POLICY R26: LAND NORTH OF ORCHARD PIECE

Showing comments and forms 91 to 120 of 1028

Object

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

Representation ID: 22990

Received: 10/03/2019

Respondent: Mr Anthony Cross

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Blackmore should be Settlement Category 4, rather than Category 3, as it is remote and it having poor public transport, limited shops, jobs and community facilities and it being reliant on nearby settlements for some of its services (doctors, vets, supermarkets etc.).

Change suggested by respondent:

Remove site R26 from plan

Full text:

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

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

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

Object

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

Representation ID: 23004

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The proposed development is on Green Belt land which 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.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken, as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23005

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23006

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The volume of traffic movements that would result from the proposed development would cause the access off Red Rose Lane to be entirely unsuitable. The lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed development is sustainable.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23007

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken, as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23008

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The proposed development sites are liable to flood and this 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. 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.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken, as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23009

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Blackmore village has very basic services and infrastructure including minimal bus services to Brentwood and Chelmsford. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23010

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The village primary school is already full. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23011

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23012

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing
development would cause a significant negative impact on all of these services and congestion.The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23013

Received: 14/03/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Site R26 is home to a number of protected species including turtle doves, skylarks 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.

Change suggested by respondent:

- Brentwood Borough Council is required to demonstrate that no other brownfield sites are available which should take priority over Green Belt development.
- Highway/traffic assessments, flood risk/drainage assessment, detailed ecological surveys and 'Housing Need survey' of Blackmore village should be undertaken as it stands the LDP is not justified because it is not based on proportionate evidence.

Full text:

- 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.
- 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.
- The volume of traffic movements that would result from the proposed development
would cause the access off Red Rose Lane, Blackmore to be entirely unsuitable. The
lane is narrow and does not have pavements for pedestrians. There are ditches on either side and two cars cannot pass each other without pulling to the side. The extra traffic would cause a major hazard because Redrose Lane is regularly used by walkers, cyclists and horse riders. The LDP has not demonstrated that the proposed
development off Red Rose Lane is sustainable.
- Brentwood Borough Council has not demonstrated a clear development strategy for
the villages in the north of Brentwood Borough, including Blackmore. The housing needs of the villages have not been specifically assessed. The LDP has not been positively prepared because there is no strategy which seeks to meet the villages
objectively assessed needs.
- Brentwood Borough Council has not consulted adequately with the neighbouring
authorities and considered the impact of developments in the neighbouring vicinity
such as Epping Forest District Council. There are approximately 30 new homes in a
new development on Fingrith Hall Lane, and it is highly likely that the residents of
these homes will use Blackmore village infrastructure. The impact of this new
development has not been taken into account in the LDP. The LDP is required to be
informed by agreements with other authorities.
- Other planned housing developments in or near to Blackmore village include in Red
Rose Farm and on Spriggs Lane. Again, it is highly likely that the residents in these
developments will rely on Blackmore infrastructure and this will result in increased
use of services that have not been taken into account in the LDP.
- Blackmore village has very basic services and infrastructure including minimal bus
services to Brentwood and Chelmsford. The village primary school is already full, the
nearest doctors' surgery is severely overstretched with increasingly long waiting times for appointments. The village centre is often very congested with parked cars near the local shop, making it difficult to park or turn at the junction or park. Further housing development would cause a significant negative impact on all of these services and congestion. The LDP does not demonstrate that the level of proposed development in Blackmore can be accommodated by existing infrastructure, and the plan is therefore not consistent with achieving sustainable development.
- 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.
- There are other more suitable and sustainable locations within Brentwood Borough
Council with much better access to urban development, and locations such as
Blackmore do not promote sustainable development.
- The proposed development sites are liable to flood and this 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.
-PLEASE REFER TO BLACKMORE VILLAGE HERITAGE ASSOCIATION (BVHA)
NEIGHBOURHOOD PLAN
- Brentwood Borough Council is 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 should conduct a 'Housing Need survey' of Blackmore
village to demonstrate that the development is justified. This modification should be
included to ensure that the LDP is sound - as it stands the LDP is not justified because it is not based on proportionate evidence.

Attachments:

Object

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

Representation ID: 23014

Received: 14/03/2019

Respondent: Mrs Ruth Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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 contrary to national policy. As it stands the LDP is not justified because it is not based on proportionate evidence.

Change suggested by respondent:

Detailed ecological surveys should be undertaken.

Full text:

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

Attachments:

Object

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

Representation ID: 23015

Received: 14/03/2019

Respondent: Mrs Ruth Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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

Change suggested by respondent:

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

Full text:

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

Attachments:

Object

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

Representation ID: 23016

Received: 14/03/2019

Respondent: Mrs Ruth Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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

Change suggested by respondent:

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

Full text:

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

Attachments:

Object

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

Representation ID: 23017

Received: 14/03/2019

Respondent: Mrs Ruth Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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

Change suggested by respondent:

Flood risk/drainage assessment should be undertaken.

Full text:

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

Attachments:

Object

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

Representation ID: 23018

Received: 14/03/2019

Respondent: Mrs Ruth Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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

Full text:

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

Attachments:

Object

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

Representation ID: 23019

Received: 14/03/2019

Respondent: Mrs Ruth Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

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

Change suggested by respondent:

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

Full text:

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

Attachments:

Object

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

Representation ID: 23028

Received: 08/04/2019

Respondent: Mr Andrew Chambers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

School full

Change suggested by respondent:

Remove site 26 from plan

Full text:

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Object

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

Representation ID: 23030

Received: 08/04/2019

Respondent: Mr Andrew Chambers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Green Belt Land should not be used as a building ground.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The Plan relating to Blackmore is unsound because:

Green Belt Land should not be used as a building ground.

Red Rose Lane is prone to flooding and is far too narrow for the access to a housing estate.

The parking in the village is diabolical already. Blackmore is a lovely village which already has a lot of visitors. Lack of parking already affects the economy you are destroying our lovely village and affecting our economy detrimentally.

Doctors surgery is not coping with the people it serves now. We have to wait a long time for an appointment now which will only get worse - very infuriating!

The school is already full with a long waiting list and will not cope with a large influx of children!

The ground has insufficient grounds to extend and this then affects all of the children who currently go to the school.

The services currently in Blackmore will not cope with the number of families coming if all the houses are built.

Attachments:

Object

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

Representation ID: 23031

Received: 08/04/2019

Respondent: Mr Andrew Chambers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Red Rose Lane is far too narrow for the access to a housing estate.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The Plan relating to Blackmore is unsound because:

Green Belt Land should not be used as a building ground.

Red Rose Lane is prone to flooding and is far too narrow for the access to a housing estate.

The parking in the village is diabolical already. Blackmore is a lovely village which already has a lot of visitors. Lack of parking already affects the economy you are destroying our lovely village and affecting our economy detrimentally.

Doctors surgery is not coping with the people it serves now. We have to wait a long time for an appointment now which will only get worse - very infuriating!

The school is already full with a long waiting list and will not cope with a large influx of children!

The ground has insufficient grounds to extend and this then affects all of the children who currently go to the school.

The services currently in Blackmore will not cope with the number of families coming if all the houses are built.

Attachments:

Object

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

Representation ID: 23034

Received: 08/04/2019

Respondent: Mr Andrew Chambers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Red Rose Lane is prone to flooding.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The Plan relating to Blackmore is unsound because:

Green Belt Land should not be used as a building ground.

Red Rose Lane is prone to flooding and is far too narrow for the access to a housing estate.

The parking in the village is diabolical already. Blackmore is a lovely village which already has a lot of visitors. Lack of parking already affects the economy you are destroying our lovely village and affecting our economy detrimentally.

Doctors surgery is not coping with the people it serves now. We have to wait a long time for an appointment now which will only get worse - very infuriating!

The school is already full with a long waiting list and will not cope with a large influx of children!

The ground has insufficient grounds to extend and this then affects all of the children who currently go to the school.

The services currently in Blackmore will not cope with the number of families coming if all the houses are built.

Attachments:

Object

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

Representation ID: 23036

Received: 08/04/2019

Respondent: Mr Andrew Chambers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The parking in the village is diabolical already. Lack of parking already affects the economy you are destroying our lovely village and affecting our economy detrimentally.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The Plan relating to Blackmore is unsound because:

Green Belt Land should not be used as a building ground.

Red Rose Lane is prone to flooding and is far too narrow for the access to a housing estate.

The parking in the village is diabolical already. Blackmore is a lovely village which already has a lot of visitors. Lack of parking already affects the economy you are destroying our lovely village and affecting our economy detrimentally.

Doctors surgery is not coping with the people it serves now. We have to wait a long time for an appointment now which will only get worse - very infuriating!

The school is already full with a long waiting list and will not cope with a large influx of children!

The ground has insufficient grounds to extend and this then affects all of the children who currently go to the school.

The services currently in Blackmore will not cope with the number of families coming if all the houses are built.

Attachments:

Object

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

Representation ID: 23039

Received: 08/04/2019

Respondent: Mr Andrew Chambers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Doctors surgery is not coping with the people it serves now. We have to wait a long time for an appointment now which will only get worse.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The Plan relating to Blackmore is unsound because:

Green Belt Land should not be used as a building ground.

Red Rose Lane is prone to flooding and is far too narrow for the access to a housing estate.

The parking in the village is diabolical already. Blackmore is a lovely village which already has a lot of visitors. Lack of parking already affects the economy you are destroying our lovely village and affecting our economy detrimentally.

Doctors surgery is not coping with the people it serves now. We have to wait a long time for an appointment now which will only get worse - very infuriating!

The school is already full with a long waiting list and will not cope with a large influx of children!

The ground has insufficient grounds to extend and this then affects all of the children who currently go to the school.

The services currently in Blackmore will not cope with the number of families coming if all the houses are built.

Attachments:

Object

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

Representation ID: 23041

Received: 08/04/2019

Respondent: Mr Andrew Chambers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The school is already full with a long waiting list and will not cope with a large influx of children!

The ground has insufficient grounds to extend and this then affects all of the children who currently go to the school.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The Plan relating to Blackmore is unsound because:

Green Belt Land should not be used as a building ground.

Red Rose Lane is prone to flooding and is far too narrow for the access to a housing estate.

The parking in the village is diabolical already. Blackmore is a lovely village which already has a lot of visitors. Lack of parking already affects the economy you are destroying our lovely village and affecting our economy detrimentally.

Doctors surgery is not coping with the people it serves now. We have to wait a long time for an appointment now which will only get worse - very infuriating!

The school is already full with a long waiting list and will not cope with a large influx of children!

The ground has insufficient grounds to extend and this then affects all of the children who currently go to the school.

The services currently in Blackmore will not cope with the number of families coming if all the houses are built.

Attachments:

Object

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

Representation ID: 23043

Received: 08/04/2019

Respondent: Mr Andrew Chambers

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The services currently in Blackmore will not cope with the number of families coming if all the houses are built.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The Plan relating to Blackmore is unsound because:

Green Belt Land should not be used as a building ground.

Red Rose Lane is prone to flooding and is far too narrow for the access to a housing estate.

The parking in the village is diabolical already. Blackmore is a lovely village which already has a lot of visitors. Lack of parking already affects the economy you are destroying our lovely village and affecting our economy detrimentally.

Doctors surgery is not coping with the people it serves now. We have to wait a long time for an appointment now which will only get worse - very infuriating!

The school is already full with a long waiting list and will not cope with a large influx of children!

The ground has insufficient grounds to extend and this then affects all of the children who currently go to the school.

The services currently in Blackmore will not cope with the number of families coming if all the houses are built.

Attachments:

Object

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

Representation ID: 23050

Received: 08/04/2019

Respondent: Miss Natalie Smith

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Green belt land should be preserved and not used for building ground.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The plan relating to Blackmore is unsound because:

Green belt land should be preserved and not used for building ground.

Parking in the village is already insufficient and is a struggle for residents. Blackmore has lots of visitors and the lack of parking already affects the economy hugely. More vehicles and need for parking would ruin the village and have a detrimental effect on the village, also making it less safe for local residents and children.

The facilities and services in the village will not cope with the additional residents and families coming into the village, it will become far too overcrowded.

The local primary school is already full at maximum capacity with a long waiting list, and will not be able to cope with a large influx of additional children. The school has insufficient extra ground to be able to extend its facilities to be able to accommodate for extra children. Neighbouring villages schools are also at maximum capacity.

The doctors surgery already struggles with the amount of local residents in the area as it is. It would not be able to cope with the needs and demands of a large number of additional residents. The waiting list is to be seen is already long, and this would only get worse and affect the service residents need.

Red Rose Lane is far too narrow for it to provide access to a busy housing estate and is prone to flooding.

Attachments:

Object

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

Representation ID: 23053

Received: 08/04/2019

Respondent: Miss Natalie Smith

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Parking in the village is already insufficient and is a struggle for residents. Blackmore has lots of visitors and the lack of parking already affects the economy hugely. More vehicles and need for parking would ruin the village and have a detrimental effect on the village, also making it less safe for local residents and children.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The plan relating to Blackmore is unsound because:

Green belt land should be preserved and not used for building ground.

Parking in the village is already insufficient and is a struggle for residents. Blackmore has lots of visitors and the lack of parking already affects the economy hugely. More vehicles and need for parking would ruin the village and have a detrimental effect on the village, also making it less safe for local residents and children.

The facilities and services in the village will not cope with the additional residents and families coming into the village, it will become far too overcrowded.

The local primary school is already full at maximum capacity with a long waiting list, and will not be able to cope with a large influx of additional children. The school has insufficient extra ground to be able to extend its facilities to be able to accommodate for extra children. Neighbouring villages schools are also at maximum capacity.

The doctors surgery already struggles with the amount of local residents in the area as it is. It would not be able to cope with the needs and demands of a large number of additional residents. The waiting list is to be seen is already long, and this would only get worse and affect the service residents need.

Red Rose Lane is far too narrow for it to provide access to a busy housing estate and is prone to flooding.

Attachments:

Object

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

Representation ID: 23056

Received: 08/04/2019

Respondent: Miss Natalie Smith

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The facilities and services in the village will not cope with the additional residents and families coming into the village, it will become far too overcrowded.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The plan relating to Blackmore is unsound because:

Green belt land should be preserved and not used for building ground.

Parking in the village is already insufficient and is a struggle for residents. Blackmore has lots of visitors and the lack of parking already affects the economy hugely. More vehicles and need for parking would ruin the village and have a detrimental effect on the village, also making it less safe for local residents and children.

The facilities and services in the village will not cope with the additional residents and families coming into the village, it will become far too overcrowded.

The local primary school is already full at maximum capacity with a long waiting list, and will not be able to cope with a large influx of additional children. The school has insufficient extra ground to be able to extend its facilities to be able to accommodate for extra children. Neighbouring villages schools are also at maximum capacity.

The doctors surgery already struggles with the amount of local residents in the area as it is. It would not be able to cope with the needs and demands of a large number of additional residents. The waiting list is to be seen is already long, and this would only get worse and affect the service residents need.

Red Rose Lane is far too narrow for it to provide access to a busy housing estate and is prone to flooding.

Attachments:

Object

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

Representation ID: 23058

Received: 08/04/2019

Respondent: Miss Natalie Smith

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The local primary school is already full at maximum capacity with a long waiting list, and will not be able to cope with a large influx of additional children. The school has insufficient extra ground to be able to extend its facilities to be able to accommodate for extra children. Neighbouring villages schools are also at maximum capacity.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The plan relating to Blackmore is unsound because:

Green belt land should be preserved and not used for building ground.

Parking in the village is already insufficient and is a struggle for residents. Blackmore has lots of visitors and the lack of parking already affects the economy hugely. More vehicles and need for parking would ruin the village and have a detrimental effect on the village, also making it less safe for local residents and children.

The facilities and services in the village will not cope with the additional residents and families coming into the village, it will become far too overcrowded.

The local primary school is already full at maximum capacity with a long waiting list, and will not be able to cope with a large influx of additional children. The school has insufficient extra ground to be able to extend its facilities to be able to accommodate for extra children. Neighbouring villages schools are also at maximum capacity.

The doctors surgery already struggles with the amount of local residents in the area as it is. It would not be able to cope with the needs and demands of a large number of additional residents. The waiting list is to be seen is already long, and this would only get worse and affect the service residents need.

Red Rose Lane is far too narrow for it to provide access to a busy housing estate and is prone to flooding.

Attachments:

Object

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

Representation ID: 23059

Received: 08/04/2019

Respondent: Miss Natalie Smith

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The doctors surgery already struggles with the amount of local residents in the area as it is. It would not be able to cope with the needs and demands of a large number of additional residents. The waiting list is to be seen is already long, and this would only get worse and affect the service residents need.

Change suggested by respondent:

The immediate withdrawal of site R26.

Full text:

The plan relating to Blackmore is unsound because:

Green belt land should be preserved and not used for building ground.

Parking in the village is already insufficient and is a struggle for residents. Blackmore has lots of visitors and the lack of parking already affects the economy hugely. More vehicles and need for parking would ruin the village and have a detrimental effect on the village, also making it less safe for local residents and children.

The facilities and services in the village will not cope with the additional residents and families coming into the village, it will become far too overcrowded.

The local primary school is already full at maximum capacity with a long waiting list, and will not be able to cope with a large influx of additional children. The school has insufficient extra ground to be able to extend its facilities to be able to accommodate for extra children. Neighbouring villages schools are also at maximum capacity.

The doctors surgery already struggles with the amount of local residents in the area as it is. It would not be able to cope with the needs and demands of a large number of additional residents. The waiting list is to be seen is already long, and this would only get worse and affect the service residents need.

Red Rose Lane is far too narrow for it to provide access to a busy housing estate and is prone to flooding.

Attachments: