remove sites R25 and R26 from the Local Plan

As attached

Remove sites R25 and R26 from the Local Plan

As attached

Remove sites R25 and R26 from the Local Plan

As attached.

Remove sites R25 and R26 from the Local Plan

As attached.

Remove sites R25 and R26 from the Local Plan

As attached.

Remove sites R25 and R26 from the Local Plan

As attached.

Delete Policy NE13

These representations are submitted by Strutt & Parker on behalf of Stonebond Properties Ltd. in relation to the Brentwood Borough Council (BBC) Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our client's land interests at Stocks Lane, Kelvedon Hatch. This is proposed for allocation under Policy R24 of the PSLP. Plans showing the site are included within the Vision Document at Appendix A to this representation. As the Council will be aware, representations have previously been made on behalf of the landowner, W H Norris & Sons, in respect of the land at Stocks Lane, most recently as part of the Regulation 18 Local Plan Consultation in March 2018. Since then the site has come into the control of Stonebond Properties Ltd, a local housing developer with considerable experience of bringing forward high quality homes on small and medium sites. As a result of the previous representations and discussions with officers at Brentwood Borough Council alongside the Local Plan process, this site and land at Blackmore Road (Site R23, Brize's Corner Field, also now under Stonebond Properties' control) have been proposed as sites for future residential development within PSLP. Stonebond's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to certain elements of the Policy R24 in relation to the amount of development, the expected time for delivery in the Plan period and certain elements of the PSLP's Development Management Policies. Where such concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist in BBC making the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy. Stonebond Properties request the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of the Examination of the submitted Local Plan. Settlement Hierarchy: Kelvedon Hatch is confirmed as a Category 3 Larger Village as set out in the Settlement Hierarchy shown at figure 2.3 of PSLP. It states that these villages are characterised by the amount of amenities and services able to cater for residents' day to day needs. Kelvedon Hatch has a local centre with a range of services, facilities, access to public transport, and education services. The PSLP sets out that Category 3 settlements should seek to make the most of brownfield redevelopment opportunities, while limited urban extensions will be encouraged to meet local needs where appropriate. The population is stated as 2,124, making Kelvedon Hatch the second largest Category 3 Settlement behind Doddinghurst. Due to the proximity of Doddinghurst (around 1km to the east), there is a reciprocal relationship between the two villages in terms of the availability and access to services and other facilities. As a result, development at Kelvedon Hatch is clearly a sustainable location to which a proportion of the Borough's housing need should be directed. In addition, as an established community, it is important that the Local Plan provides for the growth of the settlement to ensure the vitality of the community is sustained or enhanced. In line with Paragraph 78 of the NPPF, growth in one village may have the added benefit of further supporting opportunities and growth in nearby surrounding villages. The two sites for additional housing in Kelvedon Hatch identified in the PSLP at Land at Stocks Lane (R24) and west at Blackmore Road (R23) are fully supported. The proposed allocation of these two sites is considered to be justified, consistent with national policy and necessary to ensure the sustainable growth of Kelvedon Hatch and the Borough for reasons set out elsewhere in these representations. Spatial Strategy - Vision and Strategic Objectives: Vision for the Borough: The Vision for the Borough set out at Section 3 of the PSLP is supported. For the reasons set out in these representations, carefully planned development at Kelvedon Hatch as provided for at Policies R23 and R24 will make an important contribution to BBC's housing needs to meet the Local Plan objectives. Indeed, these representations and those relating to R24 make the case that a modest and justified increase in the sites' ability to accommodate more homes will assist meet those aims and provide for greater flexibility in meeting housing needs. Stonebond Properties have undertaken detailed site assessments. These confirm that there are no barriers to delivery of development. As a consequence, the expressed objectives of development in the Vision to be landscape-led responding to a "design and build with nature approach firmly embedding high quality green infrastructure through public realm to create a seamless transition to our surrounding countryside" can all be achieved and delivered in the allocation of sites R23 and R24. This is demonstrated in the accompanying Vision Documents to this representation for R24. Managing Growth - Policy SP02: Managing Growth: Policy SP02 proposes a total of 7,752 dwellings be provided in the Borough between 2011 and 2033 with 310 homes per year to 2022/23 and then 584 per year from 2022/23 taking forward a "stepped delivery" approach to deal with a projected shortfall in the first 5 years of the PSLP. This is mainly because a greater proportion of homes to be delivered in the PSLP comprise sites located in the Green Belt, resulting in longer lead in times to delivery. Whilst we do not raise objections in principle to the stepped approach as far as our clients are concerned there is a prospect that some sites in the Green Belt have the prospect of coming forward earlier, particularly smaller and medium sized developments. This certainly includes this site R24, and R23 that is the subject of a separate representation. This matter is dealt with further at Section 8 below. Furthermore, and notwithstanding the stepped approach proposed, there are still issues with BBC's over-optimistic estimates and assumptions on the delivery of larger strategic sites proposed for allocation in the PSLP. BBC are effectively placing most of its "eggs in one basket." in the range of sites that are proposed in the PSLP. It is important to note that, of the new allocations, 4,578 homes are made up of strategic allocations (of which 2,700 are at Dunton Hills Garden Village and are to be delivered in the Plan period) and 1,510 are other allocations The strategic sites therefore represent 68% of the total number of new homes of which some 59% are allocated at Dunton Hills. The ability of larger strategic sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin Review (2018); and issues with their complexity, have been ably set out in the Lichfield's study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematical due to a range of factors, including establishing required infrastructure requirements and the timing of housing delivery associated with those requirements, as well as the prolonged or protracted nature of the planning process. The Lichfield's report confirms that the planning process takes, on average, 2.5 years for the planning application determination period for up to 500 units; this can double for sites over 1,000 units. Two of the strategic sites within the PSLP's allocations also comprise developed sites currently in employment uses. The strategic sites are expected to deliver some 1555 homes within 5 years of an assumed adoption in 2020/21. Given the issues set out above it is considered that this is unrealistic and it would not be justified or the most appropriate strategy to rely on these sites for short term housing delivery. It therefore emphasises the need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound. Sequential Land Use: Paragraph 4.22 and 4.23 of the PSLP suggested that a sequential approach is to be taken to the determination of planning applications, referring only to prioritising brownfield land in urban areas and brownfield land in the Green Belt. The reasons for this are unclear when the PSLP strategy includes releasing land from the Green Belt to meet development needs which includes the sites the subject of these representations. The growth requirements set out by Policy SP02, and the sequential approach to meeting those requirements are referred to at paragraph 3.23, provide for the justification for the chosen spatial strategy. As a consequence, it is not justified to suggest that a sequential test be taken for the determination of planning applications and paras 4.22 and 4.23 should be deleted from the PSLP. SP04 - Developer Contributions: There are no objections to the general approach expressed in Policy SP04 for developer contributions. However, section E is nether precise, necessary or justified and could be open to misinterpretation. It is therefore recommended that this be omitted. Resilient Built Environment: We are generally supportive of the Council's objectives to achieve a resilient built environment. Nevertheless, there are concerns that the policies set out in the PSLP and as drafted may have an impact on viability, deliverability and affordability for housing development generally. We are aware of the representations made by the House Builders Federation (HBF) referring to sustainable construction (BE020), allotments (BE20), Green and Blue Infrastructure (BE18), access to nature (BE19), digital infrastructure (BE10), open space (BE22), electrical vehicle charging (BE15), housing quality (HP06). The implications of the requirements set out do not appear to have been fully considered as part of the viability assessment. As a consequence, we would suggest that the viability assessment for the PSLP is revisited to reflect on these requirements to better inform or provide clarity on the proposed policies. Policy BE01 - Future Proofing: Whilst the Council's objectives towards future proofing of development are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. It is of some concern that Part A of the Policy requires that all applications must take into account....... when the process of development management and determination of applications is far more prescriptive and binary in decision making. As a consequence, it is suggested that Policy BE01 should be set out as supporting text rather than a specific policy. Policy BE02 - Sustainable Construction and Resource Efficiency: Whilst the Council's objectives towards sustainable construction and resource efficiency are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. The requirement to submit details of measures that increase resilience to the threat of climate change at b. is also considered to be over prescriptive when such techniques may vary substantially. The general principles set out at para 5.19 are reflective of the fact that these matters ought more properly to be dealt with by supporting text rather than a specific policy. In addition, we are aware of comments made by the HBF on this policy and we support those comments. Policy BE20 - Allotments and Community Food Growing Space: Whilst the Council's aspirations for providing allotments are acknowledged, the policy as set out provides for no clear thresholds as to when such space should be provided which is not justified in the terms set out. On this basis, it is recommended that the policy should either be omitted and dealt with by the text to the PSLP or justified against thresholds or site specific requirements. In this respect, it may be that large strategic sites may need to include a requirement but it is certainly not necessary for smaller or medium sized sites, such as those the subject of these representations. Policy BE22 - Open Space in New Development: The policy is broadly supported. As can be seen from the Vision document that accompanies these representations, our proposed scheme for R24 makes provision for such space. It is nevertheless questionable whether it is necessary for all open space to be fully equipped (D.). The need for equipped space should also be related to the amount of development proposed and/or availability or local equipped areas. As a consequence, it is recommended that criteria D is amended to be refined to provide clarity on when equipped open space is required eg. on sites over 50 homes. Housing Provision: Policy HP01 - Housing Mix: The Council's approach to providing for an appropriate mix of dwelling types is generally supported. However, the Policy as set out refers to the Borough wide requirements in the Strategic Housing Market Assessment (SHMA) and does not necessarily take into account a local area or sub area within the Borough. It is important to note that the SHMA requirements, at Figure 6.1, confirms that it is an indicative mix guide for market housing. It is also noted that para 6.5 confirms that the final mix will be subject to negotiation. This is welcomed on the basis that some flexibility will be necessary in certain circumstances as part of the planning application process. As a consequence, it is suggested that para 6.5 should provide greater clarity and a minor change confirming that the final mix will be subject to negotiation "as part of a planning application" rather than "with the applicant". We are aware of the representations submitted by HBF regarding accessible homes and justification. We support those views. It is questionable whether it is necessary for the PSLP to set out in planning policy the requirements of Building Regulations. Policy HP03 - Residential Density: We support the PSLP's approach to residential density as set out in Policy HP03. This is considered to be justified based on the evidence and consistent with the national policy. As far as our client's land interests are concerned at R23 and R24, both sites are capable of providing an increased density to that expressed for the relevant policies R23 and R24. However, part B of the policy quite properly acknowledges that a chosen density should take into account the character of the surrounding area and other site constraints. This is supported. A further explanation of suggested density or yield for R24 is set out at Section 8 below. Policy HP05 - Affordable Housing: We note that the SHMA provides justification for the affordable housing requirements. However, it is questionable whether the precise tenure/mix should be set out at B(a) of the Policy, given that requirements can change relatively quickly over time and the prescriptive approach may not take into account precise local needs. As a consequence, it is recommended that the criteria under B(a) should omit the reference to 86% and 14% proportions. It is suggested, in the alternative, that "the mix, size, type and cost of affordable homes will meet the identified housing needs of the Council's area and local needs as appropriate, established by housing need assessments including the SHMA". Design and Place-making: The approach set out in the PSLP for design and place-making is broadly supported. However, we note that there are effectively seven policies (HP12 - HP18) which provide the requirements against these matters. We also note that there are some areas of repetition on some of the objectives against those policies. We consider that those commenting on and determining applications should preferably have one or two identified policies to refer to and/or applicable thresholds to more succinctly set out requirements. This would ensure that planning applications can be more effectively judged against context, design and place-shaping criteria. Natural Environment: We generally support the Council's approach to Green Belt and the identification of suitable sites to meet the Council's housing and other needs. Accompanying these representations is an overview of the Green Belt and Landscape Sensitivity considerations relating to Stonebond's land interests at R23 and R24 to confirm the suitability of removing those sites from the Green Belt and limited impact on the landscape. Policy NE13 - Site Allocations in the Green Belt: We welcome the PSLP's intentions to remove sites R23 and R24 from the Green Belt. This calls into question the need for Policy NE13. The requirements set out by criterion A and B are dealt with by other policies in the Plan. If there are site specific requirements relating to sites, these should be covered within the specific policies relating to those sites. Site Allocations: Policy R24 - Land off Stocks Lane: The proposed allocation of Land off Stocks Lane as Policy R24 and its removal from the Green Belt is considered sound and is fully supported. It has been established through the evidence base supporting the PSLP that Kelvedon Hatch is a sustainable location to accommodate a modest amount of new houses to contribute to the Borough's housing needs. Indeed, as recognised by para 68 of the NPPF and as a medium sized site, such sites make an important contribution to "meeting the housing requirement of an area and are often built out quickly". We do however have some concerns with the amount of development set out at A of the Policy and the indicative yield at page 340 and the suggested trajectory for the site at Appendix 1. These matters are dealt with below. Supporting these representations is a Vision Document at Appendix A, a review of Green Belt and Landscape Sensitivity at Appendix B and a Summary Drainage and Utility Appraisal at Appendix C. These all confirm that the development at the site is both justified and fully deliverable within the terms of para 67a) of the NPPF. The Vision Document demonstrates that careful consideration has been given to the emerging policies set out at BE01, BE08, BE22, as well as those relating to Design and Place-making at HP12, HP13, HP14, HP15 and HP18 of the PSLP to confirm that a scheme can meet the PSLP objectives in this regard. The Summary Drainage and Utility Appraisal at Appendix B confirms that there are no constraints to delivery. In addition, Stonebond Properties commissioned a transport appraisal from Ardent Consulting Engineers. This has confirmed that the location of the access shown in the Vision Document meets normal highway requirements in terms of safety and visability. This has been confirmed in speed surveys undertaken in Stocks Lane. The Green Belt and Landscape Sensitivity Assessment at Appendix B confirms that the release of the site from the Green Belt is justified. It also confirms that there would be no significant impact on the surrounding landscape. Part A of Policy R24 suggests that there be provision for around 30 new homes on the site. Part A Policy HP03 of the PSLP requires proposals to take a design led approach to density to ensure schemes are sympathetic to local character and make efficient use of land. Part B expects development to achieve a net density of at least 35dph unless the special character of the surrounding area suggests that such densities would be inappropriate. The suggested amount of 30 homes set out for Policy R24 does not currently reflect these requirements or provide an accurate representation of what is achievable on site. 30 homes represent 18.6dph which clearly does not represent an efficient or effective use of the land contrary to the objectives of HP03 and the supporting text set out at 6.18 to 6.20 and 6.22. The Vision Document confirms that around 45 homes can actually be provided on the site representing a far more efficient and effective dwelling yield. 45 homes would represent a density of approximately 28dph. Whilst this does not achieve 35dph, the Vision Document demonstrates that full account has been taken of the objectives of HP03 to ensure that a scheme would be sympathetic to local character. Critically, the illustrative scheme shows provision for open space within the site to meet the objectives of Policies HP13 and BE22. These policies provide for functional on-site open space. As such, achieving a greater density would be problematical. In addition, it is important to note that the site is on the edge of the settlement where there is a need for sensitivity, having regard to the countryside to the east and south. Para 6.22 of the PSLP confirms that efficient land use is critical to the delivery of this Plan for the reasons set out at Sections 4 and 6 above against this background, it is recommended that amendments are made as follows: Policy R24A - substitute 30 new homes with 45 new homes; Page R24 - indicative dwelling yield substitute 30 with 45. At para 9.195 the PSLP suggests the development would take its access from Blackmore Road. This is an error. The paragraph should be amended to refer to Stocks Lane. The site is within the control of Stonebond Properties, a local house builder with considerable experience in the development of medium sized sites, quick delivery and achieving high design and layout standards. Upon removal from the Green Belt and grant of a planning permission, it would be expected that development at the site could commence 2020/21 and be completed within two years of the Plan. As a consequence, it is recommended that the Local Development Plan Housing Trajectory at Appendix 1 is amended to provide for the following based on an increased number of homes as set out in these representations: Year 5 - 2020/21 = 10; Year 6 - 2021/22 = 35. These comments on Policy R24 provide greater certainty on delivery of the site. In addition, the changes suggested would contribute to the issues we have identified elsewhere with the PSLP specifically in relation to the supply and delivery of homes generally. As a result, we trust that the Council will be able to agree modifications/changes accordingly.

Delete Policy NE13

These representations are submitted by Strutt & Parker on behalf of Stonebond Properties Ltd. in relation to the Brentwood Borough Council (BBC) Proposed Submission Local Plan (Regulation 19) (PSLP), and in particular with regards to our client's land interests at Stocks Lane, Kelvedon Hatch. This is proposed for allocation under Policy R24 of the PSLP. Plans showing the site are included within the Vision Document at Appendix A to this representation. As the Council will be aware, representations have previously been made on behalf of the landowner, W H Norris & Sons, in respect of the land at Stocks Lane, most recently as part of the Regulation 18 Local Plan Consultation in March 2018. Since then the site has come into the control of Stonebond Properties Ltd, a local housing developer with considerable experience of bringing forward high quality homes on small and medium sites. As a result of the previous representations and discussions with officers at Brentwood Borough Council alongside the Local Plan process, this site and land at Blackmore Road (Site R23, Brize's Corner Field, also now under Stonebond Properties' control) have been proposed as sites for future residential development within PSLP. Stonebond's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations, albeit with some overarching concerns, notably in relation to certain elements of the Policy R24 in relation to the amount of development, the expected time for delivery in the Plan period and certain elements of the PSLP's Development Management Policies. Where such concerns are raised, specific changes to the relevant policies are sought and these are indicated in the following representations in order to assist in BBC making the Plan more robust and improving its soundness in terms of being positively prepared, effective, justified and consistent with national policy. Stonebond Properties request the right for its professional advisors to provide further responses on any matters appropriate to their land interests at the relevant sessions of the Examination of the submitted Local Plan. Settlement Hierarchy: Kelvedon Hatch is confirmed as a Category 3 Larger Village as set out in the Settlement Hierarchy shown at figure 2.3 of PSLP. It states that these villages are characterised by the amount of amenities and services able to cater for residents' day to day needs. Kelvedon Hatch has a local centre with a range of services, facilities, access to public transport, and education services. The PSLP sets out that Category 3 settlements should seek to make the most of brownfield redevelopment opportunities, while limited urban extensions will be encouraged to meet local needs where appropriate. The population is stated as 2,124, making Kelvedon Hatch the second largest Category 3 Settlement behind Doddinghurst. Due to the proximity of Doddinghurst (around 1km to the east), there is a reciprocal relationship between the two villages in terms of the availability and access to services and other facilities. As a result, development at Kelvedon Hatch is clearly a sustainable location to which a proportion of the Borough's housing need should be directed. In addition, as an established community, it is important that the Local Plan provides for the growth of the settlement to ensure the vitality of the community is sustained or enhanced. In line with Paragraph 78 of the NPPF, growth in one village may have the added benefit of further supporting opportunities and growth in nearby surrounding villages. The two sites for additional housing in Kelvedon Hatch identified in the PSLP at Land at Stocks Lane (R24) and west at Blackmore Road (R23) are fully supported. The proposed allocation of these two sites is considered to be justified, consistent with national policy and necessary to ensure the sustainable growth of Kelvedon Hatch and the Borough for reasons set out elsewhere in these representations. Spatial Strategy - Vision and Strategic Objectives: Vision for the Borough: The Vision for the Borough set out at Section 3 of the PSLP is supported. For the reasons set out in these representations, carefully planned development at Kelvedon Hatch as provided for at Policies R23 and R24 will make an important contribution to BBC's housing needs to meet the Local Plan objectives. Indeed, these representations and those relating to R24 make the case that a modest and justified increase in the sites' ability to accommodate more homes will assist meet those aims and provide for greater flexibility in meeting housing needs. Stonebond Properties have undertaken detailed site assessments. These confirm that there are no barriers to delivery of development. As a consequence, the expressed objectives of development in the Vision to be landscape-led responding to a "design and build with nature approach firmly embedding high quality green infrastructure through public realm to create a seamless transition to our surrounding countryside" can all be achieved and delivered in the allocation of sites R23 and R24. This is demonstrated in the accompanying Vision Documents to this representation for R24. Managing Growth - Policy SP02: Managing Growth: Policy SP02 proposes a total of 7,752 dwellings be provided in the Borough between 2011 and 2033 with 310 homes per year to 2022/23 and then 584 per year from 2022/23 taking forward a "stepped delivery" approach to deal with a projected shortfall in the first 5 years of the PSLP. This is mainly because a greater proportion of homes to be delivered in the PSLP comprise sites located in the Green Belt, resulting in longer lead in times to delivery. Whilst we do not raise objections in principle to the stepped approach as far as our clients are concerned there is a prospect that some sites in the Green Belt have the prospect of coming forward earlier, particularly smaller and medium sized developments. This certainly includes this site R24, and R23 that is the subject of a separate representation. This matter is dealt with further at Section 8 below. Furthermore, and notwithstanding the stepped approach proposed, there are still issues with BBC's over-optimistic estimates and assumptions on the delivery of larger strategic sites proposed for allocation in the PSLP. BBC are effectively placing most of its "eggs in one basket." in the range of sites that are proposed in the PSLP. It is important to note that, of the new allocations, 4,578 homes are made up of strategic allocations (of which 2,700 are at Dunton Hills Garden Village and are to be delivered in the Plan period) and 1,510 are other allocations The strategic sites therefore represent 68% of the total number of new homes of which some 59% are allocated at Dunton Hills. The ability of larger strategic sites to come forward quickly has been the subject of recent assessments in the Independent Review of Build Out, the Letwin Review (2018); and issues with their complexity, have been ably set out in the Lichfield's study From Start to Finish (2016). Both provide empirical evidence that the early delivery of such sites can be problematical due to a range of factors, including establishing required infrastructure requirements and the timing of housing delivery associated with those requirements, as well as the prolonged or protracted nature of the planning process. The Lichfield's report confirms that the planning process takes, on average, 2.5 years for the planning application determination period for up to 500 units; this can double for sites over 1,000 units. Two of the strategic sites within the PSLP's allocations also comprise developed sites currently in employment uses. The strategic sites are expected to deliver some 1555 homes within 5 years of an assumed adoption in 2020/21. Given the issues set out above it is considered that this is unrealistic and it would not be justified or the most appropriate strategy to rely on these sites for short term housing delivery. It therefore emphasises the need to review the ability of smaller or medium sized sites such as R23 and R24 to provide for greater flexibility and more homes which have a far greater prospect for short term delivery to ensure the Local Plan is sound. Sequential Land Use: Paragraph 4.22 and 4.23 of the PSLP suggested that a sequential approach is to be taken to the determination of planning applications, referring only to prioritising brownfield land in urban areas and brownfield land in the Green Belt. The reasons for this are unclear when the PSLP strategy includes releasing land from the Green Belt to meet development needs which includes the sites the subject of these representations. The growth requirements set out by Policy SP02, and the sequential approach to meeting those requirements are referred to at paragraph 3.23, provide for the justification for the chosen spatial strategy. As a consequence, it is not justified to suggest that a sequential test be taken for the determination of planning applications and paras 4.22 and 4.23 should be deleted from the PSLP. SP04 - Developer Contributions: There are no objections to the general approach expressed in Policy SP04 for developer contributions. However, section E is nether precise, necessary or justified and could be open to misinterpretation. It is therefore recommended that this be omitted. Resilient Built Environment: We are generally supportive of the Council's objectives to achieve a resilient built environment. Nevertheless, there are concerns that the policies set out in the PSLP and as drafted may have an impact on viability, deliverability and affordability for housing development generally. We are aware of the representations made by the House Builders Federation (HBF) referring to sustainable construction (BE020), allotments (BE20), Green and Blue Infrastructure (BE18), access to nature (BE19), digital infrastructure (BE10), open space (BE22), electrical vehicle charging (BE15), housing quality (HP06). The implications of the requirements set out do not appear to have been fully considered as part of the viability assessment. As a consequence, we would suggest that the viability assessment for the PSLP is revisited to reflect on these requirements to better inform or provide clarity on the proposed policies. Policy BE01 - Future Proofing: Whilst the Council's objectives towards future proofing of development are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. It is of some concern that Part A of the Policy requires that all applications must take into account....... when the process of development management and determination of applications is far more prescriptive and binary in decision making. As a consequence, it is suggested that Policy BE01 should be set out as supporting text rather than a specific policy. Policy BE02 - Sustainable Construction and Resource Efficiency: Whilst the Council's objectives towards sustainable construction and resource efficiency are broadly supported, it is questionable whether it is necessary to set out a detailed planning policy to this effect when a number of the criteria set out comprise a series of aspirations. The requirement to submit details of measures that increase resilience to the threat of climate change at b. is also considered to be over prescriptive when such techniques may vary substantially. The general principles set out at para 5.19 are reflective of the fact that these matters ought more properly to be dealt with by supporting text rather than a specific policy. In addition, we are aware of comments made by the HBF on this policy and we support those comments. Policy BE20 - Allotments and Community Food Growing Space: Whilst the Council's aspirations for providing allotments are acknowledged, the policy as set out provides for no clear thresholds as to when such space should be provided which is not justified in the terms set out. On this basis, it is recommended that the policy should either be omitted and dealt with by the text to the PSLP or justified against thresholds or site specific requirements. In this respect, it may be that large strategic sites may need to include a requirement but it is certainly not necessary for smaller or medium sized sites, such as those the subject of these representations. Policy BE22 - Open Space in New Development: The policy is broadly supported. As can be seen from the Vision document that accompanies these representations, our proposed scheme for R24 makes provision for such space. It is nevertheless questionable whether it is necessary for all open space to be fully equipped (D.). The need for equipped space should also be related to the amount of development proposed and/or availability or local equipped areas. As a consequence, it is recommended that criteria D is amended to be refined to provide clarity on when equipped open space is required eg. on sites over 50 homes. Housing Provision: Policy HP01 - Housing Mix: The Council's approach to providing for an appropriate mix of dwelling types is generally supported. However, the Policy as set out refers to the Borough wide requirements in the Strategic Housing Market Assessment (SHMA) and does not necessarily take into account a local area or sub area within the Borough. It is important to note that the SHMA requirements, at Figure 6.1, confirms that it is an indicative mix guide for market housing. It is also noted that para 6.5 confirms that the final mix will be subject to negotiation. This is welcomed on the basis that some flexibility will be necessary in certain circumstances as part of the planning application process. As a consequence, it is suggested that para 6.5 should provide greater clarity and a minor change confirming that the final mix will be subject to negotiation "as part of a planning application" rather than "with the applicant". We are aware of the representations submitted by HBF regarding accessible homes and justification. We support those views. It is questionable whether it is necessary for the PSLP to set out in planning policy the requirements of Building Regulations. Policy HP03 - Residential Density: We support the PSLP's approach to residential density as set out in Policy HP03. This is considered to be justified based on the evidence and consistent with the national policy. As far as our client's land interests are concerned at R23 and R24, both sites are capable of providing an increased density to that expressed for the relevant policies R23 and R24. However, part B of the policy quite properly acknowledges that a chosen density should take into account the character of the surrounding area and other site constraints. This is supported. A further explanation of suggested density or yield for R24 is set out at Section 8 below. Policy HP05 - Affordable Housing: We note that the SHMA provides justification for the affordable housing requirements. However, it is questionable whether the precise tenure/mix should be set out at B(a) of the Policy, given that requirements can change relatively quickly over time and the prescriptive approach may not take into account precise local needs. As a consequence, it is recommended that the criteria under B(a) should omit the reference to 86% and 14% proportions. It is suggested, in the alternative, that "the mix, size, type and cost of affordable homes will meet the identified housing needs of the Council's area and local needs as appropriate, established by housing need assessments including the SHMA". Design and Place-making: The approach set out in the PSLP for design and place-making is broadly supported. However, we note that there are effectively seven policies (HP12 - HP18) which provide the requirements against these matters. We also note that there are some areas of repetition on some of the objectives against those policies. We consider that those commenting on and determining applications should preferably have one or two identified policies to refer to and/or applicable thresholds to more succinctly set out requirements. This would ensure that planning applications can be more effectively judged against context, design and place-shaping criteria. Natural Environment: We generally support the Council's approach to Green Belt and the identification of suitable sites to meet the Council's housing and other needs. Accompanying these representations is an overview of the Green Belt and Landscape Sensitivity considerations relating to Stonebond's land interests at R23 and R24 to confirm the suitability of removing those sites from the Green Belt and limited impact on the landscape. Policy NE13 - Site Allocations in the Green Belt: We welcome the PSLP's intentions to remove sites R23 and R24 from the Green Belt. This calls into question the need for Policy NE13. The requirements set out by criterion A and B are dealt with by other policies in the Plan. If there are site specific requirements relating to sites, these should be covered within the specific policies relating to those sites. Policy R23 - Brizes Corner Field, Blackmore Road: The proposed allocation of Land off Blackmore Road as Policy R23 and its removal from the Green Belt is considered sound and is fully supported. It has been established through the evidence base supporting the PSLP that Kelvedon Hatch is a sustainable location to accommodate a modest amount of new houses to contribute to the Borough's housing needs. Indeed, as recognised by para 68 of the NPPF and as a medium sized site, such sites make an important contribution to "meeting the housing requirement of an area and are often built out quickly". We do however have some concerns with the amount of development set out at A of the Policy, the indicative yield at page 339 and the suggested trajectory for the site at Appendix 1. These representations provide for a modest increase in the developable area of the site with compensatory open space/structural landscaping. These matters are dealt with further below. Supporting these representations is a Vision Document at Appendix A, a review of Green Belt and Landscape Sensitivity at Appendix B and a Summary Drainage and Utility Appraisal at Appendix C. These all confirm that the development at the site is both justified and fully deliverable within the terms of para 67a) of the NPPF. The Vision Document demonstrates that careful consideration has been given to the emerging policies set out at BE01, BE08, BE22, as well as those relating to Design and Place-making at HP12, HP13, HP14, HP15 and HP18 of the PSLP to confirm that a scheme can meet the PSLP objectives in this regard. The Summary Drainage and Utility Appraisal at Appendix B confirms that there are no constraints to delivery. In addition, Stonebond Properties commissioned a transport appraisal from Ardent Consulting Engineers. This has confirmed that the location of the access shown in the Vision Document meets normal highway requirements in terms of safety and visibility. This has been confirmed in speed surveys undertaken in Blackmore Road. The Green Belt and Landscape Sensitivity Assessment at Appendix B confirms that the release of the site from the Green Belt is justified. It also confirms that there would be no significant impact on the surrounding landscape. Vision Document illustrates a form of development for the proposed allocation area set out in the PSLP to provide for around 28 homes. These representations suggest that the allocated area could increase to provide for a modest addition to the developable area in associate with compensatory open space and structural landscaping. It is considered that the proposals would be in accordance with para 138 of the NPPF. This advises local planning authorities to "set out ways in which the impact of removing land from the Green Belt can be off set through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land". The Vision Document demonstrates how this can be achieved using land that is within their control. The Green Belt and Landscape Sensitivity Assessment confirms that such an approach would not result in demonstrable harm to the Green Belt or landscape. Part A of Policy R23 suggests that there be provision for around 23 new homes on the site. Part A Policy HP03 of the PSLP requires proposals to take a design led approach to density to ensure schemes are sympathetic to local character and make efficient use of land. Part B expects development to achieve a net density of at least 35dph unless the special character of the surrounding area suggests that such densities would be inappropriate. Based on page 339 of the PSLP, the suggested dwelling yield of 23 homes would result in a density of 29dph. The Vision Document confirms that within the allocated area it would be possible to provide around 28 homes at a density of 35dph. The Vision Document sets out an alternative approach to the allocation to increase the area to 2.45ha gross. This would provide for around 45 homes at 29dph on a net developable area of approximately 1.6ha. Critically, the Vision Document provides for a third of the area to be set aside for structural accessible open space in accordance with para 138 of the NPPF. The Vision Document therefore proposes that around 45 homes can be provided on the site representing a far more efficient and effective dwelling yield with benefits for open space and the Green Belt generally in this location by bringing forward a robust and enduring boundary. The Vision Document demonstrates that full account has been taken of the objectives of HP03 to ensure that a scheme would be sympathetic to local character. Critically, the illustrative scheme for the increased area for allocation would meet objectives for open space within the site in accordance with Policies HP13 and BE22 whilst taking into account the need for sensitivity, having regard to the countryside to the west and south. Section 4 of these representations sets out the need for greater flexibility and need for the provision of medium sized sites to aid the Council's housing needs and requirements. Against this background, these proposals to provide a modest increase to the allocated area for R23 are commended to the Council on the basis that the increased area provide for structural and accessible open space. It is therefore recommended that Policy R23 is amended as follows: Policy R23A - substitute 23 new homes with 45 new homes; Policy R23B - additional bullet point b - development shall provide for not less than 0.7ha for accessible public open space and structural landscaping; Page 339 R23 - indicative dwelling yield substitute 23 with 45. The site is within the control of Stonebond Properties, a local house builder with considerable experience in the development of medium sized sites, quick delivery and achieving high design and layout standards. Upon removal from the Green Belt and grant of a planning permission, it would be expected that development at the site could commence 2020/21 and be completed within two years of the Plan. As a consequence, and based on these representations for an increased allocation, it is recommended that the Local Development Plan Housing Trajectory at Appendix 1 is amended to provide for the following based on an increased number of homes as set out in these representations: Year 5 2020/21 = 10 and Year 6 - 2021/22 = 35. These comments on Policy R23 provide an ability for a modest increase in the amount of houses for the allocated site with significant local benefits for accessible open space and structural landscaping. This would result in compensatory improvements to the environmental quality and accessibility of Green Belt land in accordance with para 139 of the NPPF. In addition, the recommended changes would contribute to the issues we have identified elsewhere with the PSLP specifically in relation to the supply and delivery of homes generally. As a result, we trust that the Council will be able to agree modifications/changes accordingly.

These representations have been prepared by Strutt & Parker on behalf of Childerditch Properties for Brentwood Borough Council's (BBC) Regulation 19 Pre-Submission Consultation Local Plan (PSLP) and in particular, with regards to our client's land interest on the proposed allocation Childerditch Industrial Estate. Childerditch Properties request the right for Strutt & Parker or any other professional advisor acting on their behalf to provide further responses in Hearing Statements or at the relevant sessions of the Examination in Public following the submission of the PSLP. Childerditch Properties are the sole owners of Childerditch Industrial Estate. Representations have previously been made on their behalf in respect of the site throughout the Plan making process, including at the Call for Sites stage, as part of the 2013 Preferred Options Consultation and, most recently, as part of the 2018 Draft Local Plan Regulation 18 Consultation. At present, the Estate provides some 35 units and between 700 and 800 people are employed here. All of these units are occupied and our clients continue to receive enquiries for occupation. The Estate therefore currently plays an important role in providing a significant source of the Borough's employment land and the provision of jobs. The proposed allocations provided for in the PSLP would build on the success of the Estate by creating new employment land. Located two miles from Brentwood on the A127, the Estate is ideally placed to offer future employment opportunities in a highly sustainable location with excellent transport links. Childerditch Industrial Estate is an 'island' site within the surrounding countryside, comprising a range of B1, B2 and B8 employment uses and storage yards. The proposed allocation at Childerditch Industrial Estate is referred within Policy E12 of the PSLP. The proposed allocation of additional employment land, in combination with the existing Park, will provide a developable area of approximately 20.6 hectares of employment land. Accompanying these representations is a proposed masterplan prepared by CMP Architects which, whilst indicative at this stage, demonstrates how the Estate can be more efficiently and effectively developed. This document is copied to these representations at Appendix 1. An updated Access Appraisal prepared by Journey Transport Planning is also submitted with these representations and is copied at Appendix 2. Within this document, consideration is given to the existing Estate and proposed allocations, and the cumulative traffic impacts arising from other developments in the A127 corridor. The Appraisal also considers the access from Childerditch Hall Drive onto the A127, to confirm that the proposed allocation of the site is deliverable in the context of the existing and proposed allocations referred to above. Childerditch Industrial Estate is located just to the north of the A127, approximately halfway between Junction 29 of the M25 to the west, and the junction of the A127 and A128 to the east. Other sites proposed for allocation within the PSLP also found along this section of the A127 include Brentwood Enterprise Park (Policy E11) and Land at Codham Hall Farm (Policy E10), which are located to the south and north of the A127 respectively. Given the stage of the PSLP, these representations focus on the soundness of the Plan, in accordance with paragraph 35 of the National Planning Policy Framework (NPPF). Paragraph 35 confirms that Plans are sound if they are positively prepared, justified, effective, and consistent with national policy. The PSLP is supported by an evidence base that includes a number of technical studies. These representations give regard to both the Pre-Submission Document and these studies. The following section of these representations provide comment on draft policies, with particular regard to Policy E12, and other supporting text relevant to the proposed allocation at Childerditch Industrial Estate. Our client's overall position is one of firm support for the PSLP and this is expressed where relevant in these representations. Where concerns are raised in respect of PSLP or its evidence base, specific changes will be noted to assist Brentwood Borough Council in ensuring that the Plan is sound. Regulation 19 Consultation Pre-Submission Document Section 3: Spatial Strategy - Vision and Strategic Objectives: The PSLP sets out the overarching aims of the Spatial Strategy, which includes an emphasis on 'Transit-orientated Growth'. This identifies two key transit corridors, including the 'Southern Brentwood Growth Corridor'. The PSLP focuses growth on land within the Borough's transport corridors, with strategic allocations along the A127 corridor for employment, which is justified given the aims and objectives of the Plan. The Council's strategy to direct development growth to the Borough's transport corridors is supported and has potential to provide for employment growth in locations where there is strong market demand, and to minimise environmental impacts on the wider Borough. The proposed allocation at Childerditch Industrial Estate will assist in meeting this objective, by bringing forward new business and employment opportunities along the A127 corridor. It will help support the planned residential growth within Borough. The Plan has been positively prepared in this respect. The Strategic Objectives identified within Section 3 of the PSLP are supported. Economic prosperity forms a key part of the objectives. In order to be considered sound, it is important the Plan is consistent with national policy, which seeks to enable the delivery of sustainable development. Strategic Objective SO1 seeks to direct development to the most sustainable locations and this links to the proposed allocation at Childerditch Industrial Estate. Strategic Objective SO3 supports opportunities that respond to the changing economic climate. Childerditch Industrial Estate is a traditional industrial estate that has developed over many years, as illustrated in the indicative proposed masterplan prepared by CMP Architects. It provides a mixture of B1, B2 and B8 uses across the site. The Estate will offer opportunities for a range of businesses seeking new premises within a highly sustainable location, which the A127 corridor offers through the proposed allocations. The indicative proposed masterplan sets out how the proposed allocation would allow for the redevelopment of the Estate and how this could come forward through a series of phased developments. This will be able to offer a number of units of varying sizes that would be suitable to a range of businesses, responding to the economic climate. The work undertaken by CMP Architects demonstrates how the Estate can be more efficiently and effectively developed, by providing a modern range of units for B1, B2 and B8 uses and associated infrastructure. Figure 3.1: Key Diagram: Figure 3.1 provides a visual aid in support of the Spatial Strategy. It identifies Junction 29 of the M25 as a key location for 'Employment-led development' (Brentwood Enterprise Park) and Childerditch Industrial Estate as a location for new 'Employment land', in addition to the strategic housing-led development at Dunton Hills and the redevelopment of West Horndon. A focus on employment growth along the A127 corridor will reduce the need for additional employment sites in less sustainable locations elsewhere in the Borough. This approach is fully supported and recognizes the importance of this location for new employment opportunities. This approach is justified and demonstrates that the Plan is consistent with national policy in this respect. Section 5: Resilient Built Environment: Policy BE11: Strategic Transport Infrastructure: We support part C of Policy BE11, which states that the Council will continue to work with the Highway Authority, statutory bodies and key stakeholders to deliver improvements to the ensure highway infrastructure capacity is maintained. Any future planning applications to be submitted in respect of new development at Childerditch Industrial Estate will be accompanied by the relevant transport studies. Paragraph 5.105: Paragraph 5.105 states that, within the South Brentwood Growth Corridor, there is a recognition that provision of sustainable transport in this area is poor. Since the Draft Local Plan Regulation 18 Consultation, the Council has published an Infrastructure Delivery Plan (IDP) for the Borough. This includes, at Figure 3.14 of Chapter 3, a sustainable transport plan for the Southern Growth Corridor, which includes indicative locations for new cycle ways and a new bus route to connect Childerditch Industrial Estate, Brentwood Enterprise Park, Dunton Hills Garden Village and West Horndon Industrial Estate (to be redeveloped). We support the principle of improving walking and cycling links within the land owned by our client, which extends to Little Warley Hall Lane. However, we would question the extent to which these new cycle ways could be delivered along the A127 corridor, as this would require every land owner to be committed to this initiative and an identification of funding. It is also not clear within the IDP who would be responsible for delivering this infrastructure improvement i.e. would this be the responsibility of Essex County Council, Brentwood Borough Council or landowners. This point needs to be clarified. In respect of the new bus route loop that is shown within the IDP at Childerditch Industrial Estate, whilst our client broadly supports the principle of a bus service at the Estate, they consider that the circulatory route shown within the IDP is too prescriptive and misleading, and at this stage, a broad arrow would be sufficient within the IDP. Details of how the Estate could be served can be dealt with as part of the iterative masterplan process. If a bus service from the A127 were to drop off/pick up were to be brought forward, our client could support this if the bus were to stop outside the Estate, turn and move back down Childerditch Hall Drive. Section 7: Prosperous Communities: This section of the PSLP confirms Brentwood Borough Council's Economic Strategy, which includes a number of Economic Aims and Strategic Priorities. These will help facilitate sustainable development, which is required to ensure that the Plan is sound. Paragraph 7.1 of the Plan recognises the importance of the Borough as being a high-quality environment within close proximity to London. The economic aims include the desire to encourage high value, diverse, employment uses that will provide a significant number of skilled and high-quality jobs; and to encourage the better utilisation, upgrading and redevelopment of existing land and buildings. These aims are supported and are reflected in the indicative proposed masterplan accompanying these representations. Childerditch Industrial Estate has a unique employment offer, insofar as it comprises a range of B1, B2 and B8 employment uses and storage yards. The proposed allocation provides the opportunity to build on the success of the Estate, by creating additional employment opportunities with a range of businesses. The proposed allocations will also enable the upgrading of the existing units on site through increased investment. The accompanying indicative proposed masterplan prepared by CMP Architects sets out how the redevelopment of the Estate could come forward through a series of phased developments. The development of The Range North (previously identified as site 112D in the Regulation 18 Consultation) as a first phase will assist with the provision of funding to begin the process of upgrading the existing units and infrastructure at the Estate, and provide for the ability for reinvestment to develop the proposed southern extension (previously identified as site 112E in the Regulation 18 Consultation). This redevelopment would ensure compliance with the Economic Aims of the PSLP. In addition to the Economic Aims, the PSLP sets out a number of Strategic Priorities. Of these, Strategic Policies P1 and P6 are strongly supported. P1 seeks to support business development and growth. P6 seeks to promote Brentwood Borough as a place to visit and invest, thereby encouraging the visitor economy. Childerditch Industrial Estate would assist in meeting those objectives. Policy PC02: Job Growth and Employment Land In determining the employment land allocations necessary to ensure that an adequate number of jobs can be provided, it is important that the Plan is sufficiently flexible to adapt to rapid change (as required by Paragraph 11 of the NPPF), and that it does so in a manner that ensures that the boundary of the Green Belt will not need to be reviewed before the end of the Plan period (Paragraph 136 of the NPPF refers). As set out within Paragraph 2.54 of the PSLP, 89% of the Borough lies within the Metropolitan Green Belt. There is not sufficient land outside of the Green Belt for the Council to deliver the requisite level of housing and employment land. It is therefore necessary and justified to amend the boundary of the Green Belt as part of the Local Plan process. Paragraph 8.84 of the PSLP refers to the need to release land from the Green Belt in order to achieve the Council's growth strategy. This release has been carefully balanced to ensure that sustainable development can be achieved, whilst ensuring that the longer-term purpose, integrity and benefit of the Green Belt remains intact. We support the Council's approach insofar as our client's land interests are concerned and it is important to ensure that any changes to the Green Belt endure beyond the Plan period, having regard to its intended permanence, as required by Paragraph 136 of the NPPF. The PSLP is informed by an evidence base, including an assessment of the Functional Economic Market Area (FEMA) and the Brentwood Economic Futures 2013-2033 Report. The PSLP suggests a range of growth within the Borough, where at Paragraph 7.19(iv), it is stated that a range from 33.76 hectares to 45.96 hectares will be required. This includes land lost at existing allocations (i.e. at West Horndon). Childerditch Industrial Estate will therefore make a significant and important contribution towards the required land. It is well suited for businesses that may need to relocate as a result of sites that will come out of employment use to provide for housing. It is therefore considered the approach to Policy PC02 is justified in providing for 47.39 hectares of new employment land in excess of the higher forecasts; offering support for existing employment sites and the appropriate redevelopment of sites, to be able to adapt to rapid change and to remove the need for the Green Belt to be reviewed during the Plan period. The PSLP sets out the proposed allocation at Childerditch Industrial Estate can come forward over the next 1 to 10 years. The indicative proposed masterplan prepared by CMP Architects provides an illustrative approach as to how the proposed allocation could come forward in conjunction with the redevelopment of the existing Park. The land is available now and there are no overriding constraints to delivery. The Plan would be justified and effective in this respect. The Brentwood Economic Futures (2013-2033) Final Report sets out 4 scenarios for quantifying the potential requirement for jobs in order to support the growth of the Plan Period. The Report provides indicative job capacity figures, which have been based on assumptions, in terms of both site capacity and B1a/b, B1c/B2, and B8 split. (Refer to table in attached copy of full representation). In respect of Childerditch Industrial Estate however, the Report has not taken into account that the existing Park can be redeveloped in a more efficient and effective manner to provide more job growth, as provided for in these representations. Overall, the proposed allocation will enable the upgrading of the existing units on the site through increased investment. Policy PC03: Employment Land Allocations: Policy PC03 sets out a number of considerations that are intended to relate to existing and proposed employment sites identified in Figure 7.6 of the PSLP. This includes Childerditch Industrial Estate. However, the PSLP also includes a specific policy that relates to Childerditch Industrial Estate (Policy E12, which will be addressed later in these representations). Paragraph 7.23 of the PSLP states that due to the difficulties of accommodating the quantum of employment land within other parts of the Borough, the opportunity has been taken to capitalise on the strategic connections of the South Brentwood Growth Corridor by extending employment land around Childerditch Industrial Estate. This approach is considered to be justified and consistent with national policy, as the proposed allocation seeks to make efficient use of an existing, highly sustainable employment site. Proposed Modification: It is considered that greater clarification should be added to Paragraph 7.23, Part b. ii. on where Policy PC03 applies, as Policy E12 covers the entirety of Childerditch Industrial Estate. It should be added that the proposed allocation at Childerditch Industrial Estate allows for the redevelopment of the existing Estate and new development on the extended areas, which will provide a location for employment generating sui generis uses, as provided for by Policy E12. Policy PC05: Employment Development Criteria: Policy PC05 does not specify whether it applies to existing and/or new employment land. The policy simply refers to development for employment uses. The wording of Policy PC05 is therefore ambiguous and is more restrictive than the site specific policy for Childerditch Industrial Estate (Policy E12). For example, Policy E12 requires provision to be made for improved walking and cycling links within the surrounding area. Policy PC05 on the other hand states that employment uses will be encouraged provided that the proposal is accessible by public transport. At present, there are no public transport connections directly available to Childerditch Industrial Estate, and whilst this may change in the future, there is no guarantee of if and when this will happen. On this basis, we object to Policy PC05 in its current form as it would not allow for an effective Plan. Proposed Modification to Policy PC05: It is suggested that Policy PC05, Part A. a. be amended to state that proposals provide opportunities to be accessible by public transport, walking and cycling. At Childerditch Industrial Estate, opportunities are limited to provide public transport; however, in bringing forward proposals for the site, this issue can be reviewed with Brentwood Borough Council and Essex County Council. Section 8: Natural Environment Policy NE9: Green Belt: Policy NE9 is supported. The Council has recognised the need to release some land from the Green Belt in order to meet its housing and employment needs. However, the land that will remain within the Green Belt should be protected throughout the Plan period and Policy NE9 achieves this, in accordance with the NPPF. Policy NE13: Site Allocations in the Green Belt: It is considered that Policy NE13 should be removed from the PSLP. The criteria of the policy can be included other policies, such as the site specific policy for Childerditch Industrial Estate (Policy E12), and it is therefore not considered necessary to have a standalone policy duplicating these points. Furthermore, it is queried why the policy refers to the benefits of housing sites only and no other land uses. Section 9: Site Allocations Policy E12: Childerditch Industrial Estate: Policy E12 is supported. We consider that it is justified, effective, consistent with national policy and necessary for the reasons set out elsewhere in these representations. Policy E12 proposes to allocate land that has previously been promoted at the Range North (site 112D) and the land to the south (site 112E), in addition to the existing Childerditch Industrial Estate, to provide a total developable area of 20.64 hectares across the entire Estate. The release of these sites from the Green Belt is justified and will ensure that the Plan has been positively prepared. At present, Childerditch Industrial Estate offers some 35 units. As part of the work supporting these representations, CMP Architects have undertaken an analysis of the Estate to identify how the existing Park could be regenerated for existing occupiers, redeveloped in areas to maximise efficiency, and expanded for future employment growth demand. The proposed masterplan at Appendix 1 provided for indicative purposes to support these representations, demonstrates the deliverability of the site over a period of time. The proposed allocations will extend the size of the Estate and as a whole, it is considered that it has the potential to accommodate around 50 units following redevelopment. The development of The Range North (site 112D) as a first phase will assist with the provision of funding to begin the process of upgrading the existing units and infrastructure at the Estate, which will ultimately lead to the development of the southern extension. This infrastructure will include an improved primary route through the core of the site and a number of secondary routes stemming from this to provide access to the different areas of the site. In addition to the work undertaken by CMP Architects, an Access Appraisal is submitted with these representations. The Appraisal at Appendix 2 confirms that the proposed allocation is deliverable in the context of the existing and proposed highway infrastructure, and will not have a significant impact on the efficiency or safety of the local transport network. The Appraisal also confirms that cumulatively, the allocation can be accommodated with other employment allocations along the A127 corridor, including those at Brentwood Enterprise Park and Codham Hall Farm. The PSLP, at Appendix 2, confirms a delivery forecast of 1 to 10 years. Following the adoption of the Local Plan and confirmation that the proposed allocations at Childerditch Industrial Estate are removed from the Green Belt, a planning application supported by a package of technical information will be submitted to Brentwood Borough Council for the first phase of development at The Range North. Further applications will then follow for the subsequent phases. It is very much expected that development will commence on site within the first few years of the Plan period, given the known demand as referred to at Paragraph 1.4 of these representations. We are in agreement that the entirety of the proposed allocations will be delivered within the 10 year period, which will ensure that the Plan is effective. Our clients purchased the site in 1983 and have a long term investment in the site and a desire to deliver the proposed allocations and enhancements to the existing site, as shown in the indicative proposed masterplan. In respect of Part B, criterion b) of Policy E12, we support the principle of improving walking and cycling links within the land owned by our client, which extends to Little Warley Hall Lane. However, we object to Part B, criterion c) of Policy E12, as it is not considered to be necessary. The Access Appraisal copied at Appendix 2 does not identify a need to improve the junction where the A127 meets Childerditch Hall Drive. The Access Appraisal confirms that the additional traffic created by the proposed allocation will not have an impact on the A127 junction because due to the length of the access from the A127, vehicles will not be delayed on entry. On exit from Childerditch Hall Drive onto the A127, any queuing will be held on site and therefore the increase in vehicles will not have an impact on the A127. Proposed Amendment to Policy E12: In light of the comments set out in the above paragraph, Part B, criterion b) should be removed from Policy E12. Sustainability Appraisal: A Sustainability Appraisal (SA), published in January 2019, has been produced by AECOM on behalf of Brentwood Borough Council in support of the PSLP. The SA forms only one part of the evidence base underlining the PSLP. The evidence base also includes documents such as the Brentwood Economic Futures 2013-2033 Report, Green Belt Study and Transport Assessment. In allocating additional land at Childerditch Industrial Estate, Brentwood Borough Council has taken a balanced judgement on the site constraints and the need to provide to create additional employment opportunities within the Borough. The SA is currently focused on a spatial approach to the assessment of each criterion, using the distance between the site and various factors to judge the extent to which it either achieves certain objectives or not. However, it is considered that the SA fails to fully consider the nature of each proposal or the likelihood in practice of effects in sustainability terms, where a 'broad brush' approach has instead been taken to sites regardless of their intended use. For example, in respect of distance to a GP Practice, the proposed employment allocations at Childerditch Industrial Estate have been scored in the same manner as a residential allocation. However, it is considered to be less important for an employment site to be located within close proximity to a GP practice than a residential site, given the nature of the uses. Therefore, Childerditch Industrial Estate should be considered against a different set of criteria more relevant to the proposed employment allocation. Provided below is an extract from the SA showing the scoring for the proposed allocations at Childerditch Industrial Estate. The proposed allocation includes Sites 112A, 112D and 112E. Site 112A relates to the existing allocation at the Estate. Site 112D relates to the proposed allocation at The Range North, and site 112E relates to the proposed southern extension allocation. (Refer to table in attached representation). On review of the appraisal of Childerditch Industrial Estate, the site has not scored particularly well in relation to the criteria that has data available. However, it is considered that the SA, or at least the sustainability criteria, could be too sensitive when it comes to assessing sites against the criteria. The fact that no site performed 'particularly well' against any of the criteria suggests that the scope of the assessment makes many sites appear unsustainable, with limited opportunity to score 'green' in many of the objectives. The NPPF, at paragraph 81, states that the Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Paragraph 16 of the NPPF states that Local Plans must be prepared with the objective of contributing to the achievement of sustainable development. Paragraph 17 further adds that Local Plans should include strategic policies to deliver the homes and jobs needed in the area. Childerditch Industrial Estate is within a highly sustainable location, with excellent transport links in the form of the A127 and M25, which is a significant benefit to the occupiers of the site. The Estate is a successful employment site and the PSLP process provides a pragmatic response to the opportunity to build upon this success with further land being allocated. Indeed, as outlined above, the Council's own Spatial Strategy includes an emphasis on 'Transit-orientated Growth', which provides for new development along two key transit corridors in the Borough, including the Southern Brentwood Growth Corridor. It is noted that sites 112A, 112D and 112E are presently scored 'amber' (performs poorly) under the Green Belt criterion. We do not consider that this aspect has been considered in sufficient detail by the SA given the particular circumstances of the site and existing uses. Childerditch Industrial Estate is visually contained by the surrounding agricultural land. We note that within the Green Belt Study Part II: Green Belt Parcel Definition and Review Document updated in November 2018, Green Belt Parcel 20, which the Childerditch Industrial Estate is excluded from, has been scored as making a moderate contribution to Green Belt purposes. As the existing site (112A) is excluded from the Green Belt, it is considered that this site should instead be considered to have 'no issue' in the SA assessment. There would be no loss of Green Belt land that would otherwise meet established purposes. The Green Belt Study recognises that the primary land use within the Parcel is arable farmland, but that the secondary land use is an industrial estate (Childerditch) set within the Parcel. The Estate is an 'island site' excluded from this Green Belt Parcel. The Study considers that views across the Parcel are limited, where field boundaries with dense hedgerows reduce visibility. Whilst the Study considers that undulating fields facilitate some views from the north, it is considered that views of Childerditch Industrial Estate will be limited from the north. The northern portion of the site is constrained by its topography, with some significant level changes and mature landscaping screening the existing buildings within the Estate. The northern most section of the Estate is only used as open storage and is also screened by existing woodland. These areas of the Estate form part of the existing allocation in any instance. The work undertaken by CMP Architects has given consideration to wider views of the Estate. The proposed allocations at sites 112D and 112E are currently located within the Green Belt. However, as part of the Council's review of the Local Plan, the opportunity exists to review Green Belt boundaries, in accordance with paragraphs 138 and 139 of the NPPF. At paragraph 138 of the NPPF for example, it states that, when drawing up or reviewing Green Belt boundaries, local planning authorities should take account of the need to promote sustainable patterns of development. As part of the new Local Plan, the fringes of the existing Childerditch Industrial Estate can be released to provide a necessary and important contribution to employment land within the Borough within a highly sustainable location. Furthermore, it is considered that the areas proposed for allocation, adjacent to an existing employment site, are sequentially more appropriate than other sites in the Borough that currently have no employment use. This supports the Council's growth strategy, which requires land to be released from the Green Belt, and is therefore justified. The release of land has therefore been carefully considered taking all factors into account, to ensure that sustainable development can be achieved, whilst ensuring that the longer-term purpose, integrity and benefit of the Green Belt remains intact. The Childerditch Industrial Estate sites have additionally been scored 'amber' with regard to effect on agricultural land, with the methodology stating that any site in land classified as Grade 3 will be 'amber' and Grade 2 will be 'red'. While the assessment notes that the dataset used is of poor resolution, the assessment has failed to adequately consider the existing nature of the sites (with particular regard to site 112D), as well as differentiate between Grades 3a and 3b. We would consider that the criteria should be amended to be more in line with the aims of Government policy, and that the sites be assessed on the basis of whether their use for employment purposes would lead to the loss of the best of the best and most versatile land. Furthermore, if the locally defined employment requirement is to be met, building on agricultural land is necessary. The fact that no site performed 'particularly well' (scoring 'dark green') in any of the criteria, also suggests that the scope of the assessment was not sensitive to acknowledge the competing objectives of national and local policy, particularly that in the Green Belt, to meet needs for employment and other development. Ultimately, it is important to note that the SA, at paragraph 9.6.6 states that "... there is a strategic opportunity to develop the A127 corridor as an employment growth corridor, capitalising on connections to key economic centres in the region (including Tilbury Port, Southend Airport and those in Greater London). All sites will have good or excellent access onto the strategic highway network". Furthermore, at paragraph 9.6.7, it is stated that "... With regards to site specific policy, the policies for the four employment should support timely and effective delivery". We support this view and will continue to take a proactive approach regarding promotion of and extension to Childerditch Industrial Estate through to the adoption of the new Local Plan, including attending the relevant Hearing Sessions at the Examination in Public. Summary: The PSLP confirms that the Spatial Strategy substantially focuses on 'Transit-orientated growth', including the Southern Brentwood Growth Corridor, with strategic allocations along the A127 corridor for employment, which is supported. The proposed allocation at Childerditch Industrial Estate is a recognition of the role that the Estate has in providing employment for the Borough. The proposed allocation would assist in meeting Brentwood Borough Council's identified need, to provide employment land required to assist meeting the Strategic Objectives of the PSLP Plan for the Plan period. The Estate is ideally located along the A127 to provide excellent transport links for the businesses operating at the Estate, and this is reflected in the full occupation rate of the existing units. There is a strong market for additional units in this location. The proposed allocations at The Range North and the southern extension will provide additional land to build on the success of the existing Estate. This submission demonstrates how the Estate can be more efficiently and effectively developed, by providing a modern range of units for B1, B2 and B8 uses and associated infrastructure. In conclusion, we strongly support the proposed allocation at Childerditch Industrial Estate, as set out in the PSLP, and will continue to promote the Estate as the Plan progresses to Examination in Public, in consultation with Brentwood Borough Council and key stakeholders. We consider that the Plan is generally sound; however, we do object to two policies in their current form. These are Policies PC05 and E12, as set out at paragraphs 2.23 - 2.25 and 2.34 - 2.35 of these representations. However, within these representations, we have also set out suggested amendments to these policies that we consider would make the plan sound.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The use of brownfield sites to build a modest amount of houses would be much more acceptable to most people in the local areas.
DO NOT build on Green Belt or Green Field sites for the good of the environment and wildlife. [Remove sites R25 and R26 from plan].

