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

Remove the Blackmore travellers site from the plan

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

LDP Fig 2.3 Settlement hierarchy
LDP Section 04 (management growth)
Policies:
SP01 - D
Paras 4.6 4.9 4.20
Policy SP02
Policy SP04 - A
LDP Section 06 (housing provision)
Policy HP 08
Section 08
Natural Environment
Policy NE 06 paras 8.51 -8.64; Para 8.85 (IV); Para 8.90; Para 8.101
Policy NE13
Section 09 site allocation
Policy R25 para 9.197 -9.200
Policy R26 paras 9.201 - 9.204
LPP Fig 2.3 settlement hierarchy. There are errors in the plan, population states 829 but does not include houses past Red Rose Lane or the residents in Chelmsford Road and Traveller site.
Duty to cooperate. Not enough consultation with neighbouring authorities.
Red Rose Lane is single track and wont cope with more traffic
Flood Risk
Policy NE06 Flood Risk 8.52
Infrastructure requirements - no infrastructure improvements have been listed in R25 or R25. The local school is at capacity with no room for more children.
The doctors is too at capacity, waiting times are bad already.
Electricity and services wont be able to cope with 70 extra houses.

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

Section 4
Policy SP01
Policy SP02
Policy SP03

Section 07
Policy PC 14

Section 08
Policy NE06
Policy NE13

Section 09
Policy R25
Policy R26


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

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

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

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.

Remove sites R25 and R26 from the Plan. Blackmore Village Heritage Association(BVHA) has produced a 'neighbourhood plan' which should be referred to by the Planners. This clearly sets out our local housing needs for our already sustainable community.

See attached.

Remove sites R25 and R26 from the Plan. Blackmore Village Heritage Association(BVHA) has produced a 'neighbourhood plan' which should be referred to by the Planners. This clearly sets out our local housing needs for our already sustainable community.

See attached.

Remove R25 & R26. Refer to BVHA Neighbourhood Plan.

See attached.

Sites R25 and R26 should be removed. Planners should refer to the BVHA 'neighbourhood plan'. This clearly sets out our local housing needs, and would avoid further development in the Blackmore area which is an already sustainable community.

See attached.

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

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

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

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

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

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

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

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

Question 5 - bullets 1-3 * Due to the significant issues surrounding the acceptance of Reg 18 by BBC I think it would be necessary to independently reconsider the entire process to ensure that it was handled appropriately, and if not, repeat the process correctly before proceeding to Reg 19. Other bullets * New officials who understand the local issues and can make their voices heard with independence, in an environment that is willing to listen would be a prerequisite to getting any issues of this magnitude considered in a fair and democratic fashion. * Removing Blackmore from the List of Sites as previously promised or allocating the 70 houses to Dunton Hills, as already done for other sites.

General Comment relating to my response overall: My opinions are based primarily on my detailed knowledge of my local area of the LDP. This indicates it is Unsound and has not complied with the duty to cooperate. If it is flawed in one area, across this many criteria, it will in all probability suffer from the same flaws throughout when subjected to appropriate scrutiny. 1) The LDP has changed from original plan to that considered at Reg 18, with no explanation of why some sites have been included after initially being promised they will be excluded eg Blackmore and some eminently suitable sites have disappeared eg Honeypot Lane. 2) The late changes to the plan curtailed the amount of time available to appropriately consider and challenge it. 3) When Reg 18 was debated in the BBC chamber, some items were included without any prior warning or debate eg Formal inclusion of Traveler Site Status in Chelmsford Road, and some major concerns and proposals were totally and deliberately avoided eg using a guillotine motion to stop any Blackmore concerns being raised. 4) The original LDP was full of reference to quality of life, maintaining sustainable communities, improving residents' existence via the LDP, and working for the people was a recurring theme. This have disappeared from the latest version and it is now about meeting the target number of dwellings to be built to meet government quotas, and wanting residents input in a fashion that requires specialist knowledge. 5) The way that this form and the background information has been constructed is so complex and confusing for anyone not a professional planner, it has stopped a large number of ordinary residents from responding even though they have major issues. Some have even suggested that BBC did this deliberately to avoid too many people voicing their concerns. 6) Apart from at Dunton Hills there has been no creation of a coordinated strategy for any of the medium sized sites, nor for multiple linked sites that, when considered together, require a strategy. 7) There has been insufficient, if any, coordination with neighboring Councils and this leads to developments agreed by one council adversely affecting communities in another councils area. Eg Epping Forest & Brentwood. 8) There has been no evidence of Private developments (not included in the LDP) being considered to ensure the aggregation of LDP, Other Council Developments, and Private developments do not combine to cause increased problems or overwhelm and swamp any thriving communities. 9) There is no evidence that any C.I.L. required from developers would be sufficient to do an adequate job of protecting the local community. Nor is there any requirement for such levy to be exclusively used for the benefit of the community impacted by the development. 10) There is no evidence of a Housing Needs Survey being completed for Blackmore. So there is no evidence that the proposed sites are required for the benefit of Blackmore nor that they will fulfil the needs of the local community. 11) There is no evidence of appropriate investigation into other brownfield sites that are available and should take precedence over the Green Belt Sites listed. 12) There is no evidence of proactive research by BBC into potential areas that would positively benefit the local communities if developed. Rather they have waited for developers to apply for site inclusion (presumably for sites that would provide the most profit). Indeed some viable and useful sites have been removed without comment eg Honeypot lane. 13) It is unsound to arbitrarily place disproportionate growth on one existing community which will cause it harm, leaving others with nothing at all when they would actually like some development to improve their sustainability. Eg Blackmore v Stondon Massey 14) Following removal of the Tipps Cross Sites from the proposed sites at the flawed Reg 18 meeting, the ONLY development anywhere apart from Main Towns or Village Service Centers is in Blackmore. It is unsound, unjustified, ineffective and flawed to propose a 30% increase in dwellings for any community. It is even more iniquitous when that growth would go beyond 50% if related developments were to be considered. (see 7 & 8 above). 15) No consideration has been given to Counties "Protected Lanes" & "Quiet Lanes" policies. It states "DEVELOPMENT PROPOSALS THAT WOULD ADVERSELY AFFECT THE PHYSICAL APPEARANCE OF THE PROTECTED LANES OF HISTORIC OR LANDSCAPE VALUE OR GIVE RISE TO A MATERIAL INCREASE IN THE AMOUNT OF TRAFFIC USING THESE LANES AND ROADS WILL NOT BE PERMlmD". Red Rose Lane (previously known as Service Lane) was used by travelers to avoid the village center during the Black Death in 1349, and to carry the dead around the outside of the village. The other part of the bypass to the south is Wenlocks Lane and it is protected. 16) Blackmore plans refer to type of development and require allocations for local & affordable housing. Which is unachievable as: a) House prices would be out of reach of "affordable housing'' candidates, who would also be unable to commute safely due to non-existent public transport and an unviable road system. b) There was no survey to ascertain if there was any local requirement, and any need would be for bungalows or flats for village children (which would increase the number of cars & traffic movements and would not be affordable for 1st time buyers. c) The idea of a Residential Travel Pack is ludicrous. Nothing could promote "sustainable travel from a site that big on single carriageway lanes. 17) Blackmore sites fail dismally SPOl: Don 8 of the 11 requirements. 18) When questioned, BBC Planning Team have avoided providing any solutions by passing the buck to Developers. So far, no surveys have been undertaken to ascertain if a problem exists with the development proposed. This means that Reg 18 & Reg 19 could be passed with Issues but no solutions; Developers who may suddenly have catastrophic profit margin holes and be forced to pull out or seek to cram in more houses. This would force new sites and new developers to be required after the LDP were agreed. This seems unsound, unjustified, ineffective and flawed. 19) When questioned, BBC Planning Team break down their response to individual issues with individual sites and suggest that one issue would not cause any harm to the community. They have avoided responding to situations, or reconsidering, where a site has 8 different problems. Eg Blackmore: Lack of employment viability; Lack of transport links; lack of infrastructure; lack of medical facilities; lack of education facilities; Severe flooding problems; lack of roads to build the development and subsequently deal with the astronomical increase in traffic movement; loss of Green Belt and damage to natural habitats. When problems are this significant, a solution must be proposed before including in the Listed Sites. Failure to do this is unsound, unjustified, ineffective and flawed. 20) To cause an increase in traffic movements of up 2000 per day along exceptionally narrow lanes that would cause irreparable damage to the sustainability of an existing thriving community is unsound, ineffective and flawed. Total Failure of requirement for any scheme to be acceptable item 4.9. 21) Existing traffic is a problem for Blackmore pedestrians where there are no footpaths or streetlights. Major increases in traffic would be downright dangerous. 22) If SP03 is actually imposed, the Blackmore developments will fail the requirements on over half and will in fact have a negative Health Impact on the existing residents. This means the Council would be obliged to refuse the planning permission or levy a huge CIL on the developer which would make it non-viable due to total loss of profitability. 23) There are a huge number of reports and surveys already in existence that highlight the major risk to flooding that already exists in Blackmore. Developing in a known flood prone area is crazy and will also increase the risk of flooding to the existing community. 24) The LDP states 8.90 that Blackmore & others are excluded from the Green Belt. There is no evidence provided for the comment and I would challenge the veracity of it. In fact BBC have classified in the LDP 4.23 Blackmore & Hook End developments as "Green Belt Land - Larger Villages". I can see an advantage for BBC if it were true, as it would avoid them having to come up with tortuous reasons to breach the rules for building on Green Belt. In conversations and meetings with BBC & their planning team they have never challenged our assertions that they are wrong to build on Green Belt. 25} Policy NE13 A requires that Sites allocated to meet housing needs in the Green Belt will be expected to provide significant community benefits, both for the existing community and the new homes. The Blackmore sites provide no benefit for the existing community and in fact it would be a negative change. 26} BBC (with significant support from Local Communities) went to great lengths a couple of years ago to prove the illegal occupation of the site in Chelmsford Road should not be allowed and the perpetrators should be removed. Now with no warning one individual raised the idea of formalizing the acceptability of the site, linking it to the LDP and it was passed without discussion at the infamous "Guillotine Meeting"

Question 5 - bullets 1-3 * Due to the significant issues surrounding the acceptance of Reg 18 by BBC I think it would be necessary to independently reconsider the entire process to ensure that it was handled appropriately, and if not, repeat the process correctly before proceeding to Reg 19. Other bullets * New officials who understand the local issues and can make their voices heard with independence, in an environment that is willing to listen would be a prerequisite to getting any issues of this magnitude considered in a fair and democratic fashion. * Removing Blackmore from the List of Sites as previously promised or allocating the 70 houses to Dunton Hills, as already done for other sites.

General Comment relating to my response overall: My opinions are based primarily on my detailed knowledge of my local area of the LDP. This indicates it is Unsound and has not complied with the duty to cooperate. If it is flawed in one area, across this many criteria, it will in all probability suffer from the same flaws throughout when subjected to appropriate scrutiny. 1) The LDP has changed from original plan to that considered at Reg 18, with no explanation of why some sites have been included after initially being promised they will be excluded eg Blackmore and some eminently suitable sites have disappeared eg Honeypot Lane. 2) The late changes to the plan curtailed the amount of time available to appropriately consider and challenge it. 3) When Reg 18 was debated in the BBC chamber, some items were included without any prior warning or debate eg Formal inclusion of Traveler Site Status in Chelmsford Road, and some major concerns and proposals were totally and deliberately avoided eg using a guillotine motion to stop any Blackmore concerns being raised. 4) The original LDP was full of reference to quality of life, maintaining sustainable communities, improving residents' existence via the LDP, and working for the people was a recurring theme. This have disappeared from the latest version and it is now about meeting the target number of dwellings to be built to meet government quotas, and wanting residents input in a fashion that requires specialist knowledge. 5) The way that this form and the background information has been constructed is so complex and confusing for anyone not a professional planner, it has stopped a large number of ordinary residents from responding even though they have major issues. Some have even suggested that BBC did this deliberately to avoid too many people voicing their concerns. 6) Apart from at Dunton Hills there has been no creation of a coordinated strategy for any of the medium sized sites, nor for multiple linked sites that, when considered together, require a strategy. 7) There has been insufficient, if any, coordination with neighboring Councils and this leads to developments agreed by one council adversely affecting communities in another councils area. Eg Epping Forest & Brentwood. 8) There has been no evidence of Private developments (not included in the LDP) being considered to ensure the aggregation of LDP, Other Council Developments, and Private developments do not combine to cause increased problems or overwhelm and swamp any thriving communities. 9) There is no evidence that any C.I.L. required from developers would be sufficient to do an adequate job of protecting the local community. Nor is there any requirement for such levy to be exclusively used for the benefit of the community impacted by the development. 10) There is no evidence of a Housing Needs Survey being completed for Blackmore. So there is no evidence that the proposed sites are required for the benefit of Blackmore nor that they will fulfil the needs of the local community. 11) There is no evidence of appropriate investigation into other brownfield sites that are available and should take precedence over the Green Belt Sites listed. 12) There is no evidence of proactive research by BBC into potential areas that would positively benefit the local communities if developed. Rather they have waited for developers to apply for site inclusion (presumably for sites that would provide the most profit). Indeed some viable and useful sites have been removed without comment eg Honeypot lane. 13) It is unsound to arbitrarily place disproportionate growth on one existing community which will cause it harm, leaving others with nothing at all when they would actually like some development to improve their sustainability. Eg Blackmore v Stondon Massey 14) Following removal of the Tipps Cross Sites from the proposed sites at the flawed Reg 18 meeting, the ONLY development anywhere apart from Main Towns or Village Service Centers is in Blackmore. It is unsound, unjustified, ineffective and flawed to propose a 30% increase in dwellings for any community. It is even more iniquitous when that growth would go beyond 50% if related developments were to be considered. (see 7 & 8 above). 15) No consideration has been given to Counties "Protected Lanes" & "Quiet Lanes" policies. It states "DEVELOPMENT PROPOSALS THAT WOULD ADVERSELY AFFECT THE PHYSICAL APPEARANCE OF THE PROTECTED LANES OF HISTORIC OR LANDSCAPE VALUE OR GIVE RISE TO A MATERIAL INCREASE IN THE AMOUNT OF TRAFFIC USING THESE LANES AND ROADS WILL NOT BE PERMlmD". Red Rose Lane (previously known as Service Lane) was used by travelers to avoid the village center during the Black Death in 1349, and to carry the dead around the outside of the village. The other part of the bypass to the south is Wenlocks Lane and it is protected. 16) Blackmore plans refer to type of development and require allocations for local & affordable housing. Which is unachievable as: a) House prices would be out of reach of "affordable housing'' candidates, who would also be unable to commute safely due to non-existent public transport and an unviable road system. b) There was no survey to ascertain if there was any local requirement, and any need would be for bungalows or flats for village children (which would increase the number of cars & traffic movements and would not be affordable for 1st time buyers. c) The idea of a Residential Travel Pack is ludicrous. Nothing could promote "sustainable travel from a site that big on single carriageway lanes. 17) Blackmore sites fail dismally SPOl: Don 8 of the 11 requirements. 18) When questioned, BBC Planning Team have avoided providing any solutions by passing the buck to Developers. So far, no surveys have been undertaken to ascertain if a problem exists with the development proposed. This means that Reg 18 & Reg 19 could be passed with Issues but no solutions; Developers who may suddenly have catastrophic profit margin holes and be forced to pull out or seek to cram in more houses. This would force new sites and new developers to be required after the LDP were agreed. This seems unsound, unjustified, ineffective and flawed. 19) When questioned, BBC Planning Team break down their response to individual issues with individual sites and suggest that one issue would not cause any harm to the community. They have avoided responding to situations, or reconsidering, where a site has 8 different problems. Eg Blackmore: Lack of employment viability; Lack of transport links; lack of infrastructure; lack of medical facilities; lack of education facilities; Severe flooding problems; lack of roads to build the development and subsequently deal with the astronomical increase in traffic movement; loss of Green Belt and damage to natural habitats. When problems are this significant, a solution must be proposed before including in the Listed Sites. Failure to do this is unsound, unjustified, ineffective and flawed. 20) To cause an increase in traffic movements of up 2000 per day along exceptionally narrow lanes that would cause irreparable damage to the sustainability of an existing thriving community is unsound, ineffective and flawed. Total Failure of requirement for any scheme to be acceptable item 4.9. 21) Existing traffic is a problem for Blackmore pedestrians where there are no footpaths or streetlights. Major increases in traffic would be downright dangerous. 22) If SP03 is actually imposed, the Blackmore developments will fail the requirements on over half and will in fact have a negative Health Impact on the existing residents. This means the Council would be obliged to refuse the planning permission or levy a huge CIL on the developer which would make it non-viable due to total loss of profitability. 23) There are a huge number of reports and surveys already in existence that highlight the major risk to flooding that already exists in Blackmore. Developing in a known flood prone area is crazy and will also increase the risk of flooding to the existing community. 24) The LDP states 8.90 that Blackmore & others are excluded from the Green Belt. There is no evidence provided for the comment and I would challenge the veracity of it. In fact BBC have classified in the LDP 4.23 Blackmore & Hook End developments as "Green Belt Land - Larger Villages". I can see an advantage for BBC if it were true, as it would avoid them having to come up with tortuous reasons to breach the rules for building on Green Belt. In conversations and meetings with BBC & their planning team they have never challenged our assertions that they are wrong to build on Green Belt. 25} Policy NE13 A requires that Sites allocated to meet housing needs in the Green Belt will be expected to provide significant community benefits, both for the existing community and the new homes. The Blackmore sites provide no benefit for the existing community and in fact it would be a negative change. 26} BBC (with significant support from Local Communities) went to great lengths a couple of years ago to prove the illegal occupation of the site in Chelmsford Road should not be allowed and the perpetrators should be removed. Now with no warning one individual raised the idea of formalizing the acceptability of the site, linking it to the LDP and it was passed without discussion at the infamous "Guillotine Meeting"

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

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