Refer to BHVA neighbourhood plan

Section 04; 08 - green belt flooding; 09 - R25 and R26
The strategy for rural villages like Blackmore isn't clear in the document, . Red Rose lane is unsuitable for an increase in traffic flow, due to the access onto/off of the road; the proposed sites are areas known for flooding and development will also increase flood risk elsewhere in Blackmore; the principle of the red rose lane development is wrong - Blackmore is an isolated village with limited infrastructure and poor public transport, which would struggle more.

Remove 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.

Remove R25 and R26 from plan

Refer to attached scans

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

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.

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

A detailed housing needs survey needs to be undertaken for Blackmore Village and I endorse the objectives of BVHA.

Refer to attached text

A detailed housing needs survey needs to be undertaken for Blackmore Village and I endorse the objectives of BVHA.

Refer to attached scan. Summary Section 08 Flood Risk and Green Belt
Section 09 R25 and R26
There doesn't appear to be any clear strategy for the villages including Blackmore, strain on facilities, such as school places and doctors. Very limited bus service and roads and lanes would be stretched and struggle to cope with more traffic. There is no housing need survey to say these sites are most suitable. Sites are liable to flood and new homes will increase flood risk elsewhere in Blackmore.
A detailed housing needs survey needs to be undertaken for Blackmore Village and I endorse the objectives of BVHA.

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

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"

Site R25 and R26 should be removed from the LDP and Planners should refer to the BVHA Neighbourhood Plan which clearly sets out our local housing needs, for our already sustainable community. Should not build on green belt land. Backing the BVHA.

Blackmore is one of the few remaining small historical villages. It would be a terrible thing to lose such an attraction. Its wonderful church, village green and lovely country roads. The infrastructure of such a small village can't support such a level of development therefore I consider the plan to be unsound.

Site R25 and R26 should be removed from the LDP and Planners should refer to the BVHA Neighbourhood Plan which clearly sets out our local housing needs, for our already sustainable community. Consideration has not been given to the BVHA Neighbourhood plan. Also further review must take place regarding impacts and other developments in progress and brownfield opportunities.

The plan is not sound. Blackmore as a village does not have the resource or infrastructure to even support a development of this scale. The roads are far too narrow to allow access on such a huge scale and the limited resources of schools and streets will not be able to cope. It appears consideration has not been given to other alternative available to the council.

To remove Blackmore from this list of proposed sites

UNSOUND: The flooding of a few years ago has just been alleviated this would cause more problems in that area. Blackmore would be unable to cope with this amount of development. We already have waiting lists for appointments to see local doctors. The parking is already a problem.

Consultation required with neighboring authorities this would show several developments that would impact on local services in Blackmore and cater for some local housing needs. Location needs to be re-assessed. There is no prove that Blackmore needs this number of houses being distant from transport links and there being little or no local employment. Detailed flood risk analysis required - to identify suitable locations out of flood risk areas. The historic lanes in and around Blackmore should be assessed to the established procedure and allocated "Protected Lane" status where they meet the necessary requirements. Assess possibility of smaller scale brownfield developments - support a policy of partnering owners of brownfield sites to develop local area needs where proven. Re-assess the development of sites around the transport hubs (Brentwood, Dunton, etc.) to cater for the Borough's housing needs and reduce the demands on the already stretched rural infrastructure to the north of Brentwood. Develop a strategic approach to the Villages north of Brentwood by consultation with the local community.

The Local Plan is not compliant on the following points: 1. NPPF Sect 2 8.a.b.c - to meet local need, accessible services -does not comply. 2. NPPF Sect 3 28 - the views of the local community have not been included in production of the plan. 3. NPPF Sect 5 77/78-decisions should be 'responsive to local circumstances' and 'reflect local needs'. There is no proven need for these houses. 4. NPPF Sect 9 103 - development should be location focused, limiting the need to travel and offering a genuine choice of travel modes. This development of 70 houses will rely on private cars for transport being at least 7 miles from the nearest rail stations being accessed via local rural lanes. The limited bus services are not supportive of employment during normal working hours. 5. NPPF Sect 14 -area known locally to flood although no focused flood risk assessment has been carried out. History of flooding shows both Chelmsford Road and Redrose Lane become impassable during heavy rainfall. (In 2012 my own car was written off after ingesting flood water through the air intake system when proceeding along Redrose Lane. 6. NPPF Sect 15 17 4/175 - to protect and enhance biodiversity. NPPF 16 - Conserving the historic environment. R25 and R26 have two Grade 2 listed buildings on the boundary of the development. Redrose Lane being the point of access for both developments is signed by the Highways authority as "Not suitable for heavy goods vehicles". Red rose lane has historical significance as a bypass during the Black plague of 1348. This lane has been assessed by the local community by way of the procedure used in the Brentwood Borough Council Protected Lanes report [March 2016 (Draft)].

A fully evidenced survey of the suitability of these proposed sites is required taking into account the obligations of the local authority to protect green belt and the heritage assets in Blackmore village. Detailed flood risk analysis is required. Assess fully any available or new currently unknown brownfield sites in more suitable locations. Meaningful consultation with neighboring authorities namely Chelmsford to consider the suitability of unmet housing needs being covered with an agreement with other authorities. Evidence and develop a strategic approach for the north of the borough

I object to the inclusion of the sites on Green Belt land referenced Policy R25: Land North of Woollard Way, Blackmore and Policy R26: Land North of Orchard Piece, Blackmore into the Local Plan for the following reasons. Not Positively Prepared: 1. Failure to give an objective assessment of the development and infrastructure requirements. 2. Failure to address the impact on the village with a 27% increase in size has been underestimated in respect of impact on the lives of the occupants of the village and of other residents in close proximity to the development. 3. Failure to mitigate the effects of traffic emissions and mange climate risk by concentrating new developments in existing cities or large town and/or ensuring they are well served by public transport. 4. Failure to fully examine the redevelopment of the brownfield sites identified by the local authority on their Brownfield Land Register Part 1. Failure in their obligation to preserve Green Belt as laid out in the Sustainability Appraisal - 507 Safeguard the Green Belt and protect and enhance valuable landscapes and the natural historic environment. 5. Failure by the local planning authority to provide evidence of any assessment of local housing needs in Blackmore. No Justification: 1. Failure to fulfill its own Statement of Community Involvement that relates to the involvement and engagement of the community and stakeholders in the exercising of its planning functions I do not believe that the local authority has fully demonstrated a willingness to engage with and take note of the opinions of the local community. 2. Failure to evidence a local housing need in Blackmore supporting its inclusion in the Local Plan. Not Effective: 1. Failure as the plan does not provide suitable infrastructure for the proposed new homes and does nothing to make housing affordable for people on average or low incomes. Inconsistent with national policy: 1. Failure to comply with guidance in the National Planning Policy Framework in respect to the construction of new buildings being inappropriate on Green Belt. 2. Failure to conserve the historic environment R25 and R26 have two Grade 11 listed properties on the boundary of the development, Redrose Lane which is proposed as the access point to both development is not suitable as it is a country lane not designed to take large volumes of traffic and is unsuitable for heavy goods vehicles. 3. Failure to demonstrate that the exceptions as set out in government guidance apply to the sites under consideration in Blackmore 4. Failure to demonstrate a full examination of alternatives on brownfield land/sites prior to the proposal to consider the developments on Land to the North of Woollard Way and Orchard Piece. 5. Failure to comply with the NPPF by setting out strategic policies to deliver the conservation and enhancement of the natural and historic environment, including landscape. 6. Failure to present a 'positive strategy' for the 'conservation and enjoyment of the historic environment', including those heritage assets that are most at risk. Assets should be recognised as being an 'irreplaceable resource' that should be conserved in a 'manner appropriate to their significance', taking account of 'the wider social, cultural, economic and environmental benefits' that conservation can bring, whilst also recognising the positive contribution new development can make to local character and distinctiveness

Take R25 and R26 out of the plan and consider the alternatives.

Policy R25 and R26, Sections 4,8,9 of LDP
Concerns over schools in the area, ie more traffic in and round Blackmore, Doddinghurst and nearby villages. Also Dr's surgery seems difficult to get appointments now, without new housing in the area.
Take R25 and R26 out of the plan and consider the alternatives.

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.