BBC planners should perform the outstanding and incomplete tasks as outlined above. In addition, the planners should take notice of the neighbourhood plan (BVHA) which sets out the Blackmore local housing needs and how Blackmore can continue to support a sustainable community.
Sites R25 and R26 should be removed from the Local Plan.

As there seems to be considerable doubt that all aspects of the planning process have been adhered to R26 and R26 should be removed from the LDP. Leave Blackmore in the Green Belt and restore its classification as a Rural Village in a setting with non f the amenities enjoyed by areas such as Mountnessing and Ingrave i.e. a through road., regular buses over an extended time frame, a doctors surgery that can be reached on foot. BBC should refer to the BVHA neighbourhood plan which clearly sets out local housing need for our already sustainable community.
Please note that this was a very difficult form to fill in as many on us have limited knowledge of the planning process!

R25 and R26 - refer to attached form.

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 Blackmore 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) Para 4.2, 4.9
Policy SP02
Section 8 (natural environment
Policy NE 06, 8.5-8.64 - para 8.85 (iv), 8.90, 8.101
Policy NE13
Policy R25 - 9.197-9.200
Policy R26, 9.201-9.205

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 the houses being constructed and/or planes, close to Blackmore Village.
3. The principle of residential development off of Red Rose Lane is wrong. Blackmore is an isolated village with modest services and infrastructure. (The school is full, the doctors surgery in 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 or Brentwood, (Eg Honeypot Lane) and the locations in Blackmore do 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 Green Field/Green Belt land off of Red Rose 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 Red Rode 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 teaming 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)
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 Blackmore Village Survey of July 2018, which is hereby re-submitted.
Blackmore Village Heritage Association will have an updated "Neighbourhood Plan "available.
As Chairman of the "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 dates July 2018.

Amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

Represent many residents in Blackmore and surrounding area against inclusion of R25 and R26 in the plan.

BRENTWOOD LOCAL PLAN
REGULATION 19 CONSULATION REPONSE
ON BEHALF OF
BLACKMORE, HOOK END & WYATTS GREEN PARISH COUNCIL
BLACKMORE VILLAGE HERITAGE ASSOCIATION

1. This joint representation is made on behalf of:
1.1. The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2. The Blackmore Village Heritage Association ('BVHA')

Introduction
2. The Parish Council is a statutory consultee and represents 350 households in Blackmore village (population of only 943) included in a total population of 2,561 within the wider Parish with its three distinct separate settlements. This figure does not include the many households in neighbouring villages who rely on Blackmore's facilities.

3. BVHA is an unincorporated, not for profit, organisation and has in excess of 150 active members but its newsletters are distributed to over 1,000 households.

4. Both the Parish Council and BVHA strongly oppose the proposed allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land north of Orchard Piece, Blackmore) for housing development. The proposed allocation is for "around 40 new homes" at R25 and for "around 30 new homes" at R26.

5. They say that the proposed allocations R25 and R26 are contrary to both National and Local Policies.

6. In simple terms the Parish Council's and BVHA's case is as follows:
6.1. Brentwood Borough Council has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites.
6.2. Without prejudice to the above contention, if no such sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.
6.3. In any event, there are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.
6.4. Moreover, R25 and R26 are inherently unsuitable developments because of (1) inadequate access, (2) flooding, (3) it will result in disproportionate increase in the housing stock, and, (4) the development would not be sustainable.

7. The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan).

8. Accordingly, the Parish Council and BVHA submit that the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').

Background

9. Blackmore is currently a village of approximately 350 dwellings which are home to 943 people (according to the Electoral Register). The proposal to add "around 70 homes" will add approximately 25% to the existing village housing stock. The proportionate increase to the village population would likely be greater by virtue of the number of current dwellings being occupied by two or less villagers. Outside of the LDP, housing stock is also increasing through normal planning processes both within Brentwood Borough Council and our neighbouring Epping Forest Council which will impact upon Blackmore village.

10. Blackmore is a picturesque village and surrounded by countryside. The Village Green has ponds at its eastern end. There is a village shop including post office, Primary School, two village halls, a sports and social club, tennis courts, football and cricket pitches, and a flood-lit Multi-Use Games Arena. All of these facilities are at capacity use. The village has three pubs: The Prince Albert, The Bull, and The Leather Bottle.
In addition to the Anglican parish Church there is a Baptist Church in the village. However, Blackmore has a very limited bus service and is thus remote. It is over 6 miles from the centre of Brentwood and thus the villagers of Blackmore are reliant on the motor car.

11. The village School is at capacity and local residents are having to send children to neighbouring schools. There is limited scope for expansion. It is socially undesirable for some village children to be able to attend the village school and others to be "shipped out". This social harm (i.e. lack of cohesion) would be exacerbated if more resident village children had to be "shipped out" to another school.

12. In respect of employment opportunities within Blackmore these are limited and, of those of working age nearly all, if not all, commute out of the village. That commute takes place, if not exclusively, almost exclusively by private motor car. Such further evidences that Blackmore is an unsustainable location for new development.

13. Both R25 and R26 are on the Northern Boundary of the village of Blackmore. Both are bordered (to the north) by Redrose Lane, a rare extant example of a "plague detour route". Redrose Lane is narrow and with limited passing space for two motor cars. Vehicles larger than a car (i.e. Transit van and above) cannot pass without one, or the other, stopping (see Appendix One). Development of 70 dwellings would undoubtedly result in a significant number of vehicular movements - in the order of 600 to 700 per day - and, without suitable improvements (which would erode the character of Redrose Lane), cause harm.

14. Both R25 and R26 are in the Green Belt. Both are on land classified as "very good" agricultural land. Both sites have ecological value and, more importantly, local residents have reported sightings of bats, owls and newts at, or in the vicinity of, R25 and R26 (See Appendix Two).

15. Whilst the Environmental Agency classifies both sites within Flood Zone 1, both R25 and R26 have flooded historically - and both have an identified flood risk (see Appendix Three).

16. The BVHA undertook a survey in July 2018 of local residents and visitors to the Village. The BVHA survey confirms that residents are opposed to the proposed allocation of R25 and R26. Of the responses received from village residents, over 300, 98% were strongly opposed to the allocation of sites R25 and R26. It should be noted that the response numbers (over 300 adult residents in the village) was extremely good and evidences the strength of local feeling. It also outlines the engagement of the local Community.

Issues concerning Consultation and Consistency

17. It is a maxim that "good planning is consistent planning".

18. The Current Local Plan (the Brentwood Replacement Local Plan) dates to 2005 and tightly controls development in the Green Belt. Thus, development on R25 and R26 is contrary to the current Local Plan policies absent "very special circumstances".

19. In a 2014 site assessment document, which was and is part of the current emerging local plan process, sites R25 and R26 were discounted as they did not meet the (then) draft Local Plan spatial strategy.

20. It is not clear why this assessment has changed - indeed, the constraints surrounding site R25 and R26 remain unchanged.

21. More recently, in the Council's (Regulation 18) 2016 draft Local Plan, it was stated that "No amendment is proposed to the Green Belt boundaries surrounding larger villages [Blackmore is defined as a larger village] in order to retain the character of the Borough in line with the spatial strategy" (para 5.33). That spatial strategy seeking, insofar as it was necessary to do so, "limited release of Green Belt land for development within transport corridors, in strategic locations to deliver selfsustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries". So even though Brentwood Borough Council had identified a potential need for release of Green Belt land, no suitable land was identified in Blackmore.

22. There has therefore been a significant shift of policy; namely from a position of no development at R25 and R26 to now seeking to allocate these sites for residential development. The Parish Council and BVHA say that the change in position is inconsistent and wrong for reasons more fully set out below.

23. The Parish Council and BVHA also wish to record that the Council's planning Team, represented by a Strategic Director and three other Senior Officers, confirmed at a public meeting on 31 January 2019 that Blackmore's allocation was a result of property developers promoting the development of land on which their companies held options. The Parish Council and BVHA take the view that, not only would the proposed allocation of R25 and R26 appear to be "developer-led" rather than plan led, it shows a lack of thorough and appropriate research, and understanding of the unique character and circumstances of Blackmore. The Parish Council and BVHA further take the view that developer pressure is not a good and sufficient reason for Brentwood Borough Council to abdicate its duty to promote a sound, and consistent, Development Plan.

