POLICY R25: LAND NORTH OF WOOLLARD WAY

Showing comments and forms 1 to 30 of 1016

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22178

Received: 06/02/2019

Respondent: Mr. Chris Hamilton

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

Plot is frequently flooded and so are the houses adjacent to the field. Houses built on the field are very likely to flood themselves but it will have a knock on effect on the surrounding houses due to the reduced natural ground area.
The roads on Nine Ashes road near junction with Red Rose Lane are very busy around school time so development will only make this worse.
Since this LDP was published representatives of Stondon Massey have actively sought development on a site they have highlighted in order to sustain their village. This clearly seems like an obvious solution.

Change suggested by respondent:

Alternative sights should be found. Stondon Massey is the obvious one as their local representatives have said they actually want building their to keep their village sustainable.

Full text:

Plot is frequently flooded and so are the houses adjacent to the field. Houses built on the field are very likely to flood themselves but it will have a knock on effect on the surrounding houses due to the reduced natural ground area.
The roads on Nine Ashes road near junction with Red Rose Lane are very busy around school time so development will only make this worse.
Since this LDP was published representatives of Stondon Massey have actively sought development on a site they have highlighted in order to sustain their village. This clearly seems like an obvious solution.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22189

Received: 03/03/2019

Respondent: Mrs Helen Whalley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Brentwood Council has not stated what planning principle is being used to allocate the development of the Villages in the north of the borough. There are several rural communities and I am concerned that Blackmore is being allocated more than its fair share of new housing which will change the rural character of the village Section 2.10 of the Settlement Hierarchy chapter of the LDP states 'Development should be appropriate to the rural setting of the area.'

Change suggested by respondent:

A clear, fair and evidence based strategy to be stated for the allocation of new housing in Villages in the north of the borough

Full text:

Brentwood Council has not stated what planning principle is being used to allocate the development of the Villages in the north of the borough. There are several rural communities and I am concerned that Blackmore is being allocated more than its fair share of new housing which will change the rural character of the village Section 2.10 of the Settlement Hierarchy chapter of the LDP states 'Development should be appropriate to the rural setting of the area.'

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22190

Received: 03/03/2019

Respondent: Mrs Helen Whalley

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The development of around 30 houses at the top of Fingrith Hall Lane is within Epping Forest District Council area but close to Blackmore and will impact services and infrastructure. Consultation between the two boroughs has not taken place.
Developing the greenbelt beyond the edge of Blackmore village is not appropriate to the rural setting of the area. It will change the rural nature of the village. This development will increase pressure on already stretched infrastructure and services; limited buses, one shop, drainage at capacity, Doctors with no non-emergency appointments, traffic and parking a problem, no places in local School.

Change suggested by respondent:

Take account of nearby development in Epping Forest District.
Consult with Epping Forest District Council on housing development.
Protect the rural nature of Blackmore village.
Avoid further impact on stretched village services and infrastructure.

Full text:

This site is close to the current development of around 30 houses at the A414 end of Fingrith Hall Lane. That development is within the Epping Forest District Council area but is closer to Blackmore than other villages and will impact on housing, the doctors' surgery, Blackmore school, drainage and traffic. Consultation between the two boroughs on this development has not taken place. The number of houses there must be taken into account in any proposal to build housing in Blackmore as they will have an impact on the village and hence on the LDP.
Developing the greenbelt land beyond the edge of Blackmore village is not appropriate to the rural setting of the area. It will change the rural nature of the village. Section 2.10 of the LDP states that 'Development should be appropriate to the rural setting of the area'.
This development will increase the pressure on already stretched infrastructure and services. This small village has a limited bus service, one shop that also serves as post office, drainage at full capacity, a Doctors' surgery where, at the time of writing, there are no non-emergency appointments available (for the next 6 weeks), and where traffic and parking in the centre of the village are already a problem. Blackmore Primary School is full and recent new residents have had to send their children to Doddinghurst school.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22202

Received: 10/03/2019

Respondent: Mr Anthony Cross

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Inclusion of site allocations R25 and R26 in the LDP are inappropriate, unsound and not compliant with legal requirements on the following grounds:
failure to prove that more suitable (brownfield) sites do not exist in the borough, or that other site allocations couldn't absorb the 70 dwellings proposed;
inadequate consultation with EppingForestDistrictCouncil and failure to properly consider the impact of other nearby developments on Blackmore;
failure to recognise the increased flood risk resulting from the proposed development;
adverse impact on roads, noise levels and safety of existing road users from increased traffic;
inadequate local amenities/services; other considerations per full representation.

Change suggested by respondent:

Removal of proposed developments R25 and R26 from the plan and reallocation of the 70 dwellings to more suitable brownfield sites in the borough.

Full text:

I object to the inclusion of the proposed developments R25 and R26 on the grounds the Local Plan is not legally compliant, nor sound (on the basis that it is unjustified and inconsistent with national policy) and does not comply with the duty to Co-operate for the reasons set out below.

Inclusion of proposed developments R25 and R26 contravenes the requirements of the National Planning Policy Framework as follows:
(i) Contravenes para 77, in-so-far-as in relation to the proposed developments R25 and R26, local needs have not been formally identified and considered. Indeed Brentwood Borough Council representatives conceded during a meeting with Blackmore Parish residents on 31/01/19 that the proposals were developer led; a wholly inappropriate method of site selection.
(ii) Given the building of homes on the village boundary within the Borough of Epping Forest (at the ex-Norton Heath Equestrian Centre and in Nine Ashes), and the importance of sites R25 and R26 in their current state to the village community, serious consideration should be given to these being designated as Local Green Space in accordance with para 99 and 100, instead of being allocated to housing which would impair the beauty, historic significance, tranquillity and richness of wildlife of these sites in close proximity to the village centre.
(iii) Contravenes para 108 as the historic Red Rose Lane does not allow for safe and suitable access to the proposed sites R25 and R26, and the resulting adverse impact on highway safety would be unacceptable.
(iv) Contravenes para 118(b) as the proposed developments R25 and R26 fail to recognise the importance this currently undeveloped land has on village flood risk mitigation, carbon storage and potential alternative use for food production.
(v) Contravenes para 118(c) as the proposed developments R25 and R26 on greenfield (and Green Belt) land would not be required if the council gave the necessary substantial weight to the value of using available brownfield land within the borough. The council has not demonstrated that there are no brownfield sites available within the borough that would (and should) take priority for development over the greenfield land off of Red Rose Lane.
(vi) Contravenes para 133 as the proposed developments R25 and R26 fails to recognise the great importance that the Government attaches to the Green Belt.
(vii) Contravenes para 134 (c) and (d) as the proposed developments R25 and R26 encroach upon the countryside and harm the setting and special character of the village of Blackmore.
(viii) Para 136 states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified. This bar has not been achieved with regards to the proposed developments R25 and R26 on greenfield / village Green Belt land. No exceptional circumstances exist, as alternative, more suitable locations for housing, which do not encroach on greenfield or Green Belt land, exist elsewhere within the Borough.
(ix) With alternative brownfield sites available, and/or it being possible to accommodate the number of proposed houses within other proposed developments within the LDP, the council has not demonstrated that it has examined fully all other reasonable options which are required to justify changes to the Green Belt, so has contravened para 137(a). The council has failed to demonstrate that is has examined fully all other reasonable options for the building of 70 houses on greenfield / village Green Belt land (which the proposed developments R25 and R26 would result in).
(x) The changes to the village Green Belt boundary that would result from the proposed developments R25 and R26, has failed to be informed by adequate consultation with neighbouring authorities (a requirement of para 137(c)), as it does not recognise the development that has recently occurred on the village boundary at Nine Ashes, nor the current development underway on the village boundary at the ex-Norton Heath Equestrian Centre (both falling within the Epping Forest District), which will adversely affect traffic levels and road safety in the village of Blackmore as well as lead to further over-subscription at the village primary school and over-capacity at the local doctors surgery.
(xi) Contravenes para 138 as the proposed developments R25 and R26 are not well-served by public transport; also they are located on greenfield / village Green Belt land and insufficient consideration has been given to identify previously-developed land.
(xii) Contravenes para 140 as the proposed developments R25 and R26 are situated in a village (Blackmore) on greenfield land and the open character of the village makes an important contribution rural setting. The council have until only recently treated as Blackmore as "unsuitable" for development for this reason.
(xiii) Contravenes para 141 as the council has not planned positively to enhance the beneficial use of the greenfield / village Green Belt land upon which the proposed developments R25 and R26 are situated.
(xiv) Contravenes para 143 as the proposed developments R25 and R26 are inappropriate (given their size, scope and impact on the character of the village and the adverse impact on the natural environment, road safety, road noise and essential services), so by definition, harmful to the village Green Belt and should not have been approved. The "very special circumstances" exemption has not been proven, or met, by the council.
(xv) Contravenes para 144 as insufficient weight has been given to the harm that would be caused to the village Green Belt from the proposed developments R25 and R26. The council have not demonstrated that other considerations outweigh the potential harm to the village Green Belt by reason of inappropriateness or any other harm resulting from the proposals, so have failed to meet the "very special circumstances" test.
(xvi)Contravenes para 145 as the proposed developments R25 and R26 are inappropriate as they would require the construction of new buildings in the village Green Belt and the listed exceptions do not apply:
(a) the proposed buildings are not agriculture / forestry;
(b) the proposals are not for the provision of appropriate facilities;
(c) the proposals are not for the extension or alteration of an existing building;
(d) the proposals are not for the replacement of an existing building;
(e) the proposals are not for the limited infilling in villages, as the sites are on the edge of the existing built-up area which only borders one side of the sites, so do not meet the "infilling" definition and the scale of the proposals (70 new houses) represents more than 20% increase in the number of village properties, so cannot be described as "limited".
(f) the proposals are not for limited affordable housing for local community needs, as this need has not been formally assessed; also the council have inappropriately passed a motion that would allow up to 75% of the properties built on the proposed sites to be sold to those other than local people (indeed the other 25% are reserved for "local people or those over 50 years of age", so there is no guarantee that any would be allocated to local community needs).
(g) the proposals are not limited infilling (as stated under (e) above), nor the partial or complete redevelopment of previously developed land.
(xvii) Contravenes para 149 and 150 as the proposed developments R25 and R26 would reduce the future resilience of Blackmore to climate change impacts and increase the vulnerability of the historic centre of Blackmore to further severe flooding, due to the loss of natural drainage / absorption of rainfall provided by the greenfield land that currently exist on these sites. The proposed developments R25 and R26 would also result in the loss of a natural carbon sink that currently helps absorb carbon dioxide (a key contributor to climate change) from the atmosphere.
(xviii) Contravenes para 155 through to 163, as the council has not taken into proper consideration the history of flooding in the historic village of Blackmore and the adverse impact that the proposed developments R25 and R26 would have on the future likelihood of further such flooding.
(xix) Contravenes para 170(b) as the proposed developments R25 and R26 demonstrate that the council have failed to take into account the intrinsic character and beauty of the countryside (as alternative brownfield sites exist within the borough that could accommodate the number of houses proposed for these two sites), and the potential benefits that this agricultural suitable land could provide.
(xx) Contravenes para 180(a) as the proposed developments R25 and R26 will add to traffic volumes in and around the village of Blackmore, which for those living directly on one of the main roads in the village (as I do), this increased traffic noise is highly likely to lead to increased sleep deprivation such that it adversely impacts my family's health and quality of life.

Inclusion of proposed developments R25 and R26 contravenes Brentwood Borough Council's own policies as follows:
(i) Contravenes SP01(B) as the proposed developments R25 and R26 will degrade the environmental conditions in the Blackmore area.
(ii) Contravenes SP01(D)(a) as the proposed developments R25 and R26 would harm the character and settlement setting of Blackmore.
(iii) Contravenes SP01(D)(b) as the proposed developments R25 and R26 would have an unacceptable effect on the character appearance of Blackmore as a historic, rural village.
(iv) Contravenes SP01(D)(c) as the access points to the proposed developments R25 and R26 on Red Rose Lane would not provide satisfactory means of access to the site and would endanger vehicles, pedestrians and leisure users (cyclists, horse riders, runners, dog walkers etc.); also insufficient parking exists in the village to accommodate the additional demands on existing village amenities and infrastructure.
(v) Contravenes SP01(D)(d) as the country lanes leading into and out of Blackmore cannot satisfactorily accommodate the additional travel demands generated from the proposed developments (R25 and R26) and would give rise to adverse highway conditions and safety concerns for leisure users (cyclists, horse riders, runners, dog walkers etc.).
(vi) Contravenes SP01(D)(e) as the proposed developments would have an unacceptable effect of health and the environment due to the loss of viable farmland as well as the additional noise pollution and vibration that would be generated from the additional traffic on the roads in and around the village.
(vii) Contravenes SP01(D)(f) as the proposed developments would cause unacceptable effects on village properties and their occupiers through excessive noise and activity arising from the additional vehicle movements that would result on the roads in Blackmore.
(viii) Contravenes SP01(D)(k) as no mitigation for the impact on the already over-subscribed village primary school and over-capacity local doctors surgery is included in proposed developments R25 and R26.
(ix) Inclusion of the rural village of Blackmore within Settlement Category 3, rather than Category 4, appears inappropriate given its sparse setting (given its setting is more remote than, or comparable with Wyatt's Green, Hook End and Stondon Massey) and it having poor public transport, limited shops, jobs and community facilities and it being reliant on nearby settlements for some of its services (doctors, vets, supermarkets etc.).
(x) The council's stated approach to development within Category 3 settlements should be limited to brownfield redevelopment opportunities and limited urban extensions to meet local needs where appropriate, with any development needing to be appropriate to the rural setting of the area. However, the inclusion of the proposed developments R25 and R26 does not comply with these objectives, as they are not on brownfield land, are not "limited", nor "minimal" (together they would represent more than a 20% increase in the number of village properties, so is actually a highly inappropriate large scale development for the village), nor are they for local needs (no formal local needs survey for Blackmore has been undertaken; and the proposed developments are not exclusively for the provision of housing to locals), nor are such large scale developments appropriate to the rural setting (instead they will be detrimental to the rural character of the village and borough).
(xi) Inclusion of the proposed developments R25 and R26 do not meet the council's stated aim of encouraging Brownfield redevelopment opportunities. Such opportunities exist within the parish of Blackmore and elsewhere in the borough, but these opportunities have not been sufficiently explored. This provides further evidence of the selection of sites R25 and R26 being developer-led (as admitted to by representatives of the council's planning team at a meeting with parishioners on 31/01/19), rather than through proper identification, evaluation and assessment by the council, free from undue influence by developers. The development of greenfield land currently occupying sites R25 and R26 would not be required if brownfield sites were appropriately identified and included in the LDP by the council, as required in its own stated policies.
(xii) Inclusion of the proposed developments R25 and R26 contravenes the council's stated aim (section 4.6 of the LDP) of directing development to locations that are supported by effective transport provision, community and other essential services, while minimising harm to the environment and preserving the Green Belt.
(xiii) Inclusion of the proposed developments R25 and R26 contravenes the council's stated requirements (section 4.9 of the LDP) for developments to be capable of being satisfactorily accommodated by the transport network and not give rise to unacceptable highway conditions, safety and amenity concerns.
(xiv) Recognition by the council of the existence of Green Belt land in the borough (per para 4.19 of the LDP) and presumption that such land will be available for development upon adoption of the LDP fails to take into account the importance that the Government attaches to the Green Belt as set out in the National Planning Policy Framework (para 133) and shows the council's intent on building on it without due consideration and without fully evidencing and justifying the exceptional circumstances required before such boundaries can be altered (especially in light of the existence of alternative brownfield sites within the Borough that have not been adequately considered).
(xv) Contravenes SP02(B)(b) as the proposed developments R25 and R26 are not located in transit / growth corridors and Red Rose Lane (the proposed access points) cannot be regarded as "highly accessible" given how narrow they are and also the existence of blind bends and use by cyclists, horse riders, runners, dog walkers etc.
(xvi) Inclusion of the proposed developments R25 and R26 contravenes the council's statement that they have prioritised "growth based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas", as these sites are not situated on brownfield land, but on agriculturally viable greenfield (and village Green Belt) land.
(xvii) Insufficient assessment has been undertaken of the impacts on health and well-being, upon the capacity of existing health and social care services and facilities, and the environmental impacts arising from the proposed developments R25 and R26 (which would add a combined 70 homes to the village). The following factors relating to these proposed developments will adversely affect the physical, social and mental health and well-being of existing Blackmore residents and the Blackmore community: sites are located on greenfield land (within the village Green Belt) which provide green space within the village boundary; the surrounding roads are unsuitable for the extra traffic that would be generated (unsafe for existing car and leisure users of Red Rose Lane and additional noise impacting residents of houses located on the main roads of Blackmore); existing inadequate access to public services (village school is over-subscribed and local doctors surgery is operating over-capacity); and the increased risk of flooding in the historic heart of Blackmore (due to the loss of vital natural drainage / rainfall absorption).
(xviii) Given the combined size of the neighbouring proposed developments R25 and R26 (a combined 70 dwellings) and given their impact on the community and local infrastructure, a full and proper Health Impact Assessment and Environmental Impact Assessment should have been performed prior to the inclusion of these sites in the Local Development Plan.
(xix) Contravenes SP04(A) as the proposed developments R25 and R26 are not supported by, nor have good access to, all necessary infrastructure. Transport infrastructure is inadequate for these developments as well as health provision and schooling infrastructure.
(xx) Contravenes SP04(B) as it has not been demonstrated that adequate mitigating measures have been agreed in respect of the proposed developments R25 and R26.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22244

Received: 11/03/2019

Respondent: Mr Tom Bennett

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Plan unsound - no clear strategy. R25 & R26 previously deemed 'unsuitable for development'

Change suggested by respondent:

Remove the proposals R25 for development in Blackmore village

Full text:

1. Plan unsound - no clear strategy. R25 & R26 previously deemed 'unsuitable for development'

2. No prior consultation with affected residents

3. No Housing needs Survey to assess demand

3. R25 & R26 unsuitable for residential development - flooding, poorly access road, undue strain on services

4. Village already congested in its centre (mainly parking), development will exacerbate problem.

5. Already poor transport links strained further by extra dwellings

6. No account of developments in adjacent boroughs, or evidence of consultation with those Councils

7. No evidence alternative sites (Brownfield/other parishes) has been properly examined. Development appears developer-led.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22254

Received: 14/03/2019

Respondent: mr Steve Whalley

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The building of 40 houses on greenbelt land in the ancient village of Blackmore does not fit with planning policy requirements. This unneeded commercial development will change the nature of the environment and the quality of life that has acted as a pleasant relief to visitors from nearby urban environments. This relief is being eroded by constant development sprawl.

Specifically it is against item 2.10 in the LDP Settlement Hierarchy Chapter stating "Development should be appropriate to the rural setting of the area" - this clearly is not.

Change suggested by respondent:

This element of the plan should be abandoned and deleted.

Full text:

The building of 40 houses on greenbelt land in the ancient village of Blackmore does not fit with planning policy requirements. This unneeded commercial development will change the nature of the environment and the quality of life that has acted as a pleasant relief to visitors from nearby urban environments. This relief is being eroded by constant development sprawl.

Specifically it is against item 2.10 in the LDP Settlement Hierarchy Chapter stating "Development should be appropriate to the rural setting of the area" - this clearly is not.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22262

Received: 13/03/2019

Respondent: Mrs Shirley Slade-Bennett

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

1. Plan unsound: no clear strategy. R25/R26 previously deemed 'unsuitable for development'

Change suggested by respondent:

Remove the proposals R25 & R26 for development in Blackmore village from the LDP

Full text:

1. Plan unsound: no clear strategy. R25/R26 previously deemed 'unsuitable for development'

2. No prior consultation with affected Blackmore residents

3. Plots R25 & R26 Greenbelt. Unsuitable for development owing to flooding, poor access road, extra strain on services

4. Village services already overloaded (e.g. health, education, parking). Developments will exacerbate

5. Poor transport links will suffer further by additional dwellings

6. No evidence of effect developments in adjacent areas will have on Blackmore services, or of Brentwood's consultation with those Councils

7. No evidence of proper examination of alternative sites (brownfield or in other parishes). LDP proposals appear developer-led

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22488

Received: 18/03/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

3. Effective.

Criterion B. a. of Policy R25 states that vehicular access should be via Redrose Lane.

ECC as Highway Authority has previously advised that vehicular access from Redrose Lane may not be able to meet highway standards, and it could be more appropriate to take access from Nine Ashes Road.

The policy should therefore be amended to reflect this.

Change suggested by respondent:

Amend Policy R25 B. a. as follows -

vehicular access via Nine Ashes Road;

Full text:

3. Effective.

Criterion B. a. of Policy R25 states that vehicular access should be via Redrose Lane.

ECC as Highway Authority has previously advised that vehicular access from Redrose Lane may not be able to meet highway standards, and it could be more appropriate to take access from Nine Ashes Road.

The policy should therefore be amended to reflect this.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22576

Received: 19/03/2019

Respondent: Essex Wildlife Trust

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy wording lacks a commitment to deliver biodiversity net gain.

The hedgerows should be retained and enhanced, open space should be multifunctional and should include semi natural habitats for the benefit of wildlife. The scheme should deliver a measurable net gain in biodiversity.

Change suggested by respondent:

Policy wording should be amended as follows

c. provision for "multifunctional" public open space "to deliver a measurable net gain in biodiversity"

Full text:

Policy wording lacks a commitment to deliver biodiversity net gain.

The hedgerows should be retained and enhanced, open space should be multifunctional and should include semi natural habitats for the benefit of wildlife. The scheme should deliver a measurable net gain in biodiversity.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22622

Received: 19/03/2019

Respondent: Ms Pierina Norman

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Additional planned housing developments in Blackmore will further exacerbate the stresses on Blackmore's already overloaded infrastructure and services and, subsequently, the quality of life of residents.

Change suggested by respondent:

Brentwood Council should: conduct a 'Housing Need survey' of Blackmore village to demonstrate that the development is justified; demonstrate that no other brownfield sites are available; highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22624

Received: 19/03/2019

Respondent: Ms Pierina Norman

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The access off Red Rose Lane is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow, has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.

Change suggested by respondent:

Brentwood Council should: conduct a 'Housing Need survey' of Blackmore village to demonstrate that the development is justified; demonstrate that no other brownfield sites are available; highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22627

Received: 19/03/2019

Respondent: Ms Pierina Norman

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Site R25 and R26 are liable to flood, the proposed development of these sites will also increase the flood risk in the village. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding.

Change suggested by respondent:

Flood risk/drainage assessment should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22636

Received: 19/03/2019

Respondent: Ms Pierina Norman

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

This site is on Green Belt land, amendments to Greeen Belt boundaries around Blackmore have not be fully evidenced and justified as exceptional circumstances, as required by national policy. Brentwood Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22638

Received: 19/03/2019

Respondent: Ms Pierina Norman

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22640

Received: 19/03/2019

Respondent: Ms Gabriella Fickling

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Additional planned housing developments in Blackmore will further exacerbate the stresses on Blackmore's already overloaded infrastructure and services and, subsequently, the quality of life of residents.

Change suggested by respondent:

Brentwood Council should: conduct a 'Housing Need survey' of Blackmore village to demonstrate that the development is justified; demonstrate that no other brownfield sites are available; highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22642

Received: 19/03/2019

Respondent: Ms Gabriella Fickling

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The access off Red Rose Lane is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow, has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.

Change suggested by respondent:

Brentwood Council should: conduct a 'Housing Need survey' of Blackmore village to demonstrate that the development is justified; demonstrate that no other brownfield sites are available; highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22648

Received: 19/03/2019

Respondent: Ms Gabriella Fickling

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Site R25 and R26 are liable to flood, the proposed development of these sites will also increase the flood risk in the village. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding.

Change suggested by respondent:

Flood risk/drainage assessment should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22650

Received: 19/03/2019

Respondent: Ms Gabriella Fickling

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

This site is on Green Belt land, amendments to Greeen Belt boundaries around Blackmore have not be fully evidenced and justified as exceptional circumstances, as required by national policy. Brentwood Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22652

Received: 19/03/2019

Respondent: Ms Gabriella Fickling

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22655

Received: 19/03/2019

Respondent: Ms Gabriella Fickling

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Brentwood Borough Council has failed to demonstrate that the required housing could not be met by other brownfield alternatives or increasing housing density on other allocated sites (outside Blackmore village). There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.

Change suggested by respondent:

Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22664

Received: 26/03/2019

Respondent: Cllr. Andrew Watley

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Not chosen for good planning protocols, but convenient due to developers lined up.
At last LDP iteration - inappropriate to develop in the villages due to a lack of infrastructure. Nothing changed.

Change suggested by respondent:

Remove site R25 entirely

Full text:

I object to sites R25 and R26 within the LDP.
Not chosen for good planning protocols, but convenient due to developers lined up.
At last LDP iteration - inappropriate to develop in the villages due to a lack of infrastructure. Nothing changed. The scale of 70 new houses in a village of 350 houses is totally out of proportion - will change character. Poor access. Flooding risk to village increased. Lack of good transport links. Blackmore School at capacity - would force pupils out of the area. No 'very special circumstances' to warrant building on greenbelt.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22665

Received: 26/03/2019

Respondent: Cllr. Andrew Watley

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The scale of 70 new houses in a village of 350 houses is totally out of proportion - will change character.

Change suggested by respondent:

Remove site from plan

Full text:

I object to sites R25 and R26 within the LDP.
Not chosen for good planning protocols, but convenient due to developers lined up.
At last LDP iteration - inappropriate to develop in the villages due to a lack of infrastructure. Nothing changed. The scale of 70 new houses in a village of 350 houses is totally out of proportion - will change character. Poor access. Flooding risk to village increased. Lack of good transport links. Blackmore School at capacity - would force pupils out of the area. No 'very special circumstances' to warrant building on greenbelt.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22666

Received: 26/03/2019

Respondent: Cllr. Andrew Watley

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Poor access. Lack of good transport links.

Change suggested by respondent:

Remove site from the plan

Full text:

I object to sites R25 and R26 within the LDP.
Not chosen for good planning protocols, but convenient due to developers lined up.
At last LDP iteration - inappropriate to develop in the villages due to a lack of infrastructure. Nothing changed. The scale of 70 new houses in a village of 350 houses is totally out of proportion - will change character. Poor access. Flooding risk to village increased. Lack of good transport links. Blackmore School at capacity - would force pupils out of the area. No 'very special circumstances' to warrant building on greenbelt.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22667

Received: 26/03/2019

Respondent: Cllr. Andrew Watley

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Flooding risk to village increased.

Change suggested by respondent:

Remove site from plan

Full text:

I object to sites R25 and R26 within the LDP.
Not chosen for good planning protocols, but convenient due to developers lined up.
At last LDP iteration - inappropriate to develop in the villages due to a lack of infrastructure. Nothing changed. The scale of 70 new houses in a village of 350 houses is totally out of proportion - will change character. Poor access. Flooding risk to village increased. Lack of good transport links. Blackmore School at capacity - would force pupils out of the area. No 'very special circumstances' to warrant building on greenbelt.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22668

Received: 26/03/2019

Respondent: Cllr. Andrew Watley

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Blackmore School at capacity - would force pupils out of the area.

Change suggested by respondent:

Remove site from plan

Full text:

I object to sites R25 and R26 within the LDP.
Not chosen for good planning protocols, but convenient due to developers lined up.
At last LDP iteration - inappropriate to develop in the villages due to a lack of infrastructure. Nothing changed. The scale of 70 new houses in a village of 350 houses is totally out of proportion - will change character. Poor access. Flooding risk to village increased. Lack of good transport links. Blackmore School at capacity - would force pupils out of the area. No 'very special circumstances' to warrant building on greenbelt.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22669

Received: 26/03/2019

Respondent: Cllr. Andrew Watley

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

No 'very special circumstances' to warrant building on greenbelt.

Change suggested by respondent:

Remove site from plan

Full text:

I object to sites R25 and R26 within the LDP.
Not chosen for good planning protocols, but convenient due to developers lined up.
At last LDP iteration - inappropriate to develop in the villages due to a lack of infrastructure. Nothing changed. The scale of 70 new houses in a village of 350 houses is totally out of proportion - will change character. Poor access. Flooding risk to village increased. Lack of good transport links. Blackmore School at capacity - would force pupils out of the area. No 'very special circumstances' to warrant building on greenbelt.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22693

Received: 19/03/2019

Respondent: D. Rawlings

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Blackmore is an isolated village with modest infrastructure and services and are at capacity. Therefore new development could not be supported. The area is currently prone to flooding. More suitable and sustainable site exist with Brentwood and brownfield sites. Development should not be permitted on greenfield / green belt

Full text:

The principle of residential development in the vicinity of Red Rose Lane is wrong. Blackmore is an isolated village with modest services and infrastructure. There is already limited parking available in the area, bus services are infrequent and local school and doctors are at capacity. The narrow access to and from Red Rose Lane is not suitable for the volume of traffic that will result from development. This will add to motor traffic using the lanes connecting Blackmore to neighbouring areas which are dangerous and unsuitable for sustainable forms of transport such as cycling and walking. The proposed sites are liable to flooding and building on this land will also increase the flood risk elsewhere in the village which is already prone to flooding. There is no clear strategy for the villages in the north of the borough, including Blackmore. Brentwood Borough Council has not consulted adequately with neighbouring authorities, e.g. the construction of circa 30 properties at the top of Fingrith Hall Lane and its impact on the village. There are far more suitable and sustainable locations for development adjacent to the urban area of Brentwood and other brownfield sites should take priority over the development of greenfields / green belt land of off Red Rose Lane. Brentwood Borough Council has not demonstrated that the required level of housing can be accommodated by increasing density of other allocated sites.

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22711

Received: 17/03/2019

Respondent: Dr Murray Wood

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Additional planned housing developments in Blackmore will further exacerbate the stresses on Blackmore's already overloaded infrastructure and services and, subsequently, the quality of life of residents.

Change suggested by respondent:

Brentwood Council should: conduct a 'Housing Need survey' of Blackmore village to demonstrate that the development is justified; demonstrate that no other brownfield sites are available; highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22712

Received: 17/03/2019

Respondent: Dr Murray Wood

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The access off Red Rose Lane is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow, has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.

Change suggested by respondent:

Brentwood Council should: conduct a 'Housing Need survey' of Blackmore village to demonstrate that the development is justified; demonstrate that no other brownfield sites are available; highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments:

Object

Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)

Representation ID: 22714

Received: 17/03/2019

Respondent: Dr Murray Wood

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Site R25 and R26 are liable to flood, the proposed development of these sites will also increase the flood risk in the village. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding.

Change suggested by respondent:

Flood risk/drainage assessment should be undertaken.