The building of the proposed houses is totally unacceptable in this village. There doesnt seem to be any thought given to the local area. Especially with regard to local infrastructure i.e. schools, doctors surgery, shops The existing traffic is getting so heavy there will be an accident soon. Parking has become a nightmare and parking on the pavement seems to be the done thing.
Getting a doctors appointment is very difficult and the school is already full. Green Belt land should not be used for building houses. Redrose Lane is what it sound, a lane and 2 cars passing is not an option.
The use of brownfield sites to build a modest amount of houses would be much more acceptable to most people in the local areas.
DO NOT build on Green Belt or Green Field sites for the good of the environment and wildlife.

The only practical solution is to remove sites R25 and R26. Take heed of the BVHA neighbourhood plan which identifies the actual requirement of local residents and proposes better suited alternative sites.

The plan is unsound.
Infrastructure already fails local needs: flood risk, school and doctors surgery at over capacity & struggle to cope, poor (virtually non existent) bus service, roads not suitable, insufficient parking in village centre.
BBC has not consulted with neighbouring authorities (ie: Epping and Chelmsford). Sites mentioned not suitable, Alternative sites (that are better suited have been ignored. There has been no "housing needs" survey.
The only practical solution is to remove sites R25 and R26. Take heed of the BVHA neighbourhood plan which identifies the actual requirement of local residents and proposes better suited alternative sites.

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

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

Sites R25 and R26 need to be removed from the plan. I suggest the lanners need to read the BVHA neighbourhood plan which includes the Blackmore local housing requirements for what is clearly an existing sustainable community.

Sections 04 08 09
Policy R25 nd R26

As far as I am aware no "housing needs survey" has been performed to show why Blackmore is included in the LDP. Blackmore is an established village and it would appear that an increase in demand on the infrastructure is not viable. I understand that the village school s full and the Deal Tree medical centre is reported to have one of the highest patient to practitioner rations in certainly Essex.
The access onto and off Red Rose Lane will not be suitable for the anticipated increase in traffic.
The sites R25 and R26 have over the years suffered from persistent flooding.
I believe that around 30 houses are being or will be constructed at the top of Fingrith Hall Lane.
Sites R25 and R26 need to be removed from the plan.
I suggest the planners need to read the BVHA neighbourhood plan which includes the Blackmore local housing requirements for what is clearly an existing sustainable community.
The items I have referred to in my response were patently inadequately discussed in the prematurely shortened meeting chaired by the Mayor.

Brentwood Council to read and discuss the plan in the correct manner not treat it as a foregone conclusion because of a cut off time. This procedure should not be allowed at such an important meeting, It was disgraceful what they did its not the first time they have done wrong at a planning meeting and they should be ashamed of their behaviour and attitude. What they did was undemocratic to say the least. They should reopen this file and study the evidence and discuss the findings.
We should have a legal hearing in public which we were denied.

The plan is unsound because it does not take into consideration the Green Belt, the lack of infrastructure here it just feels like they have stuck a pin in a map and said that will do.
Blackmore is a Historical Village according to some Cllrs, one of the jewels in the crown of Brentwood. Sharing the title with South Weald. We are not within walking distance of any doctors, the only Hospital we have is Brentwood which has no casualty now, a blood test which is urgent the nearest hospital is a twenty mile round trip eg Basildon, Southend, Romford. We have one bus an hour.
South Weald is close to Brentwood nearer to all senior schools and junior, easily walkable to the town and station, more buses and close to the M25 yet the land there has been withdrawn from the plan this does not make sense. We are not nimbyist it is just common sense to build closer to the town,
Our sewerage is pumped nobody seems to care whether the station can cope. All we are told is this will be sorted by the developers. Our school is at bursting point yet we are told maybe there will be some 106 agreement money come our way. This school has been under developed since the 80's my daughter was in the relocatables list and she is about to become a Granny. The extension was never built.
Flooding is another hazard Brentwood chooses to ignore. This village has been Badly flooded several times. The current when this happened is very strong, damage serious and life threatening but BBC are not interested.
Brentwood Council to read and discuss the plan in the correct manner not treat it as a foregone conclusion because of a cut off time. This procedure should not be allowed at such an important meeting, It was disgraceful what they did its not the first time they have done wrong at a planning meeting and they should be ashamed of their behaviour and attitude. What they did was undemocratic to say the least. They should reopen this file and study the evidence and discuss the findings.
We should have a legal hearing in public which we were denied.
I know my village and Brentwood I have lived in Brentwood for 75 years, in Blackmore nearly 48. I was part of the rescue team in the village floods as was my son. I was the village postie for 20 years out in all weather and have a good knowledge of the village and its needs. I did doctors and hospital runs for the elderly, shopped for them and often stayed all night when they were ill or bereaved, that's what you do.
This is a great village but it will not cope with another mass of houses building on this piece of Green Belt will only encourage more farmers to sell once they cross the line this village will spread. BBC have broken the Green Belt rules.
We need these fields Britain is an island in times of trouble we have needed every bit of land we had or we could not have survived.

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

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

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

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

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

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

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

Policy NE13

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


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

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

Proposed modifications

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

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

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

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

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

Policy NE13

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

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

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

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

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

Policy NE13

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

Remove R25 and R26 from plan

Section 04
Section 08
Section 09
Policy R25
Policy R26
Doctors. The project needs to be cancelled because having more houses and people in Blackmore will have an effect on the local Doctors surgery, it is already busy and difficult to get appointments so more people will affect our health.
School. The local school is a small village school so more children attending will mean the school needing to be expanded and made bigger and there is no area for this to be done.
Green Belt Land. The area the houses are being built on Green Belt land so the beautiful village will become overcrowded and the countryside ruined, so it affects all the local wildlife and wild animals too.
Local transport - buses transport. There would be a need for more buses and local transport and this means roads where there are no footpaths will become dangerous for local residents and the council having to provide more services and the area becoming dangerous as its only a small village with roads being able to cope with a small amount of traffic so it will be dangerous on the footpaths and the roads.

A residential development such as has been submitted for Blackmore will further stretch infrastructure (roads, parking, schooling, doctors, etc). There are more sustainable locations in the borough. There are "brown field" sites available which should be prioritised over green field sites. This area of Blackmore is known to be a flood risk (23 June 2016).

Section 04
Section 08 - especially Re: Green Belt and Flood Risk
Section 09 Policy R25, Policy R26
A residential development such as has been submitted for Blackmore will further stretch infrastructure (roads, parking, schooling, doctors, etc). There are more sustainable locations in the borough. There are "brown field" sites available which should be prioritised over green field sites. This area of Blackmore is known to be a flood risk (23 June 2016). Do not believe Green Belt land in Blackmore should be released for this development as part of BBC local plan due to all aforementioned reasons (and probably many others!)

Cancel the project. Blackmore and its environs are already in danger of forever being changed. There are plenty of other brownfield sites in Brentwood to consider, we have already had our fair share of new builds in Brentwood.

Section 04
Section 08
Section 09
Policy R25,
Policy R26

unsound and all unsound ticked.
Local services being overwhelmed: schools; doctors; transportation hubs; more crime ie: not enough police; more demand on firefighters. More cars on road leading to very dangerous conditions for young children on footpaths.

Cancel the project. Blackmore and its environs are already in danger of forever being changed. There are plenty of other brownfield sites in Brentwood to consider, we have already had our fair share of new builds in Brentwood.

Yes attend
It is important as many local views are expressed to allow the proponents of this plan to gauge the strength of local opinion.

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

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

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

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

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

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

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

Section 4
Policy SP01
Policy SP02
Policy SP03

Section 07
Policy PC 14

Section 08
Policy NE06
Policy NE13

Section 09
Policy R25
Policy R26


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

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

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