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.

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

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.

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.

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.

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.

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.

Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

1. Blackmore is a small village and as such has just enough amenities to support the number of people living here at present.
One local store, two public houses, hairdressers and a garage. At the moment parking in the centre of our village at times can be a nightmare, extra cars in the village will just add to this. Parking outside the local shop at present is now dangerous. In the event of an emergency will emergency vehicles manage to get past the often double parked cars?
The new development on the ex riding stables by Epping Forest council in Fingrith Hall Road can only add to the problem as traffic will use Blackmore as an access route and drive down to use the local shop.
Has BBC consulted with Epping Forest District council on the impact their developments have on our village?

2. Can our doctors practice cope with more people? Try getting an appointment, you have to wait weeks now. This can only get worse.

3. Can our local school cope with all the extra children any development would bring to the village?

4. We moved to Blackmore to be surrounded by green fields. Leaving our house at present within minutes we can enjoy the open countryside looking across farmland and walking along reasonably quiet country roads. We enjoy taking our dog around the village and especially along Red Rose Lane en route to our park. What will it be like in the future? Instead of green belt open countryside, urban development and our narrow lane turned into a busy access road. It certainly is not suitable for the volume of traffic any new development would create.

5. If this development does go ahead, how many years of disruption through our village. Large lorries hurtling through our country roads, breaking up the road surface. Noise, dust, road works when new sewers, pipes etc. for the essential services are required to be laid.

ALL OF THE ABOVE WILL HAVE A SERIOUS ADVERSE IMPACT ON THE QUALITY OF OUR LIVES AND WILL CERTAINLY DAMAGE THE UNIQUE CHARACTER OF OUR BEAUTIFUL VILLAGE. THE REASON WHY WE LOVE LIVING IN BLACKMORE. THIS IS A SMALL VILLAGE...KEEP IT THAT WAY.

What needs to be done........Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

1. Blackmore is a small village and as such has just enough amenities to support the number of people living here at present.
One local store, two public houses, hairdressers and a garage. At the moment parking in the centre of our village at times can be a nightmare, extra cars in the village will just add to this. Parking outside the local shop at present is now dangerous. In the event of an emergency will emergency vehicles manage to get past the often double parked cars?
The new development on the ex riding stables by Epping Forest council in Fingrith Hall Road can only add to the problem as traffic will use Blackmore as an access route and drive down to use the local shop.
Has BBC consulted with Epping Forest District council on the impact their developments have on our village?

2. Can our doctors practice cope with more people? Try getting an appointment, you have to wait weeks now. This can only get worse.

3. Can our local school cope with all the extra children any development would bring to the village?

4. We moved to Blackmore to be surrounded by green fields. Leaving our house at present within minutes we can enjoy the open countryside looking across farmland and walking along reasonably quiet country roads. We enjoy taking our dog around the village and especially along Red Rose Lane en route to our park. What will it be like in the future? Instead of green belt open countryside, urban development and our narrow lane turned into a busy access road. It certainly is not suitable for the volume of traffic any new development would create.

5. If this development does go ahead, how many years of disruption through our village. Large lorries hurtling through our country roads, breaking up the road surface. Noise, dust, road works when new sewers, pipes etc. for the essential services are required to be laid.

ALL OF THE ABOVE WILL HAVE A SERIOUS ADVERSE IMPACT ON THE QUALITY OF OUR LIVES AND WILL CERTAINLY DAMAGE THE UNIQUE CHARACTER OF OUR BEAUTIFUL VILLAGE. THE REASON WHY WE LOVE LIVING IN BLACKMORE. THIS IS A SMALL VILLAGE...KEEP IT THAT WAY.

What needs to be done........Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

1. Blackmore is a small village and as such has just enough amenities to support the number of people living here at present.
One local store, two public houses, hairdressers and a garage. At the moment parking in the centre of our village at times can be a nightmare, extra cars in the village will just add to this. Parking outside the local shop at present is now dangerous. In the event of an emergency will emergency vehicles manage to get past the often double parked cars?
The new development on the ex riding stables by Epping Forest council in Fingrith Hall Road can only add to the problem as traffic will use Blackmore as an access route and drive down to use the local shop.
Has BBC consulted with Epping Forest District council on the impact their developments have on our village?

2. Can our doctors practice cope with more people? Try getting an appointment, you have to wait weeks now. This can only get worse.

3. Can our local school cope with all the extra children any development would bring to the village?

4. We moved to Blackmore to be surrounded by green fields. Leaving our house at present within minutes we can enjoy the open countryside looking across farmland and walking along reasonably quiet country roads. We enjoy taking our dog around the village and especially along Red Rose Lane en route to our park. What will it be like in the future? Instead of green belt open countryside, urban development and our narrow lane turned into a busy access road. It certainly is not suitable for the volume of traffic any new development would create.

5. If this development does go ahead, how many years of disruption through our village. Large lorries hurtling through our country roads, breaking up the road surface. Noise, dust, road works when new sewers, pipes etc. for the essential services are required to be laid.

ALL OF THE ABOVE WILL HAVE A SERIOUS ADVERSE IMPACT ON THE QUALITY OF OUR LIVES AND WILL CERTAINLY DAMAGE THE UNIQUE CHARACTER OF OUR BEAUTIFUL VILLAGE. THE REASON WHY WE LOVE LIVING IN BLACKMORE. THIS IS A SMALL VILLAGE...KEEP IT THAT WAY.

What needs to be done........Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

1. Blackmore is a small village and as such has just enough amenities to support the number of people living here at present.
One local store, two public houses, hairdressers and a garage. At the moment parking in the centre of our village at times can be a nightmare, extra cars in the village will just add to this. Parking outside the local shop at present is now dangerous. In the event of an emergency will emergency vehicles manage to get past the often double parked cars?
The new development on the ex riding stables by Epping Forest council in Fingrith Hall Road can only add to the problem as traffic will use Blackmore as an access route and drive down to use the local shop.
Has BBC consulted with Epping Forest District council on the impact their developments have on our village?

2. Can our doctors practice cope with more people? Try getting an appointment, you have to wait weeks now. This can only get worse.

3. Can our local school cope with all the extra children any development would bring to the village?

4. We moved to Blackmore to be surrounded by green fields. Leaving our house at present within minutes we can enjoy the open countryside looking across farmland and walking along reasonably quiet country roads. We enjoy taking our dog around the village and especially along Red Rose Lane en route to our park. What will it be like in the future? Instead of green belt open countryside, urban development and our narrow lane turned into a busy access road. It certainly is not suitable for the volume of traffic any new development would create.

5. If this development does go ahead, how many years of disruption through our village. Large lorries hurtling through our country roads, breaking up the road surface. Noise, dust, road works when new sewers, pipes etc. for the essential services are required to be laid.

ALL OF THE ABOVE WILL HAVE A SERIOUS ADVERSE IMPACT ON THE QUALITY OF OUR LIVES AND WILL CERTAINLY DAMAGE THE UNIQUE CHARACTER OF OUR BEAUTIFUL VILLAGE. THE REASON WHY WE LOVE LIVING IN BLACKMORE. THIS IS A SMALL VILLAGE...KEEP IT THAT WAY.

What needs to be done........Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected

1. Blackmore is a small village and as such has just enough amenities to support the number of people living here at present.
One local store, two public houses, hairdressers and a garage. At the moment parking in the centre of our village at times can be a nightmare, extra cars in the village will just add to this. Parking outside the local shop at present is now dangerous. In the event of an emergency will emergency vehicles manage to get past the often double parked cars?
The new development on the ex riding stables by Epping Forest council in Fingrith Hall Road can only add to the problem as traffic will use Blackmore as an access route and drive down to use the local shop.
Has BBC consulted with Epping Forest District council on the impact their developments have on our village?

2. Can our doctors practice cope with more people? Try getting an appointment, you have to wait weeks now. This can only get worse.

3. Can our local school cope with all the extra children any development would bring to the village?

4. We moved to Blackmore to be surrounded by green fields. Leaving our house at present within minutes we can enjoy the open countryside looking across farmland and walking along reasonably quiet country roads. We enjoy taking our dog around the village and especially along Red Rose Lane en route to our park. What will it be like in the future? Instead of green belt open countryside, urban development and our narrow lane turned into a busy access road. It certainly is not suitable for the volume of traffic any new development would create.

5. If this development does go ahead, how many years of disruption through our village. Large lorries hurtling through our country roads, breaking up the road surface. Noise, dust, road works when new sewers, pipes etc. for the essential services are required to be laid.

ALL OF THE ABOVE WILL HAVE A SERIOUS ADVERSE IMPACT ON THE QUALITY OF OUR LIVES AND WILL CERTAINLY DAMAGE THE UNIQUE CHARACTER OF OUR BEAUTIFUL VILLAGE. THE REASON WHY WE LOVE LIVING IN BLACKMORE. THIS IS A SMALL VILLAGE...KEEP IT THAT WAY.

What needs to be done........Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

1. Blackmore is a small village and as such has just enough amenities to support the number of people living here at present.
One local store, two public houses, hairdressers and a garage. At the moment parking in the centre of our village at times can be a nightmare, extra cars in the village will just add to this. Parking outside the local shop at present is now dangerous. In the event of an emergency will emergency vehicles manage to get past the often double parked cars?
The new development on the ex riding stables by Epping Forest council in Fingrith Hall Road can only add to the problem as traffic will use Blackmore as an access route and drive down to use the local shop.
Has BBC consulted with Epping Forest District council on the impact their developments have on our village?

2. Can our doctors practice cope with more people? Try getting an appointment, you have to wait weeks now. This can only get worse.

3. Can our local school cope with all the extra children any development would bring to the village?

4. We moved to Blackmore to be surrounded by green fields. Leaving our house at present within minutes we can enjoy the open countryside looking across farmland and walking along reasonably quiet country roads. We enjoy taking our dog around the village and especially along Red Rose Lane en route to our park. What will it be like in the future? Instead of green belt open countryside, urban development and our narrow lane turned into a busy access road. It certainly is not suitable for the volume of traffic any new development would create.

5. If this development does go ahead, how many years of disruption through our village. Large lorries hurtling through our country roads, breaking up the road surface. Noise, dust, road works when new sewers, pipes etc. for the essential services are required to be laid.

ALL OF THE ABOVE WILL HAVE A SERIOUS ADVERSE IMPACT ON THE QUALITY OF OUR LIVES AND WILL CERTAINLY DAMAGE THE UNIQUE CHARACTER OF OUR BEAUTIFUL VILLAGE. THE REASON WHY WE LOVE LIVING IN BLACKMORE. THIS IS A SMALL VILLAGE...KEEP IT THAT WAY.

What needs to be done........Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

1. Blackmore is a small village and as such has just enough amenities to support the number of people living here at present.
One local store, two public houses, hairdressers and a garage. At the moment parking in the centre of our village at times can be a nightmare, extra cars in the village will just add to this. Parking outside the local shop at present is now dangerous. In the event of an emergency will emergency vehicles manage to get past the often double parked cars?
The new development on the ex riding stables by Epping Forest council in Fingrith Hall Road can only add to the problem as traffic will use Blackmore as an access route and drive down to use the local shop.
Has BBC consulted with Epping Forest District council on the impact their developments have on our village?

2. Can our doctors practice cope with more people? Try getting an appointment, you have to wait weeks now. This can only get worse.

3. Can our local school cope with all the extra children any development would bring to the village?

4. We moved to Blackmore to be surrounded by green fields. Leaving our house at present within minutes we can enjoy the open countryside looking across farmland and walking along reasonably quiet country roads. We enjoy taking our dog around the village and especially along Red Rose Lane en route to our park. What will it be like in the future? Instead of green belt open countryside, urban development and our narrow lane turned into a busy access road. It certainly is not suitable for the volume of traffic any new development would create.

5. If this development does go ahead, how many years of disruption through our village. Large lorries hurtling through our country roads, breaking up the road surface. Noise, dust, road works when new sewers, pipes etc. for the essential services are required to be laid.

ALL OF THE ABOVE WILL HAVE A SERIOUS ADVERSE IMPACT ON THE QUALITY OF OUR LIVES AND WILL CERTAINLY DAMAGE THE UNIQUE CHARACTER OF OUR BEAUTIFUL VILLAGE. THE REASON WHY WE LOVE LIVING IN BLACKMORE. THIS IS A SMALL VILLAGE...KEEP IT THAT WAY.

What needs to be done........Leave Blackmore alone, let the residents continue to enjoy their way of life. If building needs to be done look for brown belt sites in more suitable areas first before greenbelt areas are considered. Many of which I understand have been identified but rejected.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

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

I do not believe the plan is sound for the following reasons:
1. There has not been sufficient consultation with other neighbouring authorities. For example Epping Forest District Council which is building about 30 new houses just 1 mile north of Blackmore at the top of Fingrith Hall lane. This will have a major impact on the village amenities, and will increase traffic flow though the village, especially when added to the over 70 new properties being proposed for Blackmore.
2. The access to/from Red Rose Lane is completely unsuitable for the addition of over 70 properties as it is a single track lane which is unsuitable for heavy construction traffic, and the following traffic generated by the 70 properties.
3. The village has historically been subject to serious flooding, most recently being 3 years ago. Red Rose lane is susceptible to flooding and this makes it impassable to vehicles. Adding over 70 properties with their associated run-off will cause further flooding problems, even with the adoption of SUDS.
4. The sewerage, electricity and other utilities were not designed to cope with an additional 70 properties (an increase of around 30%) without counting the 30 extra properties in Fingrith Hall road.
5. There has been no clear housing strategy for the North of the Borough. Whilst there are many options that could be considered for building houses in the North of the Borough, it is as if Blackmore has been chosen with virtually no other options being considered.
6. There has been no 'Housing Needs' survey carried out which would demonstrate why Blackmore has been included in the LDP, and why other areas have not.
7. The Borough Council have not shown that the required additional houses for the Borough could not be delivered by increasing the housing density on the other allocated sites in the plan.
8. There are Brownfield sites available nearby but there is no evidence these have been considered in preference to using greenfield, Green Belt land.
9. Putting a substantial residential development in the north of the village on Green Belt land off of Red Rose Lane which increases the housing in a historic village by over 30% is fundamentally wrong. The infrastructure (bus services, roads, village facilities, doctors, school) simply cannot cope with such a large increase of people.
10. Adding approximately 200 more cars (over 70 houses in Blackmore and 30 in Fingrith Hall lane) in the village of Blackmore (which already suffers from significant parking problems) will create a real danger to pedestrians in the village. The lives of small children and old people will be put in real danger with such a large increase in traffic volumes.
11. There is not sufficient public transport links to the surrounding areas to make this environmentally sound, as the increase in private vehicles will add to the pollution already caused during the development phase.
12. Other more suitable locations (eg areas around Doddinghurst, urban extensions to Brentwood, increasing the size of the Dunton Hills proposal) which all have better transport links would have been a far better proposal than the development in Blackmore which is not a sustainable development proposal.
13. The pieces of land proposed in Blackmore are important wildlife and natural habitats for rare species such as newts and other creatures.
14. The Local Development Plan proposal includes a plan to regularize an unauthorized traveler site on the Chelmsford Road. This will add to further overcrowding in the village and of it's services by the addition of more permanent dwellings.

Remove site R25 from plan

1. This joint representation is made on behalf of:
1.1.The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2.The Blackmore Village Heritage Association ('BVHA')
Introduction
2. The Parish Council is a statutory consultee and represents 350 households in Blackmore village (population of only 943) included in a total population of 2,561 within the wider Parish with its three distinct separate settlements. This figure does not include the many households in neighbouring villages who rely on Blackmore's facilities.
3. BVHA is an unincorporated, not for profit, organisation and has in excess of 150 active members but its newsletters are distributed to over 1,000 households.
4. Both the Parish Council and BVHA strongly oppose the proposed allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land north of Orchard Piece, Blackmore) for housing development. The proposed allocation is for "around 40 new homes" at R25 and for "around 30 new homes" at R26.
5. They say that the proposed allocations R25 and R26 are contrary to both National and Local Policies.

6. In simple terms the Parish Council's and BVHA's case is as follows:
6.1.Brentwood Borough Council has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites.
6.2.Without prejudice to the above contention, if no previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.
6.3.In any event, there are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.
6.4.Moreover, R25 and R26 are inherently unsuitable developments because of (1) inadequate access, (2) flooding, (3) it will result in disproportionate increase in the housing stock, and, (4) the development would not be sustainable.
7. The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan).
8. Accordingly, the Parish Council and BVHA submit that the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').
Background
9. Blackmore is currently a village of approximately 350 dwellings which are home to 943 people (according to the Electoral Register). The proposal to add "around 70 homes" will add approximately 25% to the existing village housing stock. The proportionate increase to the village population would likely be greater by virtue of the number of current dwellings being occupied by two or less villagers. Outside of the LDP, housing stock is also increasing through normal planning processes both within Brentwood Borough Council and our neighbouring Epping Forest Council which will impact upon Blackmore village.
10.Blackmore is a picturesque village and surrounded by countryside. The Village Green has ponds at its eastern end. There is a village shop including post office, Primary School, two village halls, a sports and social club, tennis courts, football and cricket pitches, and a flood-lit Multi-Use Games Arena. All of these facilities are at capacity use. The village has three pubs: The Prince Albert, The Bull, and The Leather Bottle. In addition to the Anglican parish Church there is a Baptist Church in the village. However, Blackmore has a very limited bus service and is thus remote. It is over 6 miles from the centre of Brentwood and thus the villagers of Blackmore are reliant on the motor car.
11.The village School is at capacity and local residents are having to send children to neighbouring schools. There is limited scope for expansion. It is socially undesirable for some village children to be able to attend the village school and others to be "shipped out". This social harm (i.e. lack of cohesion) would be exacerbated if more resident village children had to be "shipped out" to another school.
12.In respect of employment opportunities within Blackmore these are limited and, of those of working age nearly all, if not all, commute out of the village. That commute takes place, if not exclusively, almost exclusively by private motor car. Such further evidences that Blackmore is an unsustainable location for new development.
13.Both R25 and R26 are on the Northern Boundary of the village of Blackmore. Both are bordered (to the north) by Redrose Lane, a rare extant example of a "plague detour route". Redrose Lane is narrow and with limited passing space for two motor cars. Vehicles larger than a car (i.e. Transit van and above) cannot pass without one, or the other, stopping (see Appendix One). Development of 70 dwellings would undoubtedly result in a significant number of vehicular movements - in the order of 600 to 700 per day - and, without suitable improvements (which would erode the character of Redrose Lane), cause harm.
14.Both R25 and R26 are in the Green Belt. Both are on land classified as "very good" agricultural land. Both sites have ecological value and, more importantly, local residents have reported sightings of bats, owls and newts at, or in the vicinity of, R25 and R26 (See Appendix Two).
15.Whilst the Environmental Agency classifies both sites within Flood Zone 1, both R25 and R26 have flooded historically - and both have an identified flood risk (see Appendix Three).
16.The BVHA undertook a survey in July 2018 of local residents and visitors to the Village. The BVHA survey confirms that residents are opposed to the proposed allocation of R25 and R26. Of the responses received from village residents, over
300, 98% were strongly opposed to the allocation of sites R25 and R26. It should be noted that the response numbers (over 300 adult residents in the village) was extremely good and evidences the strength of local feeling. It also outlines the engagement of the local Community.
Issues concerning Consultation and Consistency
17.It is a maxim that "good planning is consistent planning".
18.The Current Local Plan (the Brentwood Replacement Local Plan) dates to 2005 and tightly controls development in the Green Belt. Thus, development on R25 and R26 is contrary to the current Local Plan policies absent "very special circumstances".
19.In a 2014 site assessment document, which was and is part of the current emerging local plan process, sites R25 and R26 were discounted as they did not meet the (then) draft Local Plan spatial strategy.
20.It is not clear why this assessment has changed - indeed, the constraints surrounding site R25 and R26 remain unchanged.
21.More recently, in the Council's (Regulation 18) 2016 draft Local Plan, it was stated that "No amendment is proposed to the Green Belt boundaries surrounding larger villages [Blackmore is defined as a larger village] in order to retain the character of the Borough in line with the spatial strategy" (para 5.33). That spatial strategy seeking, insofar as it was necessary to do so, "limited release of Green Belt land for development within transport corridors, in strategic locations to deliver self- sustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries". So even though Brentwood Borough Council had identified a potential need for release of Green Belt land, no suitable land was identified in Blackmore.
22.There has therefore been a significant shift of policy; namely from a position of no development at R25 and R26 to now seeking to allocate these sites for residential development. The Parish Council and BVHA say that the change in position is inconsistent and wrong for reasons more fully set out below.
23.The Parish Council and BVHA also wish to record that the Council's planning Team, represented by a Strategic Director and three other Senior Officers, confirmed at a public meeting on 31 January 2019 that Blackmore's allocation was a result of property developers promoting the development of land on which their companies held options. The Parish Council and BVHA take the view that, not only would the proposed allocation of R25 and R26 appear to be "developer-led" rather than plan- led, it shows a lack of thorough and appropriate research, and understanding of the unique character and circumstances of Blackmore. The Parish Council and BVHA further take the view that developer pressure is not a good and sufficient reason for Brentwood Borough Council to abdicate its duty to promote a sound, and consistent, Development Plan.
Evidence Base
24.Paragraph 31 NPPF provides that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence.
25.Part of the evidence is the "Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report - January 2019" ('the SA'). The SA tells us that a number of sustainability 'topics' inform the framework for assessing the sustainability of the site. Flooding is one of those topics (see Table 3.1 of the SA).
26.Risk of flooding is important to any sustainability appraisal not only because the NPPF and emerging policy NE06 seek to direct development away from areas of highest risk of flooding but also because flooding can put lives and property at risk. It is therefore surprising that, for all bar 21 potential sites, the SA does not consider flood risk in assessing sustainability.
27.The Level 1 Strategic Flood Risk Assessment does assess risk however and identifies a medium risk of surface water flooding for Redrose Lane (Table A4b) with Site R26 being potentially vulnerable to climate change and with a 1 in 100 annual probability of surface water flooding (Table A6b). The findings appear at odds with the fact that Sites R25 and R26 are lower than Redrose Lane and thus, one may expect, may be more vulnerable to flooding than higher land (i.e. Redrose Lane). Indeed, these sites have consistently flooded as evidenced by the photographs in Appendix Two.
28.There are, of course, documents supporting housing need. However, there is no evidence of local housing need for Blackmore, or any other villages. Whilst the Parish Council and BVHA accept that there may be some demand for housing any such demand should be properly evidenced with any housing allocation proportionate and ensuring that houses are being built in the right places.
Sustainable Development
29.It is a core planning principle that plans should be prepared with the objective of contributing to the achievement of sustainable development (para 16(a) NPPF). Paragraph 8 NPPF outlines three objectives that the planning system should strive to meet.
30.The proposed allocation of sites R25 and R26 meets none of these objectives in that: 30.1. Economic objective - any contribution arising from the construction of new dwellings will be short-lived. There are no, or extremely limited, employment opportunities within Blackmore and the likelihood of new residents driving a demand for new services within the village would appear, at best, limited. In
short, any economic benefits are short-term.
30.2. Social objective - services in Blackmore are limited and the primary school
is at capacity sending additional village children to school elsewhere will further
erode social cohesion.
30.3. Environmental objective - occupiers of sites R25 and R26 would
undoubtedly be reliant on private motor cars. The sites are at risk of flooding (surface water at least) and require the release of high-grade agricultural land in the Green Belt. Redrose Lane is narrow and infrastructure works would be required to make necessary improvements which would harm the character of this area but may also result in the loss of historic hedges and important habitats.
31.There are other sites which are in far more sustainable locations which should be allocated in preference. Indeed, the SA identifies a number of sites (n.b. no scoring for flood risk) with better scores than sites R25 and R26, good examples being in Shenfield, Mountnessing, Pilgrims Hatch, Ingatestone and Brentwood such as, but not limited to, sites 038A, 253, 277B, 297, 218B, 053B, 189, 318, 288B, 153, 280, 024A and 130.
32.Furthermore, development in less sustainable locations, such as R25 and R26, before more sustainable locations, should be avoided.
Green Belt
33.Sites R25 and R26 are in the Green Belt. The Government attaches great importance to Green Belts (per para 133 NPPF). The Green Belt serves five purposes (para 134
NPPF) which includes safeguarding the countryside from encroachment, preserving the character of historic towns and assisting in urban regeneration.
34.The NPPF further confirms that, once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified (para 136 NPPF). Meeting an assessed housing need is not an exceptional circumstance. No other exceptional circumstances are put forward by Brentwood Borough Council.
35. Regardless, the NPPF is clear in that before concluding that exceptional circumstances exist to justify changing Green Belt boundaries Brentwood Borough Council should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified housing need (para 137 NPPF). In this respect the Parish Council and BVHA say:
35.1. There is no evidence that increasing densities elsewhere negates the need for the release of Green Belt land at sites R25 and R26. It should be remembered that the proposed Green Belt release, per Figure 4.2, only 123 of those homes are to be provided in the "larger villages" such as Blackmore which accounts for 1.5% of the total housing need (which includes a 20% buffer). This is a very modest contribution to housing supply which, the Parish Council and BVHA say, could easily be met by considering all other reasonable alternatives.
35.2. There are brownfield sites which should be identified, considered and used in preference.
35.3. There are also urban sites that should be used in preference, or alternatively, sites in more sustainable locations (i.e. close(r) to urban areas).
35.4. The village of Stondon Massey has actively sought new development within its boundaries. The same may be true of other villages within the Borough. Such "localised" development may reduce or negate the need for sites R25 and/or R26.
36.In consequence of the above, the Parish Council and BVHA say that Brentwood Borough Council has not demonstrated that it fully evidenced and justified a need to alter Green Belt boundaries nor that it has examined fully all other reasonable alternatives before doing so.
37.Further to the above, the notes to draft policy SP02 confirm that growth is prioritised "based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas where deemed appropriate" (para 4.22). The inclusion of R25 and R26 runs contrary to this - both being greenfield land in the Green Belt.
Whilst SP02 itself talks of the need to direct development to "highly accessible locations" - sites R25 and R26 are in a rural area with poor transport links and limited accessibility. The inclusion of R25 and R26 thus conflicts with policy SP02.
A Settlement Category 3 village?
38.As above the Parish Council and BVHA say that Blackmore should be classed as a Settlement Category 4 village and not the higher Category 3. They say this because: 38.1. There is no local shopping parade but, instead, one Co-Op Store (with Post
Office), a hairdressers and a coffee shop;
38.2. It does not have a health facility - the nearest Doctor's surgery is in
Doddinghurst (which is ~3 miles away and on roads not suitable for walking);
And 38.3. There are no, or very few, local jobs. Of those of working age nearly all
commute out of the village.
39. Accordingly, some of the key attributes of a Category 3 settlement are, in Blackmore's case, missing. As a more general point the population of Blackmore is modest and a considerable margin less than that of Doddinghurst and Kelvedon Hatch which are also classified as Category 3 settlements.
40.Further, of the Category 3 settlements it is only Blackmore (sites R25 and R26) and Kelvedon Hatch (sites R23 and R24) that it is proposed to allocate sites for housing/development. Kelvedon Hatch is in the order of 2.5 times larger (by population) than Blackmore - however its proposed housing allocation (total of ~53) is less, by approximately 25%, than that proposed for Blackmore.
41.This is in contrast to the larger Category 3 settlements of Doddinghurst and Ingrave which have no proposed allocation for housing. Indeed, no allocation is proposed for the other Category 3 settlements of Herongate and Mountnessing.
42.Simply put, the Parish Council and BVHA say that the classification of, and proposed housing allocation in, Blackmore is incorrect.
Other
43.The Parish Council and BVHA support the strategy within the plan. Indeed, in the main they recognise and support the policies within the draft plan. However, they take issue with allocations of sites R25 and R26; not only for the reasons above but when considered against the policy which Brentwood Borough Council are promoting. For example, sites R25 and R26 perform poorly against, or conflict with, draft policies SP01, SP02, SP03, NE01, NE09, BE12, BE13 and BE45. This is not withstanding the case that, in applying the NPPF, the Parish Council and BVHA say that development should be directed elsewhere in preference to sites R25 an R26.
44.The Parish Council and BVHA also take issue with the fact that of the 123 net homes allocated for "larger villages" 70, or approximately 56% of the total allocation, are met by these two sites. Thus, a disproportionately large amount of the allocation is from sites R25 and R26.
45.The above is notwithstanding the Parish Council and BVHA's primary contention that sites R25 and R26, but possibly all proposed sites on Green Belt Land in larger villages (i.e. settlement category 3), can and should be removed from the Plan.
46.The evidence of working with adjoining planning authorities is limited with a general statement that "adjacent planning authorities [have] confirmed that they [are] unwilling and unable to take any of the Brentwood identified housing need". The Parish Council and BVHA invite Brentwood Borough Council to more fully disclose the extent and nature of discussions that have been held with neighbouring authorities.
Summary/Conclusion
47.The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.
48.Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.
49.Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.
50.Sites R25 and R26 are in an unsustainable location served by a constrained access (Redrose Lane) and with an identified risk of flooding. The development of R25 and R26 does not represent sustainable development.
51.The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.
52.There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. Regardless, the proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).
53.The plan is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.
54.The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.
55.Brentwood Borough Council should amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.
HOLMES & HILLS LLP Dated 18 March 2019
Appendix 1: Photos of Redrose Lane with reference to size of Lane.
Appendix 2: Appendix Two - re R25 and R26 as Important Habitat sites
Blackmore Wildlife
The wildlife listed below has all been observed in the fields by Woollard Way and Orchard Piece and these fields provide invaluable nesting and foraging grounds.
Birds:
Redpoll, Yellowhammer, Skylarks, Barn Owls, Little Owls, Buzzard, Red Kite, Sparrowhawk, Song Thrush, Red-legged Partridges, Kestrels, Turtle Doves, Hedge sparrow, Siskin.
In particular Barn Owls and their nesting sites are protected by law during the breeding season - https://www.bto.org/volunteer-surveys/ringing/taking-part/protected-birds/s1- list
Turtle doves, Skylarks and Yellow Hammers are on the RSPB's red list which means,
amongst other things, that the species is globally threatened and are the highest priority for conservation - https://www.rspb.org.uk/birds-and-wildlife/wildlife-guides/uk- conservation-status-explained/

Reptiles:
Grass Snakes and Great Crested Newts which are a protected species -
https://www.wildlifetrusts.org/wildlife-explorer/amphibians/great-crested-newt
Photos of Owl; Sparrowhawk; reptile: newt; Bats:
All bats are protected by the law in the UK - https://www.bats.org.uk/advice/bats-and- the-law

They are frequently seen flying around the fields (i.e. R25 and R26) and there is possible nesting in the outbuildings.
Bats - video:
https://drive.google.com/file/d/15Be5ZUlvRwEDhh_ivlLf1fxb0Rf2QS3z/view
Appendix 3: Agricultural Lan Assessment and Flooding/Flood Risk mapping.
Photographs of Chelmsford Road and Redrose Lane Flooding 1987; 2016.
Flooding on The Green 2016; Flooding on Redrose Lane 2016 ((note depth of water). Redrose Lane 2018.

Extract from Daily Telegraph re: 2011 flooding.

Extract from Express re 2011 Flooding:
A woman is rescued from her car stuck in floodwater in Blackmore,
Essex, yesterday
Express - 18 Jan 2011
Fire Service in Redrose Lane east bound to Chelmsford Road.

Extract from Romford recorder RE: 2011 flooding

Remove site R25 from plan

1. This joint representation is made on behalf of:
1.1.The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2.The Blackmore Village Heritage Association ('BVHA')
Introduction
2. The Parish Council is a statutory consultee and represents 350 households in Blackmore village (population of only 943) included in a total population of 2,561 within the wider Parish with its three distinct separate settlements. This figure does not include the many households in neighbouring villages who rely on Blackmore's facilities.
3. BVHA is an unincorporated, not for profit, organisation and has in excess of 150 active members but its newsletters are distributed to over 1,000 households.
4. Both the Parish Council and BVHA strongly oppose the proposed allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land north of Orchard Piece, Blackmore) for housing development. The proposed allocation is for "around 40 new homes" at R25 and for "around 30 new homes" at R26.
5. They say that the proposed allocations R25 and R26 are contrary to both National and Local Policies.

6. In simple terms the Parish Council's and BVHA's case is as follows:
6.1.Brentwood Borough Council has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites.
6.2.Without prejudice to the above contention, if no previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.
6.3.In any event, there are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.
6.4.Moreover, R25 and R26 are inherently unsuitable developments because of (1) inadequate access, (2) flooding, (3) it will result in disproportionate increase in the housing stock, and, (4) the development would not be sustainable.
7. The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan).
8. Accordingly, the Parish Council and BVHA submit that the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').
Background
9. Blackmore is currently a village of approximately 350 dwellings which are home to 943 people (according to the Electoral Register). The proposal to add "around 70 homes" will add approximately 25% to the existing village housing stock. The proportionate increase to the village population would likely be greater by virtue of the number of current dwellings being occupied by two or less villagers. Outside of the LDP, housing stock is also increasing through normal planning processes both within Brentwood Borough Council and our neighbouring Epping Forest Council which will impact upon Blackmore village.
10.Blackmore is a picturesque village and surrounded by countryside. The Village Green has ponds at its eastern end. There is a village shop including post office, Primary School, two village halls, a sports and social club, tennis courts, football and cricket pitches, and a flood-lit Multi-Use Games Arena. All of these facilities are at capacity use. The village has three pubs: The Prince Albert, The Bull, and The Leather Bottle. In addition to the Anglican parish Church there is a Baptist Church in the village. However, Blackmore has a very limited bus service and is thus remote. It is over 6 miles from the centre of Brentwood and thus the villagers of Blackmore are reliant on the motor car.
11.The village School is at capacity and local residents are having to send children to neighbouring schools. There is limited scope for expansion. It is socially undesirable for some village children to be able to attend the village school and others to be "shipped out". This social harm (i.e. lack of cohesion) would be exacerbated if more resident village children had to be "shipped out" to another school.
12.In respect of employment opportunities within Blackmore these are limited and, of those of working age nearly all, if not all, commute out of the village. That commute takes place, if not exclusively, almost exclusively by private motor car. Such further evidences that Blackmore is an unsustainable location for new development.
13.Both R25 and R26 are on the Northern Boundary of the village of Blackmore. Both are bordered (to the north) by Redrose Lane, a rare extant example of a "plague detour route". Redrose Lane is narrow and with limited passing space for two motor cars. Vehicles larger than a car (i.e. Transit van and above) cannot pass without one, or the other, stopping (see Appendix One). Development of 70 dwellings would undoubtedly result in a significant number of vehicular movements - in the order of 600 to 700 per day - and, without suitable improvements (which would erode the character of Redrose Lane), cause harm.
14.Both R25 and R26 are in the Green Belt. Both are on land classified as "very good" agricultural land. Both sites have ecological value and, more importantly, local residents have reported sightings of bats, owls and newts at, or in the vicinity of, R25 and R26 (See Appendix Two).
15.Whilst the Environmental Agency classifies both sites within Flood Zone 1, both R25 and R26 have flooded historically - and both have an identified flood risk (see Appendix Three).
16.The BVHA undertook a survey in July 2018 of local residents and visitors to the Village. The BVHA survey confirms that residents are opposed to the proposed allocation of R25 and R26. Of the responses received from village residents, over
300, 98% were strongly opposed to the allocation of sites R25 and R26. It should be noted that the response numbers (over 300 adult residents in the village) was extremely good and evidences the strength of local feeling. It also outlines the engagement of the local Community.
Issues concerning Consultation and Consistency
17.It is a maxim that "good planning is consistent planning".
18.The Current Local Plan (the Brentwood Replacement Local Plan) dates to 2005 and tightly controls development in the Green Belt. Thus, development on R25 and R26 is contrary to the current Local Plan policies absent "very special circumstances".
19.In a 2014 site assessment document, which was and is part of the current emerging local plan process, sites R25 and R26 were discounted as they did not meet the (then) draft Local Plan spatial strategy.
20.It is not clear why this assessment has changed - indeed, the constraints surrounding site R25 and R26 remain unchanged.
21.More recently, in the Council's (Regulation 18) 2016 draft Local Plan, it was stated that "No amendment is proposed to the Green Belt boundaries surrounding larger villages [Blackmore is defined as a larger village] in order to retain the character of the Borough in line with the spatial strategy" (para 5.33). That spatial strategy seeking, insofar as it was necessary to do so, "limited release of Green Belt land for development within transport corridors, in strategic locations to deliver self- sustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries". So even though Brentwood Borough Council had identified a potential need for release of Green Belt land, no suitable land was identified in Blackmore.
22.There has therefore been a significant shift of policy; namely from a position of no development at R25 and R26 to now seeking to allocate these sites for residential development. The Parish Council and BVHA say that the change in position is inconsistent and wrong for reasons more fully set out below.
23.The Parish Council and BVHA also wish to record that the Council's planning Team, represented by a Strategic Director and three other Senior Officers, confirmed at a public meeting on 31 January 2019 that Blackmore's allocation was a result of property developers promoting the development of land on which their companies held options. The Parish Council and BVHA take the view that, not only would the proposed allocation of R25 and R26 appear to be "developer-led" rather than plan- led, it shows a lack of thorough and appropriate research, and understanding of the unique character and circumstances of Blackmore. The Parish Council and BVHA further take the view that developer pressure is not a good and sufficient reason for Brentwood Borough Council to abdicate its duty to promote a sound, and consistent, Development Plan.
Evidence Base
24.Paragraph 31 NPPF provides that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence.
25.Part of the evidence is the "Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report - January 2019" ('the SA'). The SA tells us that a number of sustainability 'topics' inform the framework for assessing the sustainability of the site. Flooding is one of those topics (see Table 3.1 of the SA).
26.Risk of flooding is important to any sustainability appraisal not only because the NPPF and emerging policy NE06 seek to direct development away from areas of highest risk of flooding but also because flooding can put lives and property at risk. It is therefore surprising that, for all bar 21 potential sites, the SA does not consider flood risk in assessing sustainability.
27.The Level 1 Strategic Flood Risk Assessment does assess risk however and identifies a medium risk of surface water flooding for Redrose Lane (Table A4b) with Site R26 being potentially vulnerable to climate change and with a 1 in 100 annual probability of surface water flooding (Table A6b). The findings appear at odds with the fact that Sites R25 and R26 are lower than Redrose Lane and thus, one may expect, may be more vulnerable to flooding than higher land (i.e. Redrose Lane). Indeed, these sites have consistently flooded as evidenced by the photographs in Appendix Two.
28.There are, of course, documents supporting housing need. However, there is no evidence of local housing need for Blackmore, or any other villages. Whilst the Parish Council and BVHA accept that there may be some demand for housing any such demand should be properly evidenced with any housing allocation proportionate and ensuring that houses are being built in the right places.
Sustainable Development
29.It is a core planning principle that plans should be prepared with the objective of contributing to the achievement of sustainable development (para 16(a) NPPF). Paragraph 8 NPPF outlines three objectives that the planning system should strive to meet.
30.The proposed allocation of sites R25 and R26 meets none of these objectives in that: 30.1. Economic objective - any contribution arising from the construction of new dwellings will be short-lived. There are no, or extremely limited, employment opportunities within Blackmore and the likelihood of new residents driving a demand for new services within the village would appear, at best, limited. In
short, any economic benefits are short-term.
30.2. Social objective - services in Blackmore are limited and the primary school
is at capacity sending additional village children to school elsewhere will further
erode social cohesion.
30.3. Environmental objective - occupiers of sites R25 and R26 would
undoubtedly be reliant on private motor cars. The sites are at risk of flooding (surface water at least) and require the release of high-grade agricultural land in the Green Belt. Redrose Lane is narrow and infrastructure works would be required to make necessary improvements which would harm the character of this area but may also result in the loss of historic hedges and important habitats.
31.There are other sites which are in far more sustainable locations which should be allocated in preference. Indeed, the SA identifies a number of sites (n.b. no scoring for flood risk) with better scores than sites R25 and R26, good examples being in Shenfield, Mountnessing, Pilgrims Hatch, Ingatestone and Brentwood such as, but not limited to, sites 038A, 253, 277B, 297, 218B, 053B, 189, 318, 288B, 153, 280, 024A and 130.
32.Furthermore, development in less sustainable locations, such as R25 and R26, before more sustainable locations, should be avoided.
Green Belt
33.Sites R25 and R26 are in the Green Belt. The Government attaches great importance to Green Belts (per para 133 NPPF). The Green Belt serves five purposes (para 134
NPPF) which includes safeguarding the countryside from encroachment, preserving the character of historic towns and assisting in urban regeneration.
34.The NPPF further confirms that, once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified (para 136 NPPF). Meeting an assessed housing need is not an exceptional circumstance. No other exceptional circumstances are put forward by Brentwood Borough Council.
35. Regardless, the NPPF is clear in that before concluding that exceptional circumstances exist to justify changing Green Belt boundaries Brentwood Borough Council should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified housing need (para 137 NPPF). In this respect the Parish Council and BVHA say:
35.1. There is no evidence that increasing densities elsewhere negates the need for the release of Green Belt land at sites R25 and R26. It should be remembered that the proposed Green Belt release, per Figure 4.2, only 123 of those homes are to be provided in the "larger villages" such as Blackmore which accounts for 1.5% of the total housing need (which includes a 20% buffer). This is a very modest contribution to housing supply which, the Parish Council and BVHA say, could easily be met by considering all other reasonable alternatives.
35.2. There are brownfield sites which should be identified, considered and used in preference.
35.3. There are also urban sites that should be used in preference, or alternatively, sites in more sustainable locations (i.e. close(r) to urban areas).
35.4. The village of Stondon Massey has actively sought new development within its boundaries. The same may be true of other villages within the Borough. Such "localised" development may reduce or negate the need for sites R25 and/or R26.
36.In consequence of the above, the Parish Council and BVHA say that Brentwood Borough Council has not demonstrated that it fully evidenced and justified a need to alter Green Belt boundaries nor that it has examined fully all other reasonable alternatives before doing so.
37.Further to the above, the notes to draft policy SP02 confirm that growth is prioritised "based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas where deemed appropriate" (para 4.22). The inclusion of R25 and R26 runs contrary to this - both being greenfield land in the Green Belt.
Whilst SP02 itself talks of the need to direct development to "highly accessible locations" - sites R25 and R26 are in a rural area with poor transport links and limited accessibility. The inclusion of R25 and R26 thus conflicts with policy SP02.
A Settlement Category 3 village?
38.As above the Parish Council and BVHA say that Blackmore should be classed as a Settlement Category 4 village and not the higher Category 3. They say this because: 38.1. There is no local shopping parade but, instead, one Co-Op Store (with Post
Office), a hairdressers and a coffee shop;
38.2. It does not have a health facility - the nearest Doctor's surgery is in
Doddinghurst (which is ~3 miles away and on roads not suitable for walking);
And 38.3. There are no, or very few, local jobs. Of those of working age nearly all
commute out of the village.
39. Accordingly, some of the key attributes of a Category 3 settlement are, in Blackmore's case, missing. As a more general point the population of Blackmore is modest and a considerable margin less than that of Doddinghurst and Kelvedon Hatch which are also classified as Category 3 settlements.
40.Further, of the Category 3 settlements it is only Blackmore (sites R25 and R26) and Kelvedon Hatch (sites R23 and R24) that it is proposed to allocate sites for housing/development. Kelvedon Hatch is in the order of 2.5 times larger (by population) than Blackmore - however its proposed housing allocation (total of ~53) is less, by approximately 25%, than that proposed for Blackmore.
41.This is in contrast to the larger Category 3 settlements of Doddinghurst and Ingrave which have no proposed allocation for housing. Indeed, no allocation is proposed for the other Category 3 settlements of Herongate and Mountnessing.
42.Simply put, the Parish Council and BVHA say that the classification of, and proposed housing allocation in, Blackmore is incorrect.
Other
43.The Parish Council and BVHA support the strategy within the plan. Indeed, in the main they recognise and support the policies within the draft plan. However, they take issue with allocations of sites R25 and R26; not only for the reasons above but when considered against the policy which Brentwood Borough Council are promoting. For example, sites R25 and R26 perform poorly against, or conflict with, draft policies SP01, SP02, SP03, NE01, NE09, BE12, BE13 and BE45. This is not withstanding the case that, in applying the NPPF, the Parish Council and BVHA say that development should be directed elsewhere in preference to sites R25 an R26.
44.The Parish Council and BVHA also take issue with the fact that of the 123 net homes allocated for "larger villages" 70, or approximately 56% of the total allocation, are met by these two sites. Thus, a disproportionately large amount of the allocation is from sites R25 and R26.
45.The above is notwithstanding the Parish Council and BVHA's primary contention that sites R25 and R26, but possibly all proposed sites on Green Belt Land in larger villages (i.e. settlement category 3), can and should be removed from the Plan.
46.The evidence of working with adjoining planning authorities is limited with a general statement that "adjacent planning authorities [have] confirmed that they [are] unwilling and unable to take any of the Brentwood identified housing need". The Parish Council and BVHA invite Brentwood Borough Council to more fully disclose the extent and nature of discussions that have been held with neighbouring authorities.
Summary/Conclusion
47.The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.
48.Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.
49.Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.
50.Sites R25 and R26 are in an unsustainable location served by a constrained access (Redrose Lane) and with an identified risk of flooding. The development of R25 and R26 does not represent sustainable development.
51.The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.
52.There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. Regardless, the proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).
53.The plan is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.
54.The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.
55.Brentwood Borough Council should amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.
HOLMES & HILLS LLP Dated 18 March 2019
Appendix 1: Photos of Redrose Lane with reference to size of Lane.
Appendix 2: Appendix Two - re R25 and R26 as Important Habitat sites
Blackmore Wildlife
The wildlife listed below has all been observed in the fields by Woollard Way and Orchard Piece and these fields provide invaluable nesting and foraging grounds.
Birds:
Redpoll, Yellowhammer, Skylarks, Barn Owls, Little Owls, Buzzard, Red Kite, Sparrowhawk, Song Thrush, Red-legged Partridges, Kestrels, Turtle Doves, Hedge sparrow, Siskin.
In particular Barn Owls and their nesting sites are protected by law during the breeding season - https://www.bto.org/volunteer-surveys/ringing/taking-part/protected-birds/s1- list
Turtle doves, Skylarks and Yellow Hammers are on the RSPB's red list which means,
amongst other things, that the species is globally threatened and are the highest priority for conservation - https://www.rspb.org.uk/birds-and-wildlife/wildlife-guides/uk- conservation-status-explained/

Reptiles:
Grass Snakes and Great Crested Newts which are a protected species -
https://www.wildlifetrusts.org/wildlife-explorer/amphibians/great-crested-newt
Photos of Owl; Sparrowhawk; reptile: newt; Bats:
All bats are protected by the law in the UK - https://www.bats.org.uk/advice/bats-and- the-law

They are frequently seen flying around the fields (i.e. R25 and R26) and there is possible nesting in the outbuildings.
Bats - video:
https://drive.google.com/file/d/15Be5ZUlvRwEDhh_ivlLf1fxb0Rf2QS3z/view
Appendix 3: Agricultural Lan Assessment and Flooding/Flood Risk mapping.
Photographs of Chelmsford Road and Redrose Lane Flooding 1987; 2016.
Flooding on The Green 2016; Flooding on Redrose Lane 2016 ((note depth of water). Redrose Lane 2018.

Extract from Daily Telegraph re: 2011 flooding.

Extract from Express re 2011 Flooding:
A woman is rescued from her car stuck in floodwater in Blackmore,
Essex, yesterday
Express - 18 Jan 2011
Fire Service in Redrose Lane east bound to Chelmsford Road.

Extract from Romford recorder RE: 2011 flooding

Remove site R25 from plan

1. This joint representation is made on behalf of:
1.1.The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2.The Blackmore Village Heritage Association ('BVHA')
Introduction
2. The Parish Council is a statutory consultee and represents 350 households in Blackmore village (population of only 943) included in a total population of 2,561 within the wider Parish with its three distinct separate settlements. This figure does not include the many households in neighbouring villages who rely on Blackmore's facilities.
3. BVHA is an unincorporated, not for profit, organisation and has in excess of 150 active members but its newsletters are distributed to over 1,000 households.
4. Both the Parish Council and BVHA strongly oppose the proposed allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land north of Orchard Piece, Blackmore) for housing development. The proposed allocation is for "around 40 new homes" at R25 and for "around 30 new homes" at R26.
5. They say that the proposed allocations R25 and R26 are contrary to both National and Local Policies.

6. In simple terms the Parish Council's and BVHA's case is as follows:
6.1.Brentwood Borough Council has failed to demonstrate that the required housing need cannot be met on existing previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites.
6.2.Without prejudice to the above contention, if no previously developed land/sites in existing urban areas or by increasing densities on proposed allocated sites exist, that Brentwood Borough Council has failed to demonstrate there are no or insufficient previously developed sites available outside the existing urban areas.
6.3.In any event, there are greenfield sites available (for example adjoining existing urban areas) in preferable and more sustainable locations.
6.4.Moreover, R25 and R26 are inherently unsuitable developments because of (1) inadequate access, (2) flooding, (3) it will result in disproportionate increase in the housing stock, and, (4) the development would not be sustainable.
7. The Parish Council and BVHA also take issue with the proposed allocation of Blackmore as a Category 3 settlement within the Local Plan Settlement Hierarchy (see pages 21-25 of the Regulation 19 Draft Local Plan).
8. Accordingly, the Parish Council and BVHA submit that the Local Plan, with proposed allocations R25 and R26 and the allocation of Blackmore as a "larger village", is unsound in that it has not been positively prepared, is not justified, is not effective nor consistent with the National Planning Policy Framework (February 2019 edition)('the NPPF').
Background
9. Blackmore is currently a village of approximately 350 dwellings which are home to 943 people (according to the Electoral Register). The proposal to add "around 70 homes" will add approximately 25% to the existing village housing stock. The proportionate increase to the village population would likely be greater by virtue of the number of current dwellings being occupied by two or less villagers. Outside of the LDP, housing stock is also increasing through normal planning processes both within Brentwood Borough Council and our neighbouring Epping Forest Council which will impact upon Blackmore village.
10.Blackmore is a picturesque village and surrounded by countryside. The Village Green has ponds at its eastern end. There is a village shop including post office, Primary School, two village halls, a sports and social club, tennis courts, football and cricket pitches, and a flood-lit Multi-Use Games Arena. All of these facilities are at capacity use. The village has three pubs: The Prince Albert, The Bull, and The Leather Bottle. In addition to the Anglican parish Church there is a Baptist Church in the village. However, Blackmore has a very limited bus service and is thus remote. It is over 6 miles from the centre of Brentwood and thus the villagers of Blackmore are reliant on the motor car.
11.The village School is at capacity and local residents are having to send children to neighbouring schools. There is limited scope for expansion. It is socially undesirable for some village children to be able to attend the village school and others to be "shipped out". This social harm (i.e. lack of cohesion) would be exacerbated if more resident village children had to be "shipped out" to another school.
12.In respect of employment opportunities within Blackmore these are limited and, of those of working age nearly all, if not all, commute out of the village. That commute takes place, if not exclusively, almost exclusively by private motor car. Such further evidences that Blackmore is an unsustainable location for new development.
13.Both R25 and R26 are on the Northern Boundary of the village of Blackmore. Both are bordered (to the north) by Redrose Lane, a rare extant example of a "plague detour route". Redrose Lane is narrow and with limited passing space for two motor cars. Vehicles larger than a car (i.e. Transit van and above) cannot pass without one, or the other, stopping (see Appendix One). Development of 70 dwellings would undoubtedly result in a significant number of vehicular movements - in the order of 600 to 700 per day - and, without suitable improvements (which would erode the character of Redrose Lane), cause harm.
14.Both R25 and R26 are in the Green Belt. Both are on land classified as "very good" agricultural land. Both sites have ecological value and, more importantly, local residents have reported sightings of bats, owls and newts at, or in the vicinity of, R25 and R26 (See Appendix Two).
15.Whilst the Environmental Agency classifies both sites within Flood Zone 1, both R25 and R26 have flooded historically - and both have an identified flood risk (see Appendix Three).
16.The BVHA undertook a survey in July 2018 of local residents and visitors to the Village. The BVHA survey confirms that residents are opposed to the proposed allocation of R25 and R26. Of the responses received from village residents, over
300, 98% were strongly opposed to the allocation of sites R25 and R26. It should be noted that the response numbers (over 300 adult residents in the village) was extremely good and evidences the strength of local feeling. It also outlines the engagement of the local Community.
Issues concerning Consultation and Consistency
17.It is a maxim that "good planning is consistent planning".
18.The Current Local Plan (the Brentwood Replacement Local Plan) dates to 2005 and tightly controls development in the Green Belt. Thus, development on R25 and R26 is contrary to the current Local Plan policies absent "very special circumstances".
19.In a 2014 site assessment document, which was and is part of the current emerging local plan process, sites R25 and R26 were discounted as they did not meet the (then) draft Local Plan spatial strategy.
20.It is not clear why this assessment has changed - indeed, the constraints surrounding site R25 and R26 remain unchanged.
21.More recently, in the Council's (Regulation 18) 2016 draft Local Plan, it was stated that "No amendment is proposed to the Green Belt boundaries surrounding larger villages [Blackmore is defined as a larger village] in order to retain the character of the Borough in line with the spatial strategy" (para 5.33). That spatial strategy seeking, insofar as it was necessary to do so, "limited release of Green Belt land for development within transport corridors, in strategic locations to deliver self- sustaining communities with accompanying local services, and urban extensions with clear defensible physical boundaries". So even though Brentwood Borough Council had identified a potential need for release of Green Belt land, no suitable land was identified in Blackmore.
22.There has therefore been a significant shift of policy; namely from a position of no development at R25 and R26 to now seeking to allocate these sites for residential development. The Parish Council and BVHA say that the change in position is inconsistent and wrong for reasons more fully set out below.
23.The Parish Council and BVHA also wish to record that the Council's planning Team, represented by a Strategic Director and three other Senior Officers, confirmed at a public meeting on 31 January 2019 that Blackmore's allocation was a result of property developers promoting the development of land on which their companies held options. The Parish Council and BVHA take the view that, not only would the proposed allocation of R25 and R26 appear to be "developer-led" rather than plan- led, it shows a lack of thorough and appropriate research, and understanding of the unique character and circumstances of Blackmore. The Parish Council and BVHA further take the view that developer pressure is not a good and sufficient reason for Brentwood Borough Council to abdicate its duty to promote a sound, and consistent, Development Plan.
Evidence Base
24.Paragraph 31 NPPF provides that the preparation and review of all policies should be underpinned by relevant and up-to-date evidence.
25.Part of the evidence is the "Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report - January 2019" ('the SA'). The SA tells us that a number of sustainability 'topics' inform the framework for assessing the sustainability of the site. Flooding is one of those topics (see Table 3.1 of the SA).
26.Risk of flooding is important to any sustainability appraisal not only because the NPPF and emerging policy NE06 seek to direct development away from areas of highest risk of flooding but also because flooding can put lives and property at risk. It is therefore surprising that, for all bar 21 potential sites, the SA does not consider flood risk in assessing sustainability.
27.The Level 1 Strategic Flood Risk Assessment does assess risk however and identifies a medium risk of surface water flooding for Redrose Lane (Table A4b) with Site R26 being potentially vulnerable to climate change and with a 1 in 100 annual probability of surface water flooding (Table A6b). The findings appear at odds with the fact that Sites R25 and R26 are lower than Redrose Lane and thus, one may expect, may be more vulnerable to flooding than higher land (i.e. Redrose Lane). Indeed, these sites have consistently flooded as evidenced by the photographs in Appendix Two.
28.There are, of course, documents supporting housing need. However, there is no evidence of local housing need for Blackmore, or any other villages. Whilst the Parish Council and BVHA accept that there may be some demand for housing any such demand should be properly evidenced with any housing allocation proportionate and ensuring that houses are being built in the right places.
Sustainable Development
29.It is a core planning principle that plans should be prepared with the objective of contributing to the achievement of sustainable development (para 16(a) NPPF). Paragraph 8 NPPF outlines three objectives that the planning system should strive to meet.
30.The proposed allocation of sites R25 and R26 meets none of these objectives in that: 30.1. Economic objective - any contribution arising from the construction of new dwellings will be short-lived. There are no, or extremely limited, employment opportunities within Blackmore and the likelihood of new residents driving a demand for new services within the village would appear, at best, limited. In
short, any economic benefits are short-term.
30.2. Social objective - services in Blackmore are limited and the primary school
is at capacity sending additional village children to school elsewhere will further
erode social cohesion.
30.3. Environmental objective - occupiers of sites R25 and R26 would
undoubtedly be reliant on private motor cars. The sites are at risk of flooding (surface water at least) and require the release of high-grade agricultural land in the Green Belt. Redrose Lane is narrow and infrastructure works would be required to make necessary improvements which would harm the character of this area but may also result in the loss of historic hedges and important habitats.
31.There are other sites which are in far more sustainable locations which should be allocated in preference. Indeed, the SA identifies a number of sites (n.b. no scoring for flood risk) with better scores than sites R25 and R26, good examples being in Shenfield, Mountnessing, Pilgrims Hatch, Ingatestone and Brentwood such as, but not limited to, sites 038A, 253, 277B, 297, 218B, 053B, 189, 318, 288B, 153, 280, 024A and 130.
32.Furthermore, development in less sustainable locations, such as R25 and R26, before more sustainable locations, should be avoided.
Green Belt
33.Sites R25 and R26 are in the Green Belt. The Government attaches great importance to Green Belts (per para 133 NPPF). The Green Belt serves five purposes (para 134
NPPF) which includes safeguarding the countryside from encroachment, preserving the character of historic towns and assisting in urban regeneration.
34.The NPPF further confirms that, once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified (para 136 NPPF). Meeting an assessed housing need is not an exceptional circumstance. No other exceptional circumstances are put forward by Brentwood Borough Council.
35. Regardless, the NPPF is clear in that before concluding that exceptional circumstances exist to justify changing Green Belt boundaries Brentwood Borough Council should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified housing need (para 137 NPPF). In this respect the Parish Council and BVHA say:
35.1. There is no evidence that increasing densities elsewhere negates the need for the release of Green Belt land at sites R25 and R26. It should be remembered that the proposed Green Belt release, per Figure 4.2, only 123 of those homes are to be provided in the "larger villages" such as Blackmore which accounts for 1.5% of the total housing need (which includes a 20% buffer). This is a very modest contribution to housing supply which, the Parish Council and BVHA say, could easily be met by considering all other reasonable alternatives.
35.2. There are brownfield sites which should be identified, considered and used in preference.
35.3. There are also urban sites that should be used in preference, or alternatively, sites in more sustainable locations (i.e. close(r) to urban areas).
35.4. The village of Stondon Massey has actively sought new development within its boundaries. The same may be true of other villages within the Borough. Such "localised" development may reduce or negate the need for sites R25 and/or R26.
36.In consequence of the above, the Parish Council and BVHA say that Brentwood Borough Council has not demonstrated that it fully evidenced and justified a need to alter Green Belt boundaries nor that it has examined fully all other reasonable alternatives before doing so.
37.Further to the above, the notes to draft policy SP02 confirm that growth is prioritised "based on brownfield land and land in urban areas first; and only then brownfield land in Green Belt areas where deemed appropriate" (para 4.22). The inclusion of R25 and R26 runs contrary to this - both being greenfield land in the Green Belt.
Whilst SP02 itself talks of the need to direct development to "highly accessible locations" - sites R25 and R26 are in a rural area with poor transport links and limited accessibility. The inclusion of R25 and R26 thus conflicts with policy SP02.
A Settlement Category 3 village?
38.As above the Parish Council and BVHA say that Blackmore should be classed as a Settlement Category 4 village and not the higher Category 3. They say this because: 38.1. There is no local shopping parade but, instead, one Co-Op Store (with Post
Office), a hairdressers and a coffee shop;
38.2. It does not have a health facility - the nearest Doctor's surgery is in
Doddinghurst (which is ~3 miles away and on roads not suitable for walking);
And 38.3. There are no, or very few, local jobs. Of those of working age nearly all
commute out of the village.
39. Accordingly, some of the key attributes of a Category 3 settlement are, in Blackmore's case, missing. As a more general point the population of Blackmore is modest and a considerable margin less than that of Doddinghurst and Kelvedon Hatch which are also classified as Category 3 settlements.
40.Further, of the Category 3 settlements it is only Blackmore (sites R25 and R26) and Kelvedon Hatch (sites R23 and R24) that it is proposed to allocate sites for housing/development. Kelvedon Hatch is in the order of 2.5 times larger (by population) than Blackmore - however its proposed housing allocation (total of ~53) is less, by approximately 25%, than that proposed for Blackmore.
41.This is in contrast to the larger Category 3 settlements of Doddinghurst and Ingrave which have no proposed allocation for housing. Indeed, no allocation is proposed for the other Category 3 settlements of Herongate and Mountnessing.
42.Simply put, the Parish Council and BVHA say that the classification of, and proposed housing allocation in, Blackmore is incorrect.
Other
43.The Parish Council and BVHA support the strategy within the plan. Indeed, in the main they recognise and support the policies within the draft plan. However, they take issue with allocations of sites R25 and R26; not only for the reasons above but when considered against the policy which Brentwood Borough Council are promoting. For example, sites R25 and R26 perform poorly against, or conflict with, draft policies SP01, SP02, SP03, NE01, NE09, BE12, BE13 and BE45. This is not withstanding the case that, in applying the NPPF, the Parish Council and BVHA say that development should be directed elsewhere in preference to sites R25 an R26.
44.The Parish Council and BVHA also take issue with the fact that of the 123 net homes allocated for "larger villages" 70, or approximately 56% of the total allocation, are met by these two sites. Thus, a disproportionately large amount of the allocation is from sites R25 and R26.
45.The above is notwithstanding the Parish Council and BVHA's primary contention that sites R25 and R26, but possibly all proposed sites on Green Belt Land in larger villages (i.e. settlement category 3), can and should be removed from the Plan.
46.The evidence of working with adjoining planning authorities is limited with a general statement that "adjacent planning authorities [have] confirmed that they [are] unwilling and unable to take any of the Brentwood identified housing need". The Parish Council and BVHA invite Brentwood Borough Council to more fully disclose the extent and nature of discussions that have been held with neighbouring authorities.
Summary/Conclusion
47.The Parish Council and BVHA represent the residents of Blackmore village - an overwhelming majority of whom are opposed to the inclusion of sites R25 and R26.
48.Sites R25 and R26 are in the Green Belt. There are no exceptional circumstances justifying their removal from the Green Belt. There is no evidence to demonstrate that all other reasonable alternatives have been explored - those alternatives including increasing densities or brownfield land and land in more urban/sustainable locations. The removal of sites R25 and R26 from the Green Belt is contrary to both local and national planning policies.
49.Development on R25 and R26 has historically been discounted, most recently as 2016. There is no change in local circumstances justifying development on sites R25 and R26 now.
50.Sites R25 and R26 are in an unsustainable location served by a constrained access (Redrose Lane) and with an identified risk of flooding. The development of R25 and R26 does not represent sustainable development.
51.The restricted access that Redrose Lane affords is inconsistent with Brentwood Borough Council's removal of Honey Pot Lane from the LDP on grounds of restricted access. At the Extraordinary Brentwood Council Meeting of 8th November a site known as Honeypot Lane, included in the Plan since inception, was withdrawn. This allocation, designed to include social and low-cost housing within 500m of the Town Centre, was removed due the narrowness of a small section of the road access that created a 'pinch-point', despite being bordered by open land providing opportunity for road widening. Unlike the continuously narrow and unpaved Redrose Lane, Honeypot Lane enjoys a double-width carriageway for all but a short section and is split between 20mph and 30mphs limits. Redrose Lane, where the national speed limit applies, is posted with weight restriction warning; whereas Honeypot Lane is not.
52.There is no evidence of a need for housing in the village of Blackmore. If there is a need then it has not been quantified by reference to number of type/size of property. Regardless, the proposed allocation accounts for a disproportionately large amount of development in "larger villages" within the Borough (i.e. >50% of the proposed Green Belt release in larger villages comes from Blackmore alone).
53.The plan is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified owing to the absence of proportionate evidence and a failure to assess all reasonable alternatives. The inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.
54.The Parish Council and BVHA believe that the change in approach, i.e. in seeking to allocate R25 and R26 now, is a result of developer pressure rather than a true assessment of the planning merit (or lack of) of sites R25 and R26 for residential development.
55.Brentwood Borough Council should amend the plan to retain R25 and R26 as Green Belt and not allocate them for housing.
HOLMES & HILLS LLP Dated 18 March 2019
Appendix 1: Photos of Redrose Lane with reference to size of Lane.
Appendix 2: Appendix Two - re R25 and R26 as Important Habitat sites
Blackmore Wildlife
The wildlife listed below has all been observed in the fields by Woollard Way and Orchard Piece and these fields provide invaluable nesting and foraging grounds.
Birds:
Redpoll, Yellowhammer, Skylarks, Barn Owls, Little Owls, Buzzard, Red Kite, Sparrowhawk, Song Thrush, Red-legged Partridges, Kestrels, Turtle Doves, Hedge sparrow, Siskin.
In particular Barn Owls and their nesting sites are protected by law during the breeding season - https://www.bto.org/volunteer-surveys/ringing/taking-part/protected-birds/s1- list
Turtle doves, Skylarks and Yellow Hammers are on the RSPB's red list which means,
amongst other things, that the species is globally threatened and are the highest priority for conservation - https://www.rspb.org.uk/birds-and-wildlife/wildlife-guides/uk- conservation-status-explained/

Reptiles:
Grass Snakes and Great Crested Newts which are a protected species -
https://www.wildlifetrusts.org/wildlife-explorer/amphibians/great-crested-newt
Photos of Owl; Sparrowhawk; reptile: newt; Bats:
All bats are protected by the law in the UK - https://www.bats.org.uk/advice/bats-and- the-law

They are frequently seen flying around the fields (i.e. R25 and R26) and there is possible nesting in the outbuildings.
Bats - video:
https://drive.google.com/file/d/15Be5ZUlvRwEDhh_ivlLf1fxb0Rf2QS3z/view
Appendix 3: Agricultural Lan Assessment and Flooding/Flood Risk mapping.
Photographs of Chelmsford Road and Redrose Lane Flooding 1987; 2016.
Flooding on The Green 2016; Flooding on Redrose Lane 2016 ((note depth of water). Redrose Lane 2018.

Extract from Daily Telegraph re: 2011 flooding.

Extract from Express re 2011 Flooding:
A woman is rescued from her car stuck in floodwater in Blackmore,
Essex, yesterday
Express - 18 Jan 2011
Fire Service in Redrose Lane east bound to Chelmsford Road.

Extract from Romford recorder RE: 2011 flooding

Remove site R25 from plan

House building on the site is not reasonable.
Redrose Lane is not fit for the traffic, being too narrow at places.
The installation of utilities will be difficult, being at the edge of the village.
The area is a natural relief floodplain for Blackmore, which already sees almost being cut off by deep water after periods of heavy rain and this development would make the situation worse.
The local community services are already at stretch - parking around the single shop is already a problem; there are no pavements in the area of Redrose Lane, making it potentially unsafe for local pedestrians if this and the adjacent development drive up local traffic.

Remove site R25 from plan

House building on the site is not reasonable.
Redrose Lane is not fit for the traffic, being too narrow at places.
The installation of utilities will be difficult, being at the edge of the village.
The area is a natural relief floodplain for Blackmore, which already sees almost being cut off by deep water after periods of heavy rain and this development would make the situation worse.
The local community services are already at stretch - parking around the single shop is already a problem; there are no pavements in the area of Redrose Lane, making it potentially unsafe for local pedestrians if this and the adjacent development drive up local traffic.

Remove site R25 from plan

House building on the site is not reasonable.
Redrose Lane is not fit for the traffic, being too narrow at places.
The installation of utilities will be difficult, being at the edge of the village.
The area is a natural relief floodplain for Blackmore, which already sees almost being cut off by deep water after periods of heavy rain and this development would make the situation worse.
The local community services are already at stretch - parking around the single shop is already a problem; there are no pavements in the area of Redrose Lane, making it potentially unsafe for local pedestrians if this and the adjacent development drive up local traffic.

Remove R25 from plan

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

Remove site R25 from plan

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

Remove site R25 from plan

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