Evidence Base

24. Paragraph 31 NPPF provides that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence.

25. Part of the evidence is the "Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report - January 2019" ('the SA'). The SA tells us that a number of sustainability 'topics' inform the framework for assessing the sustainability of the site. Flooding is one of those topics (see Table 3.1 of the SA).

26. Risk of flooding is important to any sustainability appraisal not only because the NPPF and emerging policy NE06 seek to direct development away from areas of highest risk of flooding but also because flooding can put lives and property at risk. It is therefore surprising that, for all bar 21 potential sites, the SA does not consider flood risk in assessing sustainability.

27. The Level 1 Strategic Flood Risk Assessment does assess risk however and identifies a medium risk of surface water flooding for Redrose Lane (Table A4b) with Site R26 being potentially vulnerable to climate change and with a 1 in 100 annual probability of surface water flooding (Table A6b). The findings appear at odds with the fact that Sites R25 and R26 are lower than Redrose Lane and thus, one may expect, may be more vulnerable to flooding than higher land (i.e. Redrose Lane). Indeed, these sites have consistently flooded as evidenced by the photographs in Appendix Two.

28. There are, of course, documents supporting housing need. However, there is no evidence of local housing need for Blackmore, or any other villages. Whilst the Parish Council and BVHA accept that there may be some demand for housing any such demand should be properly evidenced with any housing allocation proportionate and ensuring that houses are being built in the right places.

Sustainable Development

29. It is a core planning principle that plans should be prepared with the objective of contributing to the achievement of sustainable development (para 16(a) NPPF). Paragraph 8 NPPF outlines three objectives that the planning system should strive to meet.

30. The proposed allocation of sites R25 and R26 meets none of these objectives in that:
30.1. Economic objective - any contribution arising from the construction of new dwellings will be short-lived. There are no, or extremely limited, employment opportunities within Blackmore and the likelihood of new residents driving a demand for new services within the village would appear, at best, limited. In short, any economic benefits are short-term.
30.2. Social objective - services in Blackmore are limited and the primary school is at capacity sending additional village children to school elsewhere will further erode social cohesion.
30.3. Environmental objective - occupiers of sites R25 and R26 would undoubtedly be reliant on private motor cars. The sites are at risk of flooding (surface water at least) and require the release of high-grade agricultural land in the Green Belt. Redrose Lane is narrow and infrastructure works would be required to make necessary improvements which would harm the character of this area but may also result in the loss of historic hedges and important habitats.

31. There are other sites which are in far more sustainable locations which should be allocated in preference. Indeed, the SA identifies a number of sites (n.b. no scoring for flood risk) with better scores than sites R25 and R26, good examples being in Shenfield, Mountnessing, Pilgrims Hatch, Ingatestone and Brentwood such as, but not limited to, sites 038A, 253, 277B, 297, 218B, 053B, 189, 318, 288B, 153, 280, 024A and 130.

32. Furthermore, development in less sustainable locations, such as R25 and R26, before more sustainable locations, should be avoided.

Green Belt

33. Sites R25 and R26 are in the Green Belt. The Government attaches great importance to Green Belts (per para 133 NPPF). The Green Belt serves five purposes (para 134 NPPF) which includes safeguarding the countryside from encroachment, preserving the character of historic towns and assisting in urban regeneration.

34. The NPPF further confirms that, once established, Green Blt boundaries should only be altered where exceptional circumstances are fully evidenced and justified (para 136 NPPF). Meeting an assessed housing need is not an exceptional circumstance. No other exceptional circumstances are put forward by Brentwood Borough Council.

35. Regardless, the NPPF is clear in that before concluding that exceptional circumstances exist to justify changing Green Belt boundaries Brentwood Borough Council should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified housing need (para 137 NPPF). In this respect the Parish Council and BVHA say:
35.1. There is no evidence that increasing densities elsewhere negates the need for the release of Green Belt land at sites R25 and R26. It should be remembered that the proposed Green Belt release, per Figure 4.2, only 123 of those homes are to be provided in the "larger villages" such as Blackmore which accounts for 1.5% of the total housing need (which includes a 20% buffer). This is a very modest contribution to housing supply which, the Parish Council and BVHA say, could easily be met by considering all other reasonable alternatives.
35.2. There are brownfield sites which should be identified, considered and used in preference.
35.3. There are also urban sites that should be used in preference, or alternatively, sites in more sustainable locations (i.e. close(r) to urban areas).
35.4. The village of Stondon Massey has actively sought new development within its boundaries. The same may be true of other villages within the Borough. Such "localised" development may reduce or negate the need for sites R25 and/or R26.

36. In consequence of the above, the Parish Council and BVHA say that Brentwood Borough Council has not demonstrated that it fully evidenced and justified a need to alter Green Belt boundaries nor that it has examined fully all other reasonable alternatives before doing so.

37. Further to the above, the notes to draft policy SP02 confirm that growth is prioritised "based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas where deemed appropriate" (para 4.22). The inclusion of R25 and R26 runs contrary to this - both being greenfield land in the Green Belt. Whilst SP02 itself talks of the need to direct development to "highly accessible locations" - sites R25 and R26 are in a rural area with poor transport links and limited accessibility. The inclusion of R25 and R26 thus conflicts with policy SP02.

A Settlement Category 3 village?

38. As above the Parish Council and BVHA say that Blackmore should be classed as a Settlement Category 4 village and not the higher Category 3. They say this because:
38.1. There is no local shopping parade but, instead, one Co-Op Store (with Post Office), a hairdressers and a coffee shop;
38.2. It does not have a health facility - the nearest Doctor's surgery is in Doddinghurst (which is ~3 miles away and on roads not suitable for walking); and
38.3. There are no, or very few, local jobs. Of those of working age nearly all commute out of the village.

39. Accordingly, some of the key attributes of a Category 3 settlement are, in Blackmore's case, missing. As a more general point the population of Blackmore is modest and a considerable margin less than that of Doddinghurst and Kelvedon Hatch which are also classified as Category 3 settlements.

40. Further, of the Category 3 settlements it is only Blackmore (sites R25 and R26) and Kelvedon Hatch (sites R23 and R24) that it is proposed to allocate sites for housing/development. Kelvedon Hatch is in the order of 2.5 times larger (by population) than Blackmore - however its proposed housing allocation (total of ~53) is less, by approximately 25%, than that proposed for Blackmore.

41. This is in contrast to the larger Category 3 settlements of Doddinghurst and Ingrave which have no proposed allocation for housing. Indeed, no allocation is proposed for the other Category 3 settlements of Herongate and Mountnessing.

42. Simply put, the Parish Council and BVHA say that the classification of, and proposed
housing allocation in, Blackmore is incorrect.
Other

43. The Parish Council and BVHA support the strategy within the plan. Indeed, in the main they recognise and support the policies within the draft plan. However, they take issue with allocations of sites R25 and R26; not only for the reasons above but when considered against the policy which Brentwood Borough Council are promoting. For example, sites R25 and R26 perform poorly against, or conflict with, draft policies SP01, SP02, SP03, NE01, NE09, BE12, BE13 and BE45. This is not withstanding the case that, in applying the NPPF, the Parish Council and BVHA say that development should be directed elsewhere in preference to sites R25 an R26.

44. The Parish Council and BVHA also take issue with the fact that of the 123 net homes allocated for "larger villages" 70, or approximately 56% of the total allocation, are met by these two sites. Thus, a disproportionately large amount of the allocation is from sites R25 and R26.

45. The above is notwithstanding the Parish Council and BVHA's primary contention that sites R25 and R26, but possibly all proposed sites on Green Belt Land in larger villages (i.e. settlement category 3), can and should be removed from the Plan.

46. The evidence of working with adjoining planning authorities is limited with a general statement that "adjacent planning authorities [have] confirmed that they [are] unwilling and unable to take any of the Brentwood identified housing need". The Parish Council and BVHA invite Brentwood Borough Council to more fully disclose the extent and nature of discussions that have been held with neighbouring authorities.

Summary/Conclusion

47. The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.

48. Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.

49. Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.

50. Sites R25 and R26 are in an unsustainable location served by a constrained access (Redrose Lane) and with an identified risk of flooding. The development of R25 and R26 does not represent sustainable development.

51. The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.

52. There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. Regardless, the proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).

53. The plan is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.

54. The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.

55. Brentwood Borough Council should amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

HOLMES & HILLS LLP
Dated 18 March 2019
 
Appendix One - Redrose Lane PHOTOS

Redrose Lane from Chelmsford Road junction Redrose Lane from Nine Ashes
Road junction
Further image of Redrose Lane - note Above: image illustrating width (or lack
cut-up verges and lack of centre lines of) of Redrose Lane
(i.e. delineating insufficient width for two
vehicles to pass)

Appendix Two - re R25 and R26 as Important Habitat sites PLUS PHOTOS


Blackmore Wildlife
The wildlife listed below has all been observed in the fields by Woollard Way and Orchard
Piece and these fields provide invaluable nesting and foraging grounds.
Birds:
Redpoll, Yellowhammer, Skylarks, Barn Owls, Little Owls, Buzzard, Red Kite,
Sparrowhawk, Song Thrush, Red-legged Partridges, Kestrels, Turtle Doves, Hedge
sparrow, Siskin.
In particular Barn Owls and their nesting sites are protected by law during the breeding
season - https://www.bto.org/volunteer-surveys/ringing/taking-part/protected-birds/s1-
list
Turtle doves, Skylarks and Yellow Hammers are on the RSPB's red list which means,
amongst other things, that the species is globally threatened and are the highest priority
for conservation - https://www.rspb.org.uk/birds-and-wildlife/wildlife-guides/ukconservation-
status-explained/
Above: Owl on Site R25/R26 Above: Sparrowhawk in adjacent
garden
Turtle Dove - video:
IMG_8370 turtle
dove.MOV
Reptiles:
Grass Snakes and Great Crested Newts which are a protected species -
https://www.wildlifetrusts.org/wildlife-explorer/amphibians/great-crested-newt
Above (both): Great Crested Newt in "composting bin" in neighbouring garden to R26
Bats:
All bats are protected by the law in the UK - https://www.bats.org.uk/advice/bats-andthe-
law
They are frequently seen flying around the fields (i.e. R25 and R26) and there is possible
nesting in the outbuildings.
Bats - video:
https://drive.google.com/file/d/15Be5ZUlvRwEDhh_ivlLf1fxb0Rf2QS3z/view


Appendix Three - Agricultural Land Assessment and Flooding/Flood Risk

Map extract - ECC
Flood risk map 2018 (source - Essex County Council website - "check if you are
at risk of flooding" - with annotations)

Above: Chelmsford Road flooding- 1987 Above: Redrose Lane flooding - 1987

Above: Flooding on The Green - 2016 Above: Flooding on Redrose
Lane - 2016 (note depth of water)


Above: Chelmsford Road flooding - Above: Redrose Lane flooding -
23 June 2016 (n.b. next to site R26) 23 June 2016

Above: Redrose Lane - March 2018

Extract from Daily Telegraph re 2011 Flooding:

Extract from Express re 2011 Flooding:

A woman is rescued from her car stuck in floodwater in Blackmore,
Essex, yesterday newspaper article inc photo
Express - 18 Jan 2011
Fire Service in Redrose Lane east bound to Chelmsford Road. (see picture below)
Extract from Romford Recorder re 2011 flooding: including an incident where a person had to be rescued from their car in Red Rose Lane, Blackmore.

Amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

Represent many residents in Blackmore and surrounding area against inclusion of R25 and R26 in the plan.

BRENTWOOD LOCAL PLAN
REGULATION 19 CONSULATION REPONSE
ON BEHALF OF
BLACKMORE, HOOK END & WYATTS GREEN PARISH COUNCIL
BLACKMORE VILLAGE HERITAGE ASSOCIATION

1. This joint representation is made on behalf of:
1.1. The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2. The Blackmore Village Heritage Association ('BVHA')

Introduction
2. The Parish Council is a statutory consultee and represents 350 households in Blackmore village (population of only 943) included in a total population of 2,561 within the wider Parish with its three distinct separate settlements. This figure does not include the many households in neighbouring villages who rely on Blackmore's facilities.

3. BVHA is an unincorporated, not for profit, organisation and has in excess of 150 active members but its newsletters are distributed to over 1,000 households.

4. Both the Parish Council and BVHA strongly oppose the proposed allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land north of Orchard Piece, Blackmore) for housing development. The proposed allocation is for "around 40 new homes" at R25 and for "around 30 new homes" at R26.

5. They say that the proposed allocations R25 and R26 are contrary to both National and Local Policies.

6. In simple terms the Parish Council's and BVHA's case is as follows:
6.1. Brentwood Borough Council has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites.
6.2. Without prejudice to the above contention, if no such sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.
6.3. In any event, there are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.
6.4. Moreover, R25 and R26 are inherently unsuitable developments because of (1) inadequate access, (2) flooding, (3) it will result in disproportionate increase in the housing stock, and, (4) the development would not be sustainable.

7. The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan).

8. Accordingly, the Parish Council and BVHA submit that the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').

Background

9. Blackmore is currently a village of approximately 350 dwellings which are home to 943 people (according to the Electoral Register). The proposal to add "around 70 homes" will add approximately 25% to the existing village housing stock. The proportionate increase to the village population would likely be greater by virtue of the number of current dwellings being occupied by two or less villagers. Outside of the LDP, housing stock is also increasing through normal planning processes both within Brentwood Borough Council and our neighbouring Epping Forest Council which will impact upon Blackmore village.

10. Blackmore is a picturesque village and surrounded by countryside. The Village Green has ponds at its eastern end. There is a village shop including post office, Primary School, two village halls, a sports and social club, tennis courts, football and cricket pitches, and a flood-lit Multi-Use Games Arena. All of these facilities are at capacity use. The village has three pubs: The Prince Albert, The Bull, and The Leather Bottle.
In addition to the Anglican parish Church there is a Baptist Church in the village. However, Blackmore has a very limited bus service and is thus remote. It is over 6 miles from the centre of Brentwood and thus the villagers of Blackmore are reliant on the motor car.

11. The village School is at capacity and local residents are having to send children to neighbouring schools. There is limited scope for expansion. It is socially undesirable for some village children to be able to attend the village school and others to be "shipped out". This social harm (i.e. lack of cohesion) would be exacerbated if more resident village children had to be "shipped out" to another school.

12. In respect of employment opportunities within Blackmore these are limited and, of those of working age nearly all, if not all, commute out of the village. That commute takes place, if not exclusively, almost exclusively by private motor car. Such further evidences that Blackmore is an unsustainable location for new development.

13. Both R25 and R26 are on the Northern Boundary of the village of Blackmore. Both are bordered (to the north) by Redrose Lane, a rare extant example of a "plague detour route". Redrose Lane is narrow and with limited passing space for two motor cars. Vehicles larger than a car (i.e. Transit van and above) cannot pass without one, or the other, stopping (see Appendix One). Development of 70 dwellings would undoubtedly result in a significant number of vehicular movements - in the order of 600 to 700 per day - and, without suitable improvements (which would erode the character of Redrose Lane), cause harm.

14. Both R25 and R26 are in the Green Belt. Both are on land classified as "very good" agricultural land. Both sites have ecological value and, more importantly, local residents have reported sightings of bats, owls and newts at, or in the vicinity of, R25 and R26 (See Appendix Two).

15. Whilst the Environmental Agency classifies both sites within Flood Zone 1, both R25 and R26 have flooded historically - and both have an identified flood risk (see Appendix Three).

16. The BVHA undertook a survey in July 2018 of local residents and visitors to the Village. The BVHA survey confirms that residents are opposed to the proposed allocation of R25 and R26. Of the responses received from village residents, over 300, 98% were strongly opposed to the allocation of sites R25 and R26. It should be noted that the response numbers (over 300 adult residents in the village) was extremely good and evidences the strength of local feeling. It also outlines the engagement of the local Community.

Issues concerning Consultation and Consistency

17. It is a maxim that "good planning is consistent planning".

18. The Current Local Plan (the Brentwood Replacement Local Plan) dates to 2005 and tightly controls development in the Green Belt. Thus, development on R25 and R26 is contrary to the current Local Plan policies absent "very special circumstances".

19. In a 2014 site assessment document, which was and is part of the current emerging local plan process, sites R25 and R26 were discounted as they did not meet the (then) draft Local Plan spatial strategy.

20. It is not clear why this assessment has changed - indeed, the constraints surrounding site R25 and R26 remain unchanged.

21. More recently, in the Council's (Regulation 18) 2016 draft Local Plan, it was stated that "No amendment is proposed to the Green Belt boundaries surrounding larger villages [Blackmore is defined as a larger village] in order to retain the character of the Borough in line with the spatial strategy" (para 5.33). That spatial strategy seeking, insofar as it was necessary to do so, "limited release of Green Belt land for development within transport corridors, in strategic locations to deliver selfsustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries". So even though Brentwood Borough Council had identified a potential need for release of Green Belt land, no suitable land was identified in Blackmore.

22. There has therefore been a significant shift of policy; namely from a position of no development at R25 and R26 to now seeking to allocate these sites for residential development. The Parish Council and BVHA say that the change in position is inconsistent and wrong for reasons more fully set out below.

23. The Parish Council and BVHA also wish to record that the Council's planning Team, represented by a Strategic Director and three other Senior Officers, confirmed at a public meeting on 31 January 2019 that Blackmore's allocation was a result of property developers promoting the development of land on which their companies held options. The Parish Council and BVHA take the view that, not only would the proposed allocation of R25 and R26 appear to be "developer-led" rather than plan led, it shows a lack of thorough and appropriate research, and understanding of the unique character and circumstances of Blackmore. The Parish Council and BVHA further take the view that developer pressure is not a good and sufficient reason for Brentwood Borough Council to abdicate its duty to promote a sound, and consistent, Development Plan.

Evidence Base

24. Paragraph 31 NPPF provides that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence.

25. Part of the evidence is the "Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report - January 2019" ('the SA'). The SA tells us that a number of sustainability 'topics' inform the framework for assessing the sustainability of the site. Flooding is one of those topics (see Table 3.1 of the SA).

26. Risk of flooding is important to any sustainability appraisal not only because the NPPF and emerging policy NE06 seek to direct development away from areas of highest risk of flooding but also because flooding can put lives and property at risk. It is therefore surprising that, for all bar 21 potential sites, the SA does not consider flood risk in assessing sustainability.

27. The Level 1 Strategic Flood Risk Assessment does assess risk however and identifies a medium risk of surface water flooding for Redrose Lane (Table A4b) with Site R26 being potentially vulnerable to climate change and with a 1 in 100 annual probability of surface water flooding (Table A6b). The findings appear at odds with the fact that Sites R25 and R26 are lower than Redrose Lane and thus, one may expect, may be more vulnerable to flooding than higher land (i.e. Redrose Lane). Indeed, these sites have consistently flooded as evidenced by the photographs in Appendix Two.

28. There are, of course, documents supporting housing need. However, there is no evidence of local housing need for Blackmore, or any other villages. Whilst the Parish Council and BVHA accept that there may be some demand for housing any such demand should be properly evidenced with any housing allocation proportionate and ensuring that houses are being built in the right places.

Sustainable Development

29. It is a core planning principle that plans should be prepared with the objective of contributing to the achievement of sustainable development (para 16(a) NPPF). Paragraph 8 NPPF outlines three objectives that the planning system should strive to meet.

30. The proposed allocation of sites R25 and R26 meets none of these objectives in that:
30.1. Economic objective - any contribution arising from the construction of new dwellings will be short-lived. There are no, or extremely limited, employment opportunities within Blackmore and the likelihood of new residents driving a demand for new services within the village would appear, at best, limited. In short, any economic benefits are short-term.
30.2. Social objective - services in Blackmore are limited and the primary school is at capacity sending additional village children to school elsewhere will further erode social cohesion.
30.3. Environmental objective - occupiers of sites R25 and R26 would undoubtedly be reliant on private motor cars. The sites are at risk of flooding (surface water at least) and require the release of high-grade agricultural land in the Green Belt. Redrose Lane is narrow and infrastructure works would be required to make necessary improvements which would harm the character of this area but may also result in the loss of historic hedges and important habitats.

31. There are other sites which are in far more sustainable locations which should be allocated in preference. Indeed, the SA identifies a number of sites (n.b. no scoring for flood risk) with better scores than sites R25 and R26, good examples being in Shenfield, Mountnessing, Pilgrims Hatch, Ingatestone and Brentwood such as, but not limited to, sites 038A, 253, 277B, 297, 218B, 053B, 189, 318, 288B, 153, 280, 024A and 130.

32. Furthermore, development in less sustainable locations, such as R25 and R26, before more sustainable locations, should be avoided.

Green Belt

33. Sites R25 and R26 are in the Green Belt. The Government attaches great importance to Green Belts (per para 133 NPPF). The Green Belt serves five purposes (para 134 NPPF) which includes safeguarding the countryside from encroachment, preserving the character of historic towns and assisting in urban regeneration.

34. The NPPF further confirms that, once established, Green Blt boundaries should only be altered where exceptional circumstances are fully evidenced and justified (para 136 NPPF). Meeting an assessed housing need is not an exceptional circumstance. No other exceptional circumstances are put forward by Brentwood Borough Council.

35. Regardless, the NPPF is clear in that before concluding that exceptional circumstances exist to justify changing Green Belt boundaries Brentwood Borough Council should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified housing need (para 137 NPPF). In this respect the Parish Council and BVHA say:
35.1. There is no evidence that increasing densities elsewhere negates the need for the release of Green Belt land at sites R25 and R26. It should be remembered that the proposed Green Belt release, per Figure 4.2, only 123 of those homes are to be provided in the "larger villages" such as Blackmore which accounts for 1.5% of the total housing need (which includes a 20% buffer). This is a very modest contribution to housing supply which, the Parish Council and BVHA say, could easily be met by considering all other reasonable alternatives.
35.2. There are brownfield sites which should be identified, considered and used in preference.
35.3. There are also urban sites that should be used in preference, or alternatively, sites in more sustainable locations (i.e. close(r) to urban areas).
35.4. The village of Stondon Massey has actively sought new development within its boundaries. The same may be true of other villages within the Borough. Such "localised" development may reduce or negate the need for sites R25 and/or R26.

36. In consequence of the above, the Parish Council and BVHA say that Brentwood Borough Council has not demonstrated that it fully evidenced and justified a need to alter Green Belt boundaries nor that it has examined fully all other reasonable alternatives before doing so.

37. Further to the above, the notes to draft policy SP02 confirm that growth is prioritised "based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas where deemed appropriate" (para 4.22). The inclusion of R25 and R26 runs contrary to this - both being greenfield land in the Green Belt. Whilst SP02 itself talks of the need to direct development to "highly accessible locations" - sites R25 and R26 are in a rural area with poor transport links and limited accessibility. The inclusion of R25 and R26 thus conflicts with policy SP02.

A Settlement Category 3 village?

38. As above the Parish Council and BVHA say that Blackmore should be classed as a Settlement Category 4 village and not the higher Category 3. They say this because:
38.1. There is no local shopping parade but, instead, one Co-Op Store (with Post Office), a hairdressers and a coffee shop;
38.2. It does not have a health facility - the nearest Doctor's surgery is in Doddinghurst (which is ~3 miles away and on roads not suitable for walking); and
38.3. There are no, or very few, local jobs. Of those of working age nearly all commute out of the village.

39. Accordingly, some of the key attributes of a Category 3 settlement are, in Blackmore's case, missing. As a more general point the population of Blackmore is modest and a considerable margin less than that of Doddinghurst and Kelvedon Hatch which are also classified as Category 3 settlements.

40. Further, of the Category 3 settlements it is only Blackmore (sites R25 and R26) and Kelvedon Hatch (sites R23 and R24) that it is proposed to allocate sites for housing/development. Kelvedon Hatch is in the order of 2.5 times larger (by population) than Blackmore - however its proposed housing allocation (total of ~53) is less, by approximately 25%, than that proposed for Blackmore.

41. This is in contrast to the larger Category 3 settlements of Doddinghurst and Ingrave which have no proposed allocation for housing. Indeed, no allocation is proposed for the other Category 3 settlements of Herongate and Mountnessing.

42. Simply put, the Parish Council and BVHA say that the classification of, and proposed
housing allocation in, Blackmore is incorrect.
Other

43. The Parish Council and BVHA support the strategy within the plan. Indeed, in the main they recognise and support the policies within the draft plan. However, they take issue with allocations of sites R25 and R26; not only for the reasons above but when considered against the policy which Brentwood Borough Council are promoting. For example, sites R25 and R26 perform poorly against, or conflict with, draft policies SP01, SP02, SP03, NE01, NE09, BE12, BE13 and BE45. This is not withstanding the case that, in applying the NPPF, the Parish Council and BVHA say that development should be directed elsewhere in preference to sites R25 an R26.

44. The Parish Council and BVHA also take issue with the fact that of the 123 net homes allocated for "larger villages" 70, or approximately 56% of the total allocation, are met by these two sites. Thus, a disproportionately large amount of the allocation is from sites R25 and R26.

45. The above is notwithstanding the Parish Council and BVHA's primary contention that sites R25 and R26, but possibly all proposed sites on Green Belt Land in larger villages (i.e. settlement category 3), can and should be removed from the Plan.

46. The evidence of working with adjoining planning authorities is limited with a general statement that "adjacent planning authorities [have] confirmed that they [are] unwilling and unable to take any of the Brentwood identified housing need". The Parish Council and BVHA invite Brentwood Borough Council to more fully disclose the extent and nature of discussions that have been held with neighbouring authorities.

Summary/Conclusion

47. The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.

48. Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.

49. Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.

50. Sites R25 and R26 are in an unsustainable location served by a constrained access (Redrose Lane) and with an identified risk of flooding. The development of R25 and R26 does not represent sustainable development.

51. The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.

52. There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. Regardless, the proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).

53. The plan is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.

54. The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.

55. Brentwood Borough Council should amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

HOLMES & HILLS LLP
Dated 18 March 2019
 
Appendix One - Redrose Lane PHOTOS

Redrose Lane from Chelmsford Road junction Redrose Lane from Nine Ashes
Road junction
Further image of Redrose Lane - note Above: image illustrating width (or lack
cut-up verges and lack of centre lines of) of Redrose Lane
(i.e. delineating insufficient width for two
vehicles to pass)

Appendix Two - re R25 and R26 as Important Habitat sites PLUS PHOTOS


Blackmore Wildlife
The wildlife listed below has all been observed in the fields by Woollard Way and Orchard
Piece and these fields provide invaluable nesting and foraging grounds.
Birds:
Redpoll, Yellowhammer, Skylarks, Barn Owls, Little Owls, Buzzard, Red Kite,
Sparrowhawk, Song Thrush, Red-legged Partridges, Kestrels, Turtle Doves, Hedge
sparrow, Siskin.
In particular Barn Owls and their nesting sites are protected by law during the breeding
season - https://www.bto.org/volunteer-surveys/ringing/taking-part/protected-birds/s1-
list
Turtle doves, Skylarks and Yellow Hammers are on the RSPB's red list which means,
amongst other things, that the species is globally threatened and are the highest priority
for conservation - https://www.rspb.org.uk/birds-and-wildlife/wildlife-guides/ukconservation-
status-explained/
Above: Owl on Site R25/R26 Above: Sparrowhawk in adjacent
garden
Turtle Dove - video:
IMG_8370 turtle
dove.MOV
Reptiles:
Grass Snakes and Great Crested Newts which are a protected species -
https://www.wildlifetrusts.org/wildlife-explorer/amphibians/great-crested-newt
Above (both): Great Crested Newt in "composting bin" in neighbouring garden to R26
Bats:
All bats are protected by the law in the UK - https://www.bats.org.uk/advice/bats-andthe-
law
They are frequently seen flying around the fields (i.e. R25 and R26) and there is possible
nesting in the outbuildings.
Bats - video:
https://drive.google.com/file/d/15Be5ZUlvRwEDhh_ivlLf1fxb0Rf2QS3z/view


Appendix Three - Agricultural Land Assessment and Flooding/Flood Risk

Map extract - ECC
Flood risk map 2018 (source - Essex County Council website - "check if you are
at risk of flooding" - with annotations)

Above: Chelmsford Road flooding- 1987 Above: Redrose Lane flooding - 1987

Above: Flooding on The Green - 2016 Above: Flooding on Redrose
Lane - 2016 (note depth of water)


Above: Chelmsford Road flooding - Above: Redrose Lane flooding -
23 June 2016 (n.b. next to site R26) 23 June 2016

Above: Redrose Lane - March 2018

Extract from Daily Telegraph re 2011 Flooding:

Extract from Express re 2011 Flooding:

A woman is rescued from her car stuck in floodwater in Blackmore,
Essex, yesterday newspaper article inc photo
Express - 18 Jan 2011
Fire Service in Redrose Lane east bound to Chelmsford Road. (see picture below)
Extract from Romford Recorder re 2011 flooding: including an incident where a person had to be rescued from their car in Red Rose Lane, Blackmore.

Amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

BRENTWOOD LOCAL PLAN
REGULATION 19 CONSULATION REPONSE
ON BEHALF OF
BLACKMORE, HOOK END & WYATTS GREEN PARISH COUNCIL
BLACKMORE VILLAGE HERITAGE ASSOCIATION

1. This joint representation is made on behalf of:
1.1. The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2. The Blackmore Village Heritage Association ('BVHA')

Introduction
2. The Parish Council is a statutory consultee and represents 350 households in Blackmore village (population of only 943) included in a total population of 2,561 within the wider Parish with its three distinct separate settlements. This figure does not include the many households in neighbouring villages who rely on Blackmore's facilities.

3. BVHA is an unincorporated, not for profit, organisation and has in excess of 150 active members but its newsletters are distributed to over 1,000 households.

4. Both the Parish Council and BVHA strongly oppose the proposed allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land north of Orchard Piece, Blackmore) for housing development. The proposed allocation is for "around 40 new homes" at R25 and for "around 30 new homes" at R26.

5. They say that the proposed allocations R25 and R26 are contrary to both National and Local Policies.

6. In simple terms the Parish Council's and BVHA's case is as follows:
6.1. Brentwood Borough Council has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites.
6.2. Without prejudice to the above contention, if no such sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.
6.3. In any event, there are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.
6.4. Moreover, R25 and R26 are inherently unsuitable developments because of (1) inadequate access, (2) flooding, (3) it will result in disproportionate increase in the housing stock, and, (4) the development would not be sustainable.

7. The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan).

8. Accordingly, the Parish Council and BVHA submit that the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').

Background

9. Blackmore is currently a village of approximately 350 dwellings which are home to 943 people (according to the Electoral Register). The proposal to add "around 70 homes" will add approximately 25% to the existing village housing stock. The proportionate increase to the village population would likely be greater by virtue of the number of current dwellings being occupied by two or less villagers. Outside of the LDP, housing stock is also increasing through normal planning processes both within Brentwood Borough Council and our neighbouring Epping Forest Council which will impact upon Blackmore village.

10. Blackmore is a picturesque village and surrounded by countryside. The Village Green has ponds at its eastern end. There is a village shop including post office, Primary School, two village halls, a sports and social club, tennis courts, football and cricket pitches, and a flood-lit Multi-Use Games Arena. All of these facilities are at capacity use. The village has three pubs: The Prince Albert, The Bull, and The Leather Bottle.
In addition to the Anglican parish Church there is a Baptist Church in the village. However, Blackmore has a very limited bus service and is thus remote. It is over 6 miles from the centre of Brentwood and thus the villagers of Blackmore are reliant on the motor car.

11. The village School is at capacity and local residents are having to send children to neighbouring schools. There is limited scope for expansion. It is socially undesirable for some village children to be able to attend the village school and others to be "shipped out". This social harm (i.e. lack of cohesion) would be exacerbated if more resident village children had to be "shipped out" to another school.

12. In respect of employment opportunities within Blackmore these are limited and, of those of working age nearly all, if not all, commute out of the village. That commute takes place, if not exclusively, almost exclusively by private motor car. Such further evidences that Blackmore is an unsustainable location for new development.

13. Both R25 and R26 are on the Northern Boundary of the village of Blackmore. Both are bordered (to the north) by Redrose Lane, a rare extant example of a "plague detour route". Redrose Lane is narrow and with limited passing space for two motor cars. Vehicles larger than a car (i.e. Transit van and above) cannot pass without one, or the other, stopping (see Appendix One). Development of 70 dwellings would undoubtedly result in a significant number of vehicular movements - in the order of 600 to 700 per day - and, without suitable improvements (which would erode the character of Redrose Lane), cause harm.

14. Both R25 and R26 are in the Green Belt. Both are on land classified as "very good" agricultural land. Both sites have ecological value and, more importantly, local residents have reported sightings of bats, owls and newts at, or in the vicinity of, R25 and R26 (See Appendix Two).

15. Whilst the Environmental Agency classifies both sites within Flood Zone 1, both R25 and R26 have flooded historically - and both have an identified flood risk (see Appendix Three).

16. The BVHA undertook a survey in July 2018 of local residents and visitors to the Village. The BVHA survey confirms that residents are opposed to the proposed allocation of R25 and R26. Of the responses received from village residents, over 300, 98% were strongly opposed to the allocation of sites R25 and R26. It should be noted that the response numbers (over 300 adult residents in the village) was extremely good and evidences the strength of local feeling. It also outlines the engagement of the local Community.

Issues concerning Consultation and Consistency

17. It is a maxim that "good planning is consistent planning".

18. The Current Local Plan (the Brentwood Replacement Local Plan) dates to 2005 and tightly controls development in the Green Belt. Thus, development on R25 and R26 is contrary to the current Local Plan policies absent "very special circumstances".

19. In a 2014 site assessment document, which was and is part of the current emerging local plan process, sites R25 and R26 were discounted as they did not meet the (then) draft Local Plan spatial strategy.

20. It is not clear why this assessment has changed - indeed, the constraints surrounding site R25 and R26 remain unchanged.

21. More recently, in the Council's (Regulation 18) 2016 draft Local Plan, it was stated that "No amendment is proposed to the Green Belt boundaries surrounding larger villages [Blackmore is defined as a larger village] in order to retain the character of the Borough in line with the spatial strategy" (para 5.33). That spatial strategy seeking, insofar as it was necessary to do so, "limited release of Green Belt land for development within transport corridors, in strategic locations to deliver selfsustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries". So even though Brentwood Borough Council had identified a potential need for release of Green Belt land, no suitable land was identified in Blackmore.

22. There has therefore been a significant shift of policy; namely from a position of no development at R25 and R26 to now seeking to allocate these sites for residential development. The Parish Council and BVHA say that the change in position is inconsistent and wrong for reasons more fully set out below.

23. The Parish Council and BVHA also wish to record that the Council's planning Team, represented by a Strategic Director and three other Senior Officers, confirmed at a public meeting on 31 January 2019 that Blackmore's allocation was a result of property developers promoting the development of land on which their companies held options. The Parish Council and BVHA take the view that, not only would the proposed allocation of R25 and R26 appear to be "developer-led" rather than plan led, it shows a lack of thorough and appropriate research, and understanding of the unique character and circumstances of Blackmore. The Parish Council and BVHA further take the view that developer pressure is not a good and sufficient reason for Brentwood Borough Council to abdicate its duty to promote a sound, and consistent, Development Plan.

Evidence Base

24. Paragraph 31 NPPF provides that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence.

25. Part of the evidence is the "Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report - January 2019" ('the SA'). The SA tells us that a number of sustainability 'topics' inform the framework for assessing the sustainability of the site. Flooding is one of those topics (see Table 3.1 of the SA).

26. Risk of flooding is important to any sustainability appraisal not only because the NPPF and emerging policy NE06 seek to direct development away from areas of highest risk of flooding but also because flooding can put lives and property at risk. It is therefore surprising that, for all bar 21 potential sites, the SA does not consider flood risk in assessing sustainability.

27. The Level 1 Strategic Flood Risk Assessment does assess risk however and identifies a medium risk of surface water flooding for Redrose Lane (Table A4b) with Site R26 being potentially vulnerable to climate change and with a 1 in 100 annual probability of surface water flooding (Table A6b). The findings appear at odds with the fact that Sites R25 and R26 are lower than Redrose Lane and thus, one may expect, may be more vulnerable to flooding than higher land (i.e. Redrose Lane). Indeed, these sites have consistently flooded as evidenced by the photographs in Appendix Two.

28. There are, of course, documents supporting housing need. However, there is no evidence of local housing need for Blackmore, or any other villages. Whilst the Parish Council and BVHA accept that there may be some demand for housing any such demand should be properly evidenced with any housing allocation proportionate and ensuring that houses are being built in the right places.

Sustainable Development

29. It is a core planning principle that plans should be prepared with the objective of contributing to the achievement of sustainable development (para 16(a) NPPF). Paragraph 8 NPPF outlines three objectives that the planning system should strive to meet.

30. The proposed allocation of sites R25 and R26 meets none of these objectives in that:
30.1. Economic objective - any contribution arising from the construction of new dwellings will be short-lived. There are no, or extremely limited, employment opportunities within Blackmore and the likelihood of new residents driving a demand for new services within the village would appear, at best, limited. In short, any economic benefits are short-term.
30.2. Social objective - services in Blackmore are limited and the primary school is at capacity sending additional village children to school elsewhere will further erode social cohesion.
30.3. Environmental objective - occupiers of sites R25 and R26 would undoubtedly be reliant on private motor cars. The sites are at risk of flooding (surface water at least) and require the release of high-grade agricultural land in the Green Belt. Redrose Lane is narrow and infrastructure works would be required to make necessary improvements which would harm the character of this area but may also result in the loss of historic hedges and important habitats.

31. There are other sites which are in far more sustainable locations which should be allocated in preference. Indeed, the SA identifies a number of sites (n.b. no scoring for flood risk) with better scores than sites R25 and R26, good examples being in Shenfield, Mountnessing, Pilgrims Hatch, Ingatestone and Brentwood such as, but not limited to, sites 038A, 253, 277B, 297, 218B, 053B, 189, 318, 288B, 153, 280, 024A and 130.

32. Furthermore, development in less sustainable locations, such as R25 and R26, before more sustainable locations, should be avoided.

Green Belt

33. Sites R25 and R26 are in the Green Belt. The Government attaches great importance to Green Belts (per para 133 NPPF). The Green Belt serves five purposes (para 134 NPPF) which includes safeguarding the countryside from encroachment, preserving the character of historic towns and assisting in urban regeneration.

34. The NPPF further confirms that, once established, Green Blt boundaries should only be altered where exceptional circumstances are fully evidenced and justified (para 136 NPPF). Meeting an assessed housing need is not an exceptional circumstance. No other exceptional circumstances are put forward by Brentwood Borough Council.

35. Regardless, the NPPF is clear in that before concluding that exceptional circumstances exist to justify changing Green Belt boundaries Brentwood Borough Council should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified housing need (para 137 NPPF). In this respect the Parish Council and BVHA say:
35.1. There is no evidence that increasing densities elsewhere negates the need for the release of Green Belt land at sites R25 and R26. It should be remembered that the proposed Green Belt release, per Figure 4.2, only 123 of those homes are to be provided in the "larger villages" such as Blackmore which accounts for 1.5% of the total housing need (which includes a 20% buffer). This is a very modest contribution to housing supply which, the Parish Council and BVHA say, could easily be met by considering all other reasonable alternatives.
35.2. There are brownfield sites which should be identified, considered and used in preference.
35.3. There are also urban sites that should be used in preference, or alternatively, sites in more sustainable locations (i.e. close(r) to urban areas).
35.4. The village of Stondon Massey has actively sought new development within its boundaries. The same may be true of other villages within the Borough. Such "localised" development may reduce or negate the need for sites R25 and/or R26.

36. In consequence of the above, the Parish Council and BVHA say that Brentwood Borough Council has not demonstrated that it fully evidenced and justified a need to alter Green Belt boundaries nor that it has examined fully all other reasonable alternatives before doing so.

37. Further to the above, the notes to draft policy SP02 confirm that growth is prioritised "based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas where deemed appropriate" (para 4.22). The inclusion of R25 and R26 runs contrary to this - both being greenfield land in the Green Belt. Whilst SP02 itself talks of the need to direct development to "highly accessible locations" - sites R25 and R26 are in a rural area with poor transport links and limited accessibility. The inclusion of R25 and R26 thus conflicts with policy SP02.

A Settlement Category 3 village?

38. As above the Parish Council and BVHA say that Blackmore should be classed as a Settlement Category 4 village and not the higher Category 3. They say this because:
38.1. There is no local shopping parade but, instead, one Co-Op Store (with Post Office), a hairdressers and a coffee shop;
38.2. It does not have a health facility - the nearest Doctor's surgery is in Doddinghurst (which is ~3 miles away and on roads not suitable for walking); and
38.3. There are no, or very few, local jobs. Of those of working age nearly all commute out of the village.

39. Accordingly, some of the key attributes of a Category 3 settlement are, in Blackmore's case, missing. As a more general point the population of Blackmore is modest and a considerable margin less than that of Doddinghurst and Kelvedon Hatch which are also classified as Category 3 settlements.

40. Further, of the Category 3 settlements it is only Blackmore (sites R25 and R26) and Kelvedon Hatch (sites R23 and R24) that it is proposed to allocate sites for housing/development. Kelvedon Hatch is in the order of 2.5 times larger (by population) than Blackmore - however its proposed housing allocation (total of ~53) is less, by approximately 25%, than that proposed for Blackmore.

41. This is in contrast to the larger Category 3 settlements of Doddinghurst and Ingrave which have no proposed allocation for housing. Indeed, no allocation is proposed for the other Category 3 settlements of Herongate and Mountnessing.

42. Simply put, the Parish Council and BVHA say that the classification of, and proposed
housing allocation in, Blackmore is incorrect.
Other

43. The Parish Council and BVHA support the strategy within the plan. Indeed, in the main they recognise and support the policies within the draft plan. However, they take issue with allocations of sites R25 and R26; not only for the reasons above but when considered against the policy which Brentwood Borough Council are promoting. For example, sites R25 and R26 perform poorly against, or conflict with, draft policies SP01, SP02, SP03, NE01, NE09, BE12, BE13 and BE45. This is not withstanding the case that, in applying the NPPF, the Parish Council and BVHA say that development should be directed elsewhere in preference to sites R25 an R26.

44. The Parish Council and BVHA also take issue with the fact that of the 123 net homes allocated for "larger villages" 70, or approximately 56% of the total allocation, are met by these two sites. Thus, a disproportionately large amount of the allocation is from sites R25 and R26.

45. The above is notwithstanding the Parish Council and BVHA's primary contention that sites R25 and R26, but possibly all proposed sites on Green Belt Land in larger villages (i.e. settlement category 3), can and should be removed from the Plan.

46. The evidence of working with adjoining planning authorities is limited with a general statement that "adjacent planning authorities [have] confirmed that they [are] unwilling and unable to take any of the Brentwood identified housing need". The Parish Council and BVHA invite Brentwood Borough Council to more fully disclose the extent and nature of discussions that have been held with neighbouring authorities.

Summary/Conclusion

47. The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.

48. Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.

49. Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.

50. Sites R25 and R26 are in an unsustainable location served by a constrained access (Redrose Lane) and with an identified risk of flooding. The development of R25 and R26 does not represent sustainable development.

51. The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.

52. There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. Regardless, the proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).

53. The plan is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.

54. The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.

55. Brentwood Borough Council should amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

HOLMES & HILLS LLP
Dated 18 March 2019
 
Appendix One - Redrose Lane PHOTOS

Redrose Lane from Chelmsford Road junction Redrose Lane from Nine Ashes
Road junction
Further image of Redrose Lane - note Above: image illustrating width (or lack
cut-up verges and lack of centre lines of) of Redrose Lane
(i.e. delineating insufficient width for two
vehicles to pass)

Appendix Two - re R25 and R26 as Important Habitat sites PLUS PHOTOS


Blackmore Wildlife
The wildlife listed below has all been observed in the fields by Woollard Way and Orchard
Piece and these fields provide invaluable nesting and foraging grounds.
Birds:
Redpoll, Yellowhammer, Skylarks, Barn Owls, Little Owls, Buzzard, Red Kite,
Sparrowhawk, Song Thrush, Red-legged Partridges, Kestrels, Turtle Doves, Hedge
sparrow, Siskin.
In particular Barn Owls and their nesting sites are protected by law during the breeding
season - https://www.bto.org/volunteer-surveys/ringing/taking-part/protected-birds/s1-
list
Turtle doves, Skylarks and Yellow Hammers are on the RSPB's red list which means,
amongst other things, that the species is globally threatened and are the highest priority
for conservation - https://www.rspb.org.uk/birds-and-wildlife/wildlife-guides/ukconservation-
status-explained/
Above: Owl on Site R25/R26 Above: Sparrowhawk in adjacent
garden
Turtle Dove - video:
IMG_8370 turtle
dove.MOV
Reptiles:
Grass Snakes and Great Crested Newts which are a protected species -
https://www.wildlifetrusts.org/wildlife-explorer/amphibians/great-crested-newt
Above (both): Great Crested Newt in "composting bin" in neighbouring garden to R26
Bats:
All bats are protected by the law in the UK - https://www.bats.org.uk/advice/bats-andthe-
law
They are frequently seen flying around the fields (i.e. R25 and R26) and there is possible
nesting in the outbuildings.
Bats - video:
https://drive.google.com/file/d/15Be5ZUlvRwEDhh_ivlLf1fxb0Rf2QS3z/view


Appendix Three - Agricultural Land Assessment and Flooding/Flood Risk

Map extract - ECC
Flood risk map 2018 (source - Essex County Council website - "check if you are
at risk of flooding" - with annotations)

Above: Chelmsford Road flooding- 1987 Above: Redrose Lane flooding - 1987

Above: Flooding on The Green - 2016 Above: Flooding on Redrose
Lane - 2016 (note depth of water)


Above: Chelmsford Road flooding - Above: Redrose Lane flooding -
23 June 2016 (n.b. next to site R26) 23 June 2016

Above: Redrose Lane - March 2018

Extract from Daily Telegraph re 2011 Flooding:

Extract from Express re 2011 Flooding:

A woman is rescued from her car stuck in floodwater in Blackmore,
Essex, yesterday newspaper article inc photo
Express - 18 Jan 2011
Fire Service in Redrose Lane east bound to Chelmsford Road. (see picture below)
Extract from Romford Recorder re 2011 flooding: including an incident where a person had to be rescued from their car in Red Rose Lane, Blackmore.

Please refer to Blackmore Village Heritage Association Neighbourhood Plan.

You say you want to build 70 new homes on the Green Belt land, but it won't end there because 70 new homes will possibly end up with 280 people (4 people per household) plus at least 200 cars (or more).
Infrastructure will not be able to cope with this amount. Schools, hospitals, doctors, traffic and litter and at the end of the day we have lost our Green Belt. This is the thin end of the wedge because it will not end here. Blackmore will end up the same as Billericay, a sprawl of estates.
Proposed modifications:
Please refer to Blackmore Village Heritage Association Neighbourhood Plan.

Please refer to Blackmore Village Heritage Association Neighbourhood Plan.

The history of Blackmore many years ago was known as the black swamp and was a very wet area. This is why it is not a large village due to flood risk. Most of the land is given over to Green Belt because of this reason. There are many brown sites which could be used without flood risk.
Proposed modifications:
Please refer to Blackmore Village Heritage Association Neighbourhood Plan.

Site that need removing from the LDP as follows: R26 and R25.

Managing Growth and disproportionate allocation. Village isn't large enough to accommodate the new houses. The school is at capacity, there is an issue with parking around the village especially when busy during school term time and when events are on in the village. Growing on Green Belt now is this allowed? Brings the landscape down.
We haven't been spoken to on the building of land in the village. i.e. if we want to build on our own property we have to apply? Same should happen vice versa (consultancy work) speaking to the local villagers and find out what needs improving before adding more housing into a village that is already struggling with capacity of residents/visitors.
There are plenty of places that are screaming for new housing. I am looking to buy a property but the village isn't affordable and that's what makes it lovely place to live!
Ruining the area adding more housing has a knock on effect to all local/government services! x amount of house x amount of schools needed, doctors, hospitals, teachers etc. Things you hear we struggle with already and the village doesn't have any these apart from school and therefore would more building work be needed?
The village has small narrow roads not equipped for builders/machinery and that ilk.
Proposed modifications:
Site that need removing from the LDP as follows: R26 and R25.

remove R25 and R26 from plan

Refer to attached scans

Has considered local opinion to an extent but requires further local consultation with residents.

Refer to attached scanned form.
Agree with development of West Horndon Industrial Estate, concerned about congestion from development to the north of Brentwood and Pilgrims Hatch. Sawyers Hall Lane development would result in loss of greenery and increase in local pollution. Noticed Ingrave isn't marked as a location for improvement or partial urbanisation. In the SA , Figure 5.8 as an option would reduce parking.
In the town centre, Sainsbury's parking is already full and costs money to park. Table 6.1 in the SA [Sustainability Appraisal] notes Brentwood ranks low with "significant effects". Urbanisation in these areas could further effect the biodiversity and quality if further traffic is added> This relates back to 024 Sawyers Hall Lane. The railway station in Brentwood being made into homes would mean people could park and would be able to counter productive to an increase in housing and local traffic.
I feel a reduction in car parking would be a detriment to Brentwood community in come and ability for Brentwood to be a high street to visit since there is already limited parking.
Even if 9.4.9 'other modes of transport' [Sustainability Appraisal] mean increasing local pots for the council as money making. I feel that older people cannot always rely on public transport. My experience is that it is slow and unreliable.
The Ingatestone urbanisation took several years. My concern that disruption closer to Brentwood could cause delays to local traffic.
I would prefer to pay for parking. This would enable me and my older family to retain independence around the neighbourhood rather than worrying about catching the bus.

Remove Blackmore from this list of proposed sites

BBC has not shown alternative brownfield sites that are available-they should be used before Green belt land. The access would be impossible with that amount of traffic. We do not have the infrastructure to take this amount of development. We already have waiting lists for appointments to see local doctors. The parking is already a problem. Surely Epping Forest Council would have more sites available than a tiny village like Blackmore. We need to preserve our small village and green belt.

Consultation is required with neighboring authorities and the local community. An assessment of local need for housing is required. A survey of traffic impact on the surrounding area is required. There is already a development of 30 houses just outside the village that will impact the traffic flow. Detailed flood risk analysis required. Assess possibility of smaller scale brownfield developments within the area to cater for local need if any is proven. Larger developments like this should be placed nearer the transport hubs (Brentwood, Dunton, etc.)and nearer to possible employment opportunities. Develop a strategic approach to the Villages north of Brentwood by consultation.

The LDP is unsound as it does not meet the test of Soundness as detailed on your form. There is no proven local need nor accessibility to local services. The local community has not been consulted on the LDP. A survey by a local group has been completely ignored by the Council. The Green Belt should be protected and although other sites that were looked at in the Allocation have been 'discounted for Green Belt impact' this appears to have been ignored in Blackmore. There is a need to minimize travel under the NPPF. Building 70 houses in a small rural village miles from train stations and other transport hubs is not compliant. The local flooding in the recent past has been ignored. There is a need to 'Conserve historic environment'. The centre of the village is a conservation area. R25 and R26 have two Grade 2 listed buildings on the boundary of the development. The character of Red Rose Lane an historic plague road around the village will be completely destroyed by the development

Sites R25 and R26 should be removed from the plan. Please refer to the BHVA neighbourhood plan. Remove Blackmore from the proposed sites.

Refer to attached scan - Objection to sections 04 08 and 09

To remove Blackmore from this list of proposed sites

UNSOUND: Brownfield sites should be chosen before green belt. The flooding of a few years ago has improved , development would cause more problems. Blackmore school would be unable to cope with this amount of development. Waiting times for appointments to see local doctors would be prolonged.

To remove Blackmore from this list of proposed sites

UNSOUND: Brownfield sites should be chosen before green belt. The flooding of a few years ago has improved , development would cause more problems. Blackmore school would be unable to cope with this amount of development. Waiting times for appointments to see local doctors would be prolonged

In view of my comments on how this would impact on the character of the village, I cannot see how any modifications could be made to the local plan that could rectify the whole situation. [Remove R25 and R26 from plan].

Refer to scanned form for details.
Summary
Object specifically to Section 04: Policy SP02; SP02
Section 08 Policy NE06; NE13
Section 09 Policy R25; R26
BBC has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites. The inclusion of sites R25 and R26 is not sound and cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.

The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.

If no previously developed land sites or urban areas or increase in densities on other proposed sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.

There are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because of inadequate access and narrowness of Red Rose Lane.


Sites R25 and R26 are inherently unsuitable and unsustainable developments because loss of "very good" agricultural land, of loss of biodiversity.

Sites R25 and R26 are inherently unsuitable and unsupported by relevant and up to date evidence base. Evidence regarding flooding shows the sites to be unsuitable.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because they don't fulfil the three sustainability objectives: economic, social or environmental. There is only limed employment in Blackmore so benefits would be limited and short term. Service are limited in the Village and children are being sent elsewhere for education. There is a reliance on the car, the sites are at risk of flooding, require the release of high grade agricultural land in the Green Belt. The access road is narrow and infrastructure works would harm the character of the area and loss of historic hedges and habitat. Other more sustainable locations should be allocated in preference - refer to SA. Nos: 038A,253, 277B, 297, 218B 053B, 189, 318, 288B, 153, 280, 024A and 130.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because it will result in disproportionate increase in the housing stock
Infrastructure and facilities within the village are already at capacity. (Shop, primary school, two village halls, a sports and social club, tennis courts, football and cricket pitches, a flood-lit Multi-Use Games Arena. Three pubs, Anglian Church, Baptist Church). There is a very limited bus service and s thus remote. It is over 6 miles to Brentwood and so residents are reliant on the car. There is social harm from some children being shipped out to other schools. There is only limited employment


Settlement hierarchy (heading before 2.8)
The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan). Therefore the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').

The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.

Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.


Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.


The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.

There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. The proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).



Change:
Amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.

In view of my comments on how this would impact on the character of the village, I cannot see how any modifications could be made to the local plan that could rectify the whole situation. [Remove R25 and R26 from plan].

In view of my comments on how this would impact on the character of the village, I cannot see how any modifications could be made to the local plan that could rectify the whole situation. [Remove R25 and R26 from plan].

refer to attached scan of submission.
Summary
BBC has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites. The inclusion of sites R25 and R26 is not sound and cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.

The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.

If no previously developed land sites or urban areas or increase in densities on other proposed sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.

There are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because of inadequate access and narrowness of Red Rose Lane.


Sites R25 and R26 are inherently unsuitable and unsustainable developments because loss of "very good" agricultural land, of loss of biodiversity.

Sites R25 and R26 are inherently unsuitable and unsupported by relevant and up to date evidence base. Evidence regarding flooding shows the sites to be unsuitable.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because they don't fulfil the three sustainability objectives: economic, social or environmental. There is only limed employment in Blackmore so benefits would be limited and short term. Service are limited in the Village and children are being sent elsewhere for education. There is a reliance on the car, the sites are at risk of flooding, require the release of high grade agricultural land in the Green Belt. The access road is narrow and infrastructure works would harm the character of the area and loss of historic hedges and habitat. Other more sustainable locations should be allocated in preference - refer to SA. Nos: 038A,253, 277B, 297, 218B 053B, 189, 318, 288B, 153, 280, 024A and 130.

Sites R25 and R26 are inherently unsuitable and unsustainable developments because it will result in disproportionate increase in the housing stock
Infrastructure and facilities within the village are already at capacity. (Shop, primary school, two village halls, a sports and social club, tennis courts, football and cricket pitches, a flood-lit Multi-Use Games Arena. Three pubs, Anglian Church, Baptist Church). There is a very limited bus service and s thus remote. It is over 6 miles to Brentwood and so residents are reliant on the car. There is social harm from some children being shipped out to other schools. There is only limited employment


Settlement hierarchy (heading before 2.8)
The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan). Therefore the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').

The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.

Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.


Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.


The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.

There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. The proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).
Red Rose Lane is signposted unsuitable for HGV traffic and Fingrith Hall Lane is too narrow. The choice of these sites seems random and unjustified.
In view of my comments on how this would impact on the character of the village, I cannot see how any modifications could be made to the local plan that could rectify the whole situation. [Remove R25 and R26 from plan].

The Blackmore Sites should be removed from the Local Plan until there has been:
(1) A full housing need survey for Blackmore
(2) A proper consultation, including the 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 04: (Managing Growth)
Policy SP01 - D (a) and D (f)
Para 4.9
Para 4.2
Policy SP02

Section 09: (Site Allocation)
Policy R25,-9:"197: 9,200
Policy R26, 9.201 - 9.205
Section 08: (Natural Environment)

Policy NE06, 8.5 - 8.64
Para 8.85 (iv)
Para 8.90
Para 8.101
Policy NE13

The Plan ls 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 villages.
* 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 ef 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 should be removed from the Local Plan until there has been:
(1) A full housing need survey for Blackmore
(2) A proper consultation, including the 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

To remove Blackmore from this list of proposed sites

UNSOUND: Brownfield sites should be chosen before green belt. The flooding of a few years ago has improved , development would cause more problems. Blackmore school would be unable to cope with this amount of development. Waiting times for appointments to see local doctors would be prolonged

To remove Blackmore from this list of proposed sites

UNSOUND: Brownfield sites should be chosen before green belt. The flooding of a few years ago has improved , development would cause more problems. Blackmore school would be unable to cope with this amount of development. Waiting times for appointments to see local doctors would be prolonged