Full text:

Unsound because :-
-Brentwood Borough Council has failed to provide a development strategy for the villages, including Blackmore, in the north of the Brentwood Borough. The LDP has not been prepared appropriately because it lacks any provision for meeting the village's needs, which have not been objectively assessed. This is clearly demonstrated by the lack of an assessment of the housing needs within the village.
- Brentwood Borough Council has not consulted adequately with neighbouring authorities and has failed to account for the impact of developments in close proximity to the village. This contradicts key requirements of the LDP, as a nearby development of around 30 houses is under way on Fingrith Hall Lane, having been approved by Epping Forest District Council. The residents of these homes will undoubtedly use Blackmore infrastructure and the impact of these properties has not been taken into account.
- Additional planned housing developments on Red Rose Farm and on Spriggs, near to Blackmore, have not been considered by the planners. These properties will rely on the village of Blackmore and further exacerbate the stresses on already overloaded infrastructure and services.
- Blackmore is a small village with modest services and infrastructure. Currently, Blackmore has minimal public transport providing access to the local towns of Brentwood and Chelmsford, a heavily oversubscribed primary school, a severely overstretched GP / Health services, narrow and heavily used roads, and desperately insufficient parking around the local shop. Additional housing on the scale proposed in the LDP will have a dramatically detrimental effect on these services and, subsequently, the quality of life of Blackmore's residents. The LDP fails to demonstrate that the level of proposed development in Blackmore can be sustained by the existing infrastructure and is, therefore, inconsistent with the requirement to achieve sustainable development.
- Far more suitable and sustainable locations are available within Brentwood Borough Council, that would provide much better access to urban development and services. Blackmore does not present the opportunity to achieve sustainable development.
- The proposed development is on Green Belt land - the Government and Brentwood Borough Council have given numerous assurances that high quality green field Green Belt land will not be sacrificed to housing unless no suitable brownfield alternatives are available. National Planning Policy Framework (NPPF) states that green belt boundaries should only be altered in exceptional circumstances. Amendments to boundaries around the village of Blackmore have not be fully evidenced and justified as required by national policy. Brentwood Borough Council has not demonstrated that it has examined fully all other reasonable options for meeting its identified need for development, in particular that there are no other brownfield sites available which should take priority over Green Belt land development such as the sites off Red Rose Lane. The LDP is therefore unsound because it does not take into account reasonable alternatives and the need to promote sustainable patterns of development and is therefore contrary to national planning policy. Paragraph 138 of the NPPF states "When drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should be taken into account. Strategic policymaking authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the outer Green Belt boundary. Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been previously-developed and/or is well-served by public transport. They should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."
- Brentwood Borough Council has failed to demonstrate that the required housing could not be met by increasing housing density on other allocated sites within the LDP. The LDP is therefore not based on proportionate evidence.
- There has been no 'Housing needs Survey' undertaken to demonstrate why Blackmore is included in the LDP, and there is no justification of the numbers of dwellings proposed in the village. The LDP is therefore not based on proportionate evidence.
- The access off Red Rose Lane, Blackmore is entirely unsuitable for the volume of traffic movements that would result from the proposed development. The lane is very narrow and two cars cannot pass each other without pulling to the side. The lane has ditches either side and does not have pavements or other provision for pedestrians. The lane is regularly used by walkers, cyclists and horse riders and the additional traffic would cause a major hazard. The LDP has not demonstrated that the proposed development off Red Rose Lane is sustainable.
- The proposed sites are liable to flood, and the proposed development of these sites will also increase the flood risk in the village which has been subject to severe flooding in the past. Red Rose Lane itself has flooded many times in the past, and a neighbouring field was rejected from the LDP proposals because of the risk of flooding. The proposed development is therefore not sustainable, and if ponds and extra drainage are required to alleviate the risk of flooding, then the development may not be deliverable.
- Site R26 is home to a number of protected species including turtle doves, skylarks, various species of bat, and barn owls. The turtle dove is a Section 41 species which is of principal importance for the conservation of biodiversity in England. They are vulnerable to global extinction and identified in the Red List of Endangered Species. The loss of this site to housing would inevitably mean the loss of this important breeding site and thus further loss of appropriate habitat. Loss of this habitat and impact on protected species is also contrary to national policy, included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.
- Brentwood Borough Council are required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development. As it stands the LDP is not justified in terms of overturning the Green Belt status of these sites. The LDP is unsound at present because the proposed development does not take account of reasonable alternatives.
- Highway/traffic assessments, flood risk/drainage assessment and detailed ecological surveys should be undertaken in order to demonstrate the sites R25 and R26 are deliverable.

Attachments: