Policy R01 (I): Dunton Hills Garden Village Strategic Allocation (page 252)

Showing comments and forms 31 to 60 of 546

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26784

Received: 25/11/2019

Respondent: Mr Gary Dimond

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Agree, Dunton Hills can accommodate the site planned for Blackmore.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26789

Received: 25/11/2019

Respondent: Historic England

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

The site contains three Grade II listed buildings and is surrounded by a range of other designated heritage assets. Development on site therefore has the potential to harm the significance designated heritage assets within the setting of the site. A Heritage Impact Assessment (HIA) is required to justify its allocation, inform the potential capacity of the site, and any mitigation measures necessary to accompany the proposals. Additional characterisation and archaeological investigations will also be fundamental to understanding the capacity of development on site.

Change suggested by respondent:

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken. The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form. Further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base

Full text:

Re: Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

Thank you for consulting Historic England on the Brentwood Local Development Plan - Focussed changes to the Pre-Submission Local Plan (Regulation 19), October 2019.

We understand that the Council has taken the opportunity to put forward focussed changes to the Brentwood Pre-Submission Local Plan (Pre-Submission Draft, Regulation 19, February 2019), and note that the amendments do not alter the Plan's spatial strategy but seek to respond to concerns in specific areas of the Borough by redistributing housing growth.

As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment. We hope that the following comments and observations are helpful.

Focussed change no. 1) Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation)

We note that the Council is proposing to amend the policy from "at least 2,700" to "at least 2,770 homes in the plan period".

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) and most recently in response to your Environmental Impact Assessment (EIA) Scoping Opinion Request for the site, that this allocation has the potential to harm the significance of a number of designated heritage assets within the setting of the site, and that a Heritage Impact Assessment (HIA) is required to justify its allocation, inform the potential capacity of the site, and any mitigation measures necessary to accompany the proposals.

The site contains three Grade II listed buildings:
* Dunton Hall - an early C19 yellow brick house, which may enclose an earlier C18 building;
* Church of St May - Church rebuilt in 1873 by WG Bartleet; and
* Dunton Hills - House with cottage attached, C17.

In addition to these listed buildings within the site, it is surrounded by a range of other designated heritage assets including to the north-east of the site:

* Wayletts (Grade II Listed)- a C16 timber framed and plastered farmhouse;
* East Horndon Hall (Grade II Listed) - house C16 and C18, extended C19 and C20;

To the north-west of the site:

* Church of All Saints (Grade II* Listed) - C15, C16, and early C17;
* Stabling at Church of All Saints (Grade II Listed); and
* Firemans Monument in Churchyard of All Saints Church (Grade II Listed).

And further to the north-west, across the A127 and the Brentwood Road:

* Thorndon Hall - Grade II* Registered Park and Garden (RPAG);
* Thorndon Park Conservation Area; and
* Old Thorndon Hall and Garden Scheduled Monument

It is acknowledged that some of these surrounding heritage assets are severed from the site by the A127 and therefore the detailed consideration of setting will be a matter of material importance when considering the impact of development upon the significance of nearby assets. It is also not clear how the listed properties within the site are to be treated, or what evidence has been provided to support this allocation.
As well as these designated heritage assets, any consideration of development on this site would also need to include an assessment of impact on non-designated heritage assets, including buildings on the Local List that may be located within or in close proximity to the site. That assessment would need to include a consideration of the archaeological potential of the site and the County Archaeologist will be best place to advise on such matters.

Given the sensitive nature of the site and given the lack of supporting evidence on the historic environment, we reiterate our request that a Heritage Impact Assessment (HIA) is undertaken in accordance with our advice note 'Site allocations in Local Plans' (<https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/heag074-he-and-site-allocation-local-plans/>). The HIA should determine the appropriateness or otherwise of the site for development, the extent of the development and therefore potential capacity of the site, the impacts upon the historic environment (considering each asset and its setting and its significance), impacts of development upon the asset and any potential mitigation measures necessary to accompany the proposals. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Historic England also recommends that further archaeological investigation is undertaken as well as landscape characterisation work to inform the evidence base. Essex County Council holds a series of Historic Landscape Characterisation Studies which will be a useful starting point and should form part of the evidence base to support this allocation. Characterisation work will be fundamental to understanding the capacity of development in the Dunton Hills Garden Suburb. Additional characterisation and archaeological investigations could be amalgamated into the HIA or can form separate documents.

Focussed change no. 2) Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 3) Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";

There are no designated heritage assets within or near to the site. Historic England has no comments to make on this focussed change.

Focussed change no. 4) Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"

We acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that two Grade II listed buildings - The Woodbines and Horselocks Cottage - are located to the immediate east of the site whilst the Grade II listed Wells Farmhouse is located to the north of the site. The Blackmore Conservation Area is to the south of the site, which contains a number of individual listed buildings. Any development of the site will need to be sensitive to this edge of settlement location and relate to the open landscape around it as well as to the historic settlement it adjoins. The surrounding land is of historic interest and also makes a positive contribution to the character and appearance of the conservation area. The cumulative impacts of the development of this site and that of site R26 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Focussed change no. 5) Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".

As with R25, we acknowledge the proposed modification, but maintain our position as set out in our response to your regulation 18 consultation (dated 26th March 2018) that the development of this site has the potential to harm the significance of a number of designated heritage assets including the Grade II listed The Woodbines and Horselocks Cottage, and the Blackmore Conservation Area by eroding their setting. We recommend that Policy R26 includes a criterion to help secure a high quality development which respects the setting of the nearby listed buildings and conservation area. The policy should refer to the sites' sensitive edge of settlement location, and the need for high quality design which will relate to both the rural surroundings to the north and to the historic settlement adjoining the site to the south. Careful master planning will be required to ensure the scale and density of the development is appropriate for the location. The cumulative impacts of the development of this site and that of R25 must be taken into account in order to ensure the setting of these listed buildings and conservation area is not compromised. Development of this site will need to conserve and, where opportunities arise, enhance these heritage assets and their settings. The development should be of high quality design. These requirements should be included in any site specific policy and supporting text of the Plan.
Conclusions

I hope that you find the above comments helpful. I'd like to stress that this response is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise as a result of this plan, where we consider that these would have an adverse effect upon the historic environment. Please note that absence of a comment on a proposed modification in this letter does not mean that Historic England is content.

If you have any questions with regards to the comments made then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime we look forward to continuing to work with you and your colleagues.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26790

Received: 25/11/2019

Respondent: Hallam Land Management Ltd

Agent: Marrons Planning

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

No clear or sufficient evidence to demonstrate that the housing trajectory for R01 Dunton Hills Garden Village in Appendix 1 is justified. Whilst the change is a relatively small increase, given the absence of evidence to support the rate of delivery proposed, an objection is maintained. As also noted from the Sustainability Appraisal Addendum (paragraph 2.9.3), there is a degree of increased risk associated with reliance on this site, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery.

Full text:

Focussed Change 1 increases the minimum number of dwellings to be delivered at Dunton Hills Garden Village by 2032/33 by 70 dwellings to 2,770 dwellings. Whilst the change is a relatively small increase, given the absence of evidence to support the rate of delivery proposed, an objection is maintained.
It is noted from the Sustainability Appraisal Addendum (paragraph 2.9.3) that it concluded there is a degree of increased risk associated with reliance on this site, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery. Although it also noted discussions between the Council and site promoter indicated this was deliverable, it maintained there was an uncertain negative implication for the achievement of the Housing objectives.
Therefore, given the concerns shared with the authors of the Sustainability Appraisal, and in the absence of any evidence to demonstrate the amended number of dwellings is capable of being delivered within the Plan period, an objection is made to the focussed change on the grounds of soundness that it is not justified, as required by the Framework.
Appendix 1: Schedule of Focussed Changes
HLM submitted an objection to the Pre-Submission Local Plan on the grounds that it does not demonstrate a five year supply on adoption of the Plan.
Focussed Change 13 within the Schedule amends the Local Development Plan Housing Trajectory and reduces the five year supply of deliverable housing by 70 dwellings. This is on the basis of the Plan being adopted in 2020, and the five year supply being calculated for Years 5 to 9 of the trajectory. Whilst the change is a relatively small reduction in supply, it still further reduces supply and an objection is maintained on the grounds of soundness in that it is not consistent with national policy in failing to identify a five year supply of specific deliverable sites against the housing requirement.
Sustainability Appraisal Addendum
HLM submitted an objection to the Pre-Submission Local Plan on the grounds that the Spatial Strategy is reliant upon the delivery of a significant level of growth away from where the vast majority of housing and employment needs of the Borough are derived (Central Brentwood Growth Corridor). The comment is made that it is noted from the Sustainability Appraisal Addendum (paragraph 2.9.4) that this concern is now acknowledged.
HLM also submitted an objection to the Pre-Submission Local Plan on the grounds that the housing provision within Policy SP02 does not reflect the minimum number of homes needed. The comment is made that it is noted from the Sustainability Appraisal Addendum (paragraphs 2.9.3 and 2.9.5) that it is acknowledged the minimum number of homes needed (Local Housing Need) now equates to 454 dwellings per annum, which as a consequence means the Plan no longer makes any provision for a housing supply buffer. The Addendum therefore notes that the absence of a buffer, and the greater reliance upon one site (Dunton Hills Garden Village) to meet the housing need in a location some distance from where the need is largely derived (Central Brentwood) places a greater degree of uncertainty and risk that the Housing objectives will not be met.
As housing affordability is acknowledged as a significant concern for the Borough, HLM would respectfully request the Council consider through the Examination process additional allocation(s) within the Central Brentwood area in order to maintain its supply buffer and reduce the uncertainty and risks associated with the current Plan in relation to failing to meet housing need in areas where the need is derived. In this regard, HLM would also encourage the Council again to consider the evidence submitted as to the benefits of allocating or safeguarding Land west of Ongar Road for residential development.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26804

Received: 26/11/2019

Respondent: M Scott Properties Ltd

Agent: Strutt & Parker LLP

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Cross-boundary and Statutory Consultee Objections: Basildon Borough Council have objected to the DHGV allocation raising concerns regarding the cross-boundary impacts of this site. Similarly, Essex County Council also raised concerns in respect of the transport evidence base for DHGV. As part of the Focussed Changes, the Council have seemingly overlooked these comments, in the absence of any evidence to the contrary, seeking instead to direct more housing numbers to this allocation within the Plan period, and failing to consider any reasonable alternatives.

Full text:

1.0 Introduction
1.1 These representations have been prepared by Strutt & Parker on behalf of M Scott Properties Ltd (Scott Properties) pursuant to Brentwood Borough Council's (the Council) Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) (Focussed Changes). They are submitted in addition to and should be read alongside those submitted in response to the previous Regulation 19 consultation held in February - March 2019.
1.2 Scott Properties have an interest in land to the west of Crossby Close, Mountnessing (the Site), which has been actively promoted as part of the Council's plan-making process, site reference 073 (AECOM (January 2019) SA Report). Previous representations have been made at various stages of the Local Plan, including the Call for Sites exercises and each consultation regarding the emerging Local Plan.
1.3 Scott Properties, in their capacity as a provider of specialist accommodation, are promoting the Site for specialist accommodation for those aged 55 and over, as well as those with, or supporting someone with a disability, in order to address an identified and unmet need locally and within the Borough.
1.4 Our earlier response to the Regulation 19 Consultation included evidence which demonstrated the existence of a local need for specialist accommodation within Mountnessing, and support for this type of accommodation through an online local needs consultation which received 92 positive responses.
1.5 These representations raise concerns as to:
 the impact of the higher Local Housing Need (LHN) figure;
 the lack of reasonable alternatives considered in making the Focussed Changes;
 the ability of the Focussed Changes to meet local housing needs, particularly older people; and
 the robustness of the SHLAA in light of the Focussed Changes.
2.0 Higher Local Housing Need (LHN)
2.1 These representations seek to focus on the proposed focussed changes to the Pre-Submission Local Plan (PSLP), set out in the consultation draft of the Focussed Changes. However, there are inevitable consequences resulting from the proposed amendments that draw together matters not specifically intended to be the focus of the addendum. We highlight these to ensure there is a holistic understanding of the effects of the changes proposed in the addendum and changes to national and local circumstances that should be considered prior to submission of the Plan.
2.2 Since the publication of the Pre-Submission Local Plan, Planning Practice Guidance (PPG) has been updated (in February 2019, during the previous Regulation 19 consultation) and confirms that the 2014-based subnational household projections should be used to calculate the housing requirement using the Standard Method.1 The Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report Addendum - October 2019 (the SA Addendum) confirms at paragraph 2.9.3 that the LHN figure is now understood to equate to 454 dwellings per annum (dpa).
2.3 We expressed our concerns in our response to the previous Regulation 19 representations that there was insufficient flexibility within the PSLP's target figure of 456 dpa, which incorporates a 20% buffer on the housing requirement of 350 dpa as set out therein.2 Based on the actual housing need figure, as confirmed at 454 dpa within the SA Addendum, there now exists a buffer of just two dwellings per annum, which does not provide sufficient flexibility to ensure the Borough's housing needs are met. This is confirmed in paragraph 2.9.6 of the SA Addendum, which states that:
"the proposed supply figure of 456 dpa can no longer be said to put in place a significant 'buffer' over-and above the housing requirement."
2.4 In addition, it also highlights the risks of delays in delivery, as a result of increasing the housing supply to be provided at Dunton Hill Garden Village (DHGV) within the Plan period, confirming the importance of a buffer over-and-above the housing requirement for this reason. The Nathaniel Litchfield Study From Start to Finish (2016) confirms that the planning process takes on average 2.5 years for a planning application determination period for schemes of up to 500 units, but that this can double for schemes of 1,000 units and over. This not only confirms that it is unlikely that DHGV will deliver as early as 2022/23 as stated in the housing trajectory, but also points towards a necessity to ensure there is adequate provision within the Plan to meet housing requirements in the short-term. Within our earlier representations we stated that is was unrealistic that DHGV could deliver 100 dwellings as soon as 2022/23 as set out in the PSLP. Given that this was predicated (partly) on the adoption of the Local Plan in 2019, this timeframe is now clearly unrealistic and adoption by the end of 2020 remains challenging, with obvious implications for the proposed trajectory.
2.5 We consider that the Focussed Changes should have included an update to the LHN and the trajectory, without which the Plan can no longer be considered sound. Paragraph 11 of the NPPF requires plan-makers to positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change (our emphasis). It is considered that this is now not the case as a result of the updated LHN, given the Focussed Changes make no attempt to positively seek opportunities to meet development needs within the Borough. This is also set out in our comments regarding the lack of consideration of reasonable alternatives. This renders the plan inconsistent with national policy and unsound.
2.6 Paragraph 2.9.3 of the SA Addendum states that:
"It is fair to conclude that there is naturally a degree of increased risk associated with reliance on DHGV, as this is a large and complex site associated with delivery challenges, including in respect of infrastructure delivery; however, discussions between the Council and the site promoter have served to indicate that the 70 homes additionally assigned to the site through the Focussed Changes are deliverable within the plan period, and indeed can be delivered in a timely fashion such that the Local Plan housing delivery trajectory is unaffected."
2.7 The updated housing trajectory in the Focussed Changes shows the 70 homes reallocated to DHGV, as a result of the decreases from Focused Changes numbers.2-5, between years 15 and 17 (2030-2033), which does not represent delivery in a 'timely fashion', nor is the trajectory unaffected as a result. The Focussed Changes reduce the housing delivery within the earlier years of the Plan and thus the Plan's ability to meet its needs within those years. Our concern as to the robustness of the decision to adopted a stepped trajectory as raised in our response to the previous Regulation 19 consultation remains. We consider that the effect of the Focussed Changes in further reducing the Plan's ability to meet its needs within the earlier years of the Plan; a concern that we raised in our previous Regulation 19 response.
2.8 We have concerns as to the accuracy of the updated housing trajectory, which shows an increase in the Total Housing Provision within years 12 and 13, but no corresponding increases within the expected delivery from the Plan Allocations. Furthermore, the additional housing allocated to DHGV in year 17 does not correspond with the Total Housing Provision. This results in an over-estimated supply within years 12 and 13, and an under-estimation in year 17. We would expect the Council to clarify these errors, as it is casts uncertainty as to the exact effect of the Focussed Changes on the housing trajectory.
2.9 The table attached at Appendix A shows the updated housing trajectory (assuming a Total Housing Provision that aligns with expected delivery of the allocations) against the updated LHN. This shows that by year 7 (2022/23) there will be a deficit of 1,151 dwellings, and this is based on optimistic delivery rates for sites without planning permission expected to deliver in year 5 and onwards, so likely represents the best-case scenario. It also assumes that DHGV will commence delivery as early as year 7 (2022/23), which, as stated above and within our response to the previous Regulation 19 consultation, is an unrealistic expectation.
2.10 As a result of the increased LHN, the Total Housing Provision within the Plan provides a buffer of only 69 dwellings over the Plan's total housing requirement, which equates to just 0.9% of the requirement across the Plan period. The PSLP sought to provide a buffer of 20% against the housing requirement and we would highlight that the Chelmsford Local Plan, which has recently been examined, proposes a 20% buffer and this has been found to be suitable by the Inspector. The situation for the PSLP is that, again, the Plan demonstrates a lack of flexibility contrary to best practice, contrary to the rationale of the PSLP itself and contrary to Paragraph 11(a) of the NPPF. The Plan is therefore not positively prepared, nor will it be effective in meeting its needs across the Plan period.
3.0 Ability to Meet Local Housing Need (LHN)
3.1 Our representations to the previous Regulation 19 consultation highlighted the ageing population within the Borough, as recognised within paragraph 6.6 of the PSLP, and our concerns as to the lack of provision for specialist accommodation within the PSLP to meet present and future needs.
3.2 The Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report October 2019 (the SA) states at paragraph 9.5 that:
"There is also a need to address the health inequalities that exist within the population, and which are set to worsen, including because of the ageing population."
3.3 The Focussed Changes reduce the Plan's ability to meet local needs, particularly those of an ageing population, firstly, by reducing housing numbers in areas where housing needs are likely to be the highest, as quoted within the SA Addendum.3
3.4 Policies R25 and R26 require a provision for a minimum of 25% of the dwellings provided to be made available to those with a local connection, or to those aged 50 and over. The reduction in the number of dwellings not only reduces the potential availability of housing suitable for older people, but also raises concerns as to viability, as recognised within the SA Addendum. It states at paragraph 2.9.2 that:
"A reduced number of homes will have implications for scheme viability, and it is noted that these sites are subject to a policy requirement in respect of reserving a minimum of 25% of the proposed dwellings to be reserved for people with a strong and demonstrable local connection or those over 50 years of age; however, it is not possible to conclude any significant risk of the schemes becoming undeliverable."
3.5 Although this concludes that the schemes themselves may not become undeliverable, there is a real possibility that viability will affect the provision for these 25% homes for local people and those aged 50 and over coming forward through these allocations.
3.6 In addition, the Brentwood Local Development Plan Health Impact Assessment Version 3 October 2019 (HIA) notes that the reduction in dwellings on allocation R19 means that no wheelchair accessible dwellings will be required on site, taking it below the 60 dwelling threshold as set out in Policy HP01 of the PSLP.
3.7 Although the reduction in housing numbers on R18-19 and R25-26 will be redistributed to DHGV as part of the Focussed Changes, we would reiterate our concerns in relation to the provision and delivery of specialist accommodation at DHGV. Firstly, as stated above, the redistributed housing is not expected to be delivered at DHGV until year 12, reducing the ability of the Plan to address needs earlier in the Plan period.
3.8 Secondly, the provision for specialist accommodation at DHGV is to be delivered in accordance with Policy HP04. Paragraph 9.9.4 of the SA states that the provision of specialist accommodation at DHGV is not clear. Our response to the Regulation 19 consultation also raised concerns as to the lack of clarity regarding the definition of specialist accommodation within the supporting text of this Policy. The supporting text fails to give an accurate representation as to which type of specialist accommodation the Plan is seeking to deliver and for which group(s).
3.9 In light of this, it is considered that the Focussed Changes negatively affect the delivery of specialist accommodation for older people within the Plan period. We consider that the identification of additional suitable sites to meet needs within the short to medium term of the Plan period would enable the Plan to meet its housing needs specifically for older people. In the absence of this, we consider the Plan to be unsound and in direct conflict with the 'Housing for older and disabled people' 26 June 2019 addition to the NPPG.
4.0 Lack of Reasonable Alternatives Considered
4.1 The Sustainability Appraisal (SA) of the Brentwood Local Plan SA Report Addendum (October 2019) (the SA Addendum) states at paragraph 1.2.5 that as part of preparing the Focussed Changes and updating the SA, there was not considered to be a need to give further formal consideration to reasonable alternatives, as it was considered unlikely that alternatives would lead to notably different side effects. This was in reliance of Planning Practice Guidance (PPG) paragraph 009 Reference ID: 11-009-20140306, which states:
"The sustainability appraisal should only focus on what is needed to assess the likely significant effects of the plan."
4.2 We consider that the conclusions as to the effects of the Focused Changes, particularly in respect of the 'Housing' objective as stated within the Sustainability Appraisal (SA) of the Brentwood Local Plan - SA Report October 2019 (SA) clearly demonstrate that reasonable alternatives should have been considered.
4.3 The SA states that there will be 'uncertain negative implications' for the achievement of the 'Housing' objectives.4 This is on the basis that the housing has been reduced in areas where needs are likely to be highest, and, has been moved to Dunton Hills Garden Village (DHGV), potentially increasing the risk of not delivering the housing requirement. It also makes reference to the higher LHN figure. In comparison, the PSLP, prior to the Focussed Changes, was assessed as likely to have 'significant positive effects' on the basis of ability to meet the LHN and provide for specialist accommodation.
4.4 In our previous representations to the Regulation 19 consultation, we disputed this conclusion and the ability of the plan to deliver specialist accommodation. A number of concerns were received from respondents to the Regulation 19 consultation as to the effectiveness of the Plan to meet the needs of older people, which should have prompted the Council to review the strategy in this regard as part of the Focussed Changes. The Site (reference 073) has consistently been promoted for specialist accommodation for older people, to meet a locally identified need within Mountnessing, as detailed in our previous representations, and represents a missed opportunity. Not only would this help to address a locally identified need, it would also enable delivery in the early years of the plan period; two concerns that were prevalent in the responses to the Regulation 19 consultation. This further supports the argument that reasonable alternatives to the Focussed Changes should have been considered.
4.5 Despite this, the SA then goes onto conclude that the assessment of the PSLP against the housing objective (significant positive effects) 'broadly holds true' for the Focussed Changes (uncertain negative effects). This is clearly not the case, and it is considered that this conclusion is both incorrect and misleading.
4.6 It is considered that the change from 'significant positive effects' (PSLP) to 'uncertain negative implications' (Focussed Changes) in achieving the 'Housing' objective amounts to a significant effect of the Focussed Changes. Therefore, in accordance with the PPG (as referenced above), consideration should have been given to reasonable alternatives, and the definitive conclusion that alternatives would not have led to notably different side effects is unjustified. As a minimum, the Council should have considered reasonable alternatives to ascertain whether there was a more suitable strategy which would enable the Plan to meet its housing needs, thus enabling the Plan to achieve a more positive and beneficial outcome in respect of the 'Housing' objective. We consider this to be fundamentally important to ensuring a sound Local Plan.
4.7 Given the decrease in housing within areas with the highest needs as raised in the SA, regard should have been had to allocating additional suitable sites to meet housing needs at a local level (which the plan failed to do prior to the Focussed Changes). This would help to address local housing requirements, including the provision of specialist accommodation, as well as providing a more substantial buffer over and above the increased LHN and help to minimise the risks associated with potential delays in delivery at DHGV; a concern that is highlighted in the SA.
4.8 Following from this, it would seem highly appropriate to consider settlements on key transport corridors such as Mountnessing, that contain sites that scored better than many of the allocated sites in the SA such as Site 073 (Land adjacent to Mountnessing Primary School), that could deliver housing to meet identified local needs within the first 5 years of the Plan, before choosing, what should be a last resort given the trajectory already discussed, increasing housing numbers at DHGV. Our representations to the previous Regulation 19 consultation contained evidence of local support via a social media consultation, which received 96 responses in total, all of whom were interested in a new build bungalow specifically for those aged 55 and over on the Site.5 Appendix B contains a summary of this. This demonstrates a locally supported site which is a suitable alternative to the Focussed Changes, yet one which has been overlooked.
4.9 The Plan has failed to consider alternative, suitable sites, to balance the reduction in housing numbers in the sites subject to the Focussed Changes when identifying suitable solutions to correct this.
5.0 Robustness of SLAA
5.1 We argued clearly within previous representations that the approach to assessing sites within the SA using the 'traffic light' scoring system was primitive, inconsistent and unjustified, which resulted in subjective and ill-informed conclusions. This is clearly shown in relation to the Site - land west of Crossby Close, Mountnessing, as shown below:
 the Site scored higher than many of the allocated sites, yet was not allocated due to 'potential highways access issues' despite previous representations confirming Essex County Council Highways have no objection to the access, and which agree with the proposed access strategy;
 the scoring system as to a Site's classification of agricultural land (criterion 17) the dataset for which, as confirmed in the SA, is described as 'of a poor resolution.' This resulted in some sites being scored 'red' or 'amber' when in fact they were brownfield or non-agricultural land. The Site was incorrectly assessed as 'amber' for this criterion, yet it has not been in agricultural use since the current owner's acquisition in 1995 (with evidence adduced as part of our response to the previous Regulation 19 consultation to support this);
5.2 This further demonstrates inconsistencies and inaccuracies within the site assessment process, which we consider fails to demonstrate that the Plan has been positively prepared. However, despite pointing these out, the Focussed Changes do not include any rectification of these errors, and instead has taken a selective and non-transparent approach to amend existing allocations in response to objections received in the previous Regulation 19 consultation. We consider that this should have formed part of the consideration of reasonable alternatives to the Focussed Changes, which, as discussed above, was unjustifiably overlooked by the Council, in preference for amending the evidence base to suit the desired outcome. As a result, the Plan is not justified and cannot be considered sound.
6.0 The Unclear Approach to R18, R19, R25 and R26
6.1. The Council has decided to reduce the densities on allocations R18, R19, R25 and R26 (Focussed Changes 2-5), citing a considerable number of representations raising concerns as to the suitability of the sites for the proposed densities as the justification.
6.2. In redistributing the housing numbers from the above allocations to DHGV, the large number of objections received during the previous Regulation 19 consultation in respect of DHGV, including from statutory consultees, have been ignored. Instead, the Focussed Changes have gone against a number of comments, which highlight the unrealistic delivery timetable, and the need for sites which can deliver in the early years of the Plan.
6.3. There were also objections received in respect of other allocations within the Plan, as well as comments in respect of omission sites, such as our response to that consultation, which sought to clarify inaccuracies about the Site within the site assessment and show that earlier concerns regarding the access arrangements had been addressed.
6.4. The Addendum of Focussed Changes explains that the total loss of 70 homes across the four aforementioned sites will be off-set by altering another allocation to increase the number of new homes provided at Dunton Hill Garden Village (Focussed Change 1). However, the addendum does confirm that the overall number of new homes will not be increased, merely that there will be a faster rate of delivery at Dunton Hills Garden Village, resulting in more dwellings being provided before 2033 than previously projected (resulting in fewer post-2033).
6.5. We have a number of concerns with the proposed approach to addressing the shortfall that Focussed Changes 2-5 necessitate by simply altering Dunton Hills Garden Village to deliver at a greater rate than previously calculated, and at just a fast enough rate to account for the shortfall created by the need to reduce the proposed capacities for site R18, R19, R25, and R26. The lack of clarity in how both the reduction and the increase have been justified is unhelpful in being able to comment on the justification for the Focused Changes.
7.0 Cross-boundary and Statutory Consultee Objections
7.1. Basildon Borough Council have objected to the DHGV allocation in its response to the previous Regulation 19 consultation, in which it raised concerns regarding the cross-boundary impacts of this site, questioning the soundness of the Plan in this respect. Similarly, Essex County Council also raised concerns in respect of the transport evidence base for DHGV. As part of the Focussed Changes, the Council have seemingly overlooked these comments, in the absence of any evidence to the contrary, seeking instead to direct more housing numbers to this allocation within the Plan period, and failing to consider any reasonable alternatives.
7.2. As for the key concerns raised, it is concerning that the site assessments undertaken to date have failed to identify the numerous cited issues raised by respondents. Notwithstanding the inaccuracies in the assessment of our Site (land west of Crossby Close, Mountnessing) as mentioned above and in detail in our response to the previous Regulation 19 consultation, this casts further doubt on the robustness and the overall accuracy of the site assessment process which underpins the allocations within the Plan. This also substantiates our previous concerns that the site assessment process was inadequate, and therefore potentially undermines the remaining allocations within the Plan, as it is unclear as to whether any significant objection was raised in relation to those through the previous Regulation 19 consultation.
8.0 Conclusion
8.1. We consider that the Plan remains unsound as a result of the Focussed Changes. The higher confirmed LHN has not been incorporated within the Plan, nor the effects of this on whether the Plan should identify a suitable buffer to provide flexibility to adapt to rapid change. The Plan is therefore failing to meet the requirements of the NPPF and failing to meet the identified need for the Borough. The Focussed Changes do not demonstrate that the Plan will be effective in meeting housing needs, given it seeks to re-direct housing delivery from the short-term to the later years of the Plan, further decreasing its ability to meet its needs early in the Plan period. This is particularly concerning given the results of the Housing Delivery Test for the Borough (2019).
8.2. The trajectory as set out in the Focussed Changes remains overly optimistic, with the concerns as to the effects of a slippage in delivery at DHGV raised forming part of the reason for the SA conclusions that the Focussed Changes will have 'uncertain negative effects' on the 'Housing' objective. We strongly disagree with the SA's further conclusions that the assessment of the PSLP against the 'Housing' objective (significant positive effects) 'broadly holds true' for the Focussed Changes (uncertain negative effects).
8.3. The decision to discount the need for consideration of reasonable alternatives is inconsistent with national policy, and unjustified. This is apparent from the SA conclusions (discussed above), and we are highly concerned that this has reduced the ability of the Plan to meet the housing needs of the Borough going forward. The Council should have considered the merits of identifying additional, suitable sites to deliver in the short-medium term, including those which provide specialist accommodation to meet an identified local need, such as the land west of Crossby Close (site 073). As discussed above and shown in Appendix B, this represents a suitable site with local support for specialist accommodation that has been overlooked.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26807

Received: 26/11/2019

Respondent: Glenda Fleming

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

Loading more houses on the Dunton Hills Garden Village is a risky strategy as there are many planning and infrastructure issues still to resolve.

Full text:

Policy R19 covers two entirely separate sites. As the landowner of the Westernmost site (HELAA ref 178) I stand by my previous representations submitted in earlier stages of the local Plan development and these should be available to view unedited on the Brentwood Borough Council website and considered in full by the Planning Inspectorate.
Regarding Policy R19, the Council have already reduced the number of homes from 130 to 75 and now (under Focussed Change 3) they are proposing to reduce the numbers further to 45. This Change has arisen solely because of concerns from the public.
I do not believe that this policy has been positively prepared in a "Sound" manner as required by the National Planning Policy Framework. There is no evidence that this reduction in numbers on site R19 has any technical basis as the land is capable of accommodating far more homes (130 originally proposed by the planners) and the alternative proposed by this Focussed Change is to move most of the development down to Dunton in the Green Belt. This cannot be considered as sustainable development.
Most people want to live in easy reach of a town centre, and the most appropriate location is the available urban site at R19. Moving homes to the edge of the Borough where there are currently few schools, shops, health facilities and transport links is only going to add to congested roads and pollution. This is not sustainable.
The Aecom Sustainability Report analysed the effects of the changes with respect to site R19 and the conclusion was that these were nearly all negative. The changes cannot therefore be Justified, based on the expert evidence, and the alternative of keeping the numbers at 75 offer a better alternative.
Aecom have also expressed concerns that reducing the numbers of houses at R19 to 45 could adversely affect the viability of the development. At the same time, they explained that loading more houses on the Dunton Hills Garden Village is a risky strategy as there are many planning and infrastructure issues still to resolve. The targets for housing delivery may well be missed, whereas the small development on site 178 will be built out in a much shorter time period.
Finally, reducing the number of houses on site R19 and reducing the density of development is not making best use of a valuable resource. Land in a sustainable urban location with established infrastructure (roads, schools etc) is a valuable commodity and taking the hierarchical approach at the heart of the Local Plan and National Planning Policy Guidance, development should be prioritised here before squandering precious Green Belt that can never be replaced.
In my opinion the Focussed Change at R19 is unsound.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26813

Received: 26/11/2019

Respondent: Tesco Stores Limited

Agent: GL Hearn

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

We advise BBC to rethink its proposed strategy which has over the course of three drafts increased housing allocations at Dunton Hills Garden Village (DHGV). Any delay in implementing DHGV in line with the revised housing trajectory would result in housing shortfalls. The objections from Basildon and Thurrock Council are clear indicators that there has been insufficient engagement with adjoining Local Authorities over important cross boundary issues. 'The Consolidated Changes' should not be adopted until all concerning Local Authorities have discharged their duties to cooperate [in addressing all the issues relating to DHGV].

Change suggested by respondent:

recommend that the Sawyers Hall Farm site (ref: 024a and 024b) is allocated as this site is available for development now.

Full text:

INTRODUCTION
1.1 These Representations are submitted to Brentwood Borough Council (BBC) in response to the 'Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19) Local Plan' and Brentwood Local Plan Pre-submission Document (February 2019) (henceforth referred to as 'the Consolidated Changes'). The addendum was published on Tuesday 15 October for consultation and will close on Tuesday 26 November 2019. These Representations have been prepared by GL Hearn, on behalf of Tesco. Tesco has a land interest at Sawyers Hall Farm (also referred to as Hopefield Animal Sanctuary) (site ref: 024a and 024b).
1.2 Firstly, please note that GL Hearn has on two previous occasions objected to the subdivision of the site (Sawyers Hall Farm) into two separate parcels. This has resulted in the site being subject to two separate site appraisals (please see Paragraph 2.46 'Representations to Brentwood Local Plan, dated 18/03/19' AND Paragraph 2.30 'Representations to Brentwood Draft Local Plan Proffered Site Allocation, dated 12/03/2018). The failure to resolve this matter and amend the Sustainability Appraisal Report (Consolidated) (October 2019) amounts to a failure to follow local plan preparation procedures. If BBC does not revise 'the Consolidated Changes' prior to resubmission, then GL Hearn asks that the appointed Inspector discharges his/her duty under Regulation 23 of the Town and Country Planning (Local Planning) (England) Regulations 2012 and recommends that BBC conducts a thorough and balanced assessment of the site, taking into account of the site's full potential for a housing allocation within the plan.
1.3 This document provides our commentary on the proposed 'Consolidated Changes' and accompanying 'Sustainability Appraisal Report Addendum' dated October 2019. The purpose of this report is to assess 'the Consolidated Changes' against the legal and procedural requirements as set out in the Planning and Compulsory Purchase Act 2004 (henceforth referred to as 'the Act'), Town and Country Planning (Local Planning)(England)(Amendment) Regulations 2012 (henceforth referred to as 'the Regulations') and the 'four tests' of 'soundness' as detailed in Paragraph 35 of the NPPF (2019). This report does not intend to repeat the arguments made from previous representations and therefore we ask that this report is read in conjunction with the representations made on 18/03/2019 (Regulation 19), 26/03/2016 (Draft Local Plan Regulation 18) and the representations on the 'Strategic Growth Options Consultation' submitted on 17/02/2015.
1.4 We argue that 'the Consolidated Changes' have not been prepared in accordance with legal and procedural requirements. The policies contained within the plan have not been positively prepared,
Representations to Brentwood Local Development Plan - Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation
19) (October 2019) Tesco Stores Ltd, Brentwood CM15 9BZ (FINAL)
GL Hearn Page 5 of 14
nor have they been justified, or if adopted would be effective in delivering enough housing to meet the Borough's Local Housing Needs (LHN). 'The Consolidated Changes' are not consistent with national policy. GL Hearn concludes that upon examination an Inspector would not find the plan 'sound'. The delay in adopting a 'sound' plan would very likely leave the Borough vulnerable to sporadic and unsustainable patterns of development and therefore we urge BBC to make early revisions before submitting the plan to the Secretary of State.
1.5 We advise BBC to rethink its proposed strategy which has over the course of three drafts increased housing allocations at Dunton Hills Garden Village (DHGV). The Draft Local Plan 2018 (Regulation 18) allocated 2,500 dwellings which increased [without justification] to 2,700 dwellings in February 2019 (Regulation 19). 'The Consolidated Changes' proposes to increase the allocation at DHGV to 2,770 dwellings despite previous objections. The SA Report Addendum (2019) identifies the following negative impacts relating to the spatial strategy:
* 'The Consolidated Changes' would lead to an increase in car movements through Brentwood Town Centre Air Quality Management Area (AQMA) (located 6km away) (Paragraph 2.2.5 of Sustainability Report Addendum, October 2019). It should be noted that concerns over congestion within the urban area was a key reason why the number of dwellings allocated at sites R18 & R19 had been reduced [by 20 and 30 dwellings respectively]. The evidence shows that the reallocation of 50 dwellings from the urban area to DHGV results in no net improvement to the levels of congestion or air quality within the urban area.
* 'The Consolidated Changes' would impact on the Government's plans to reduce roadside nitrogen dioxide concentrations along the A127 corridor (Paragraph 2.2.10 and 2.211 of Sustainability Report Addendum, October 2019),
* 'The Consolidated Changes' would have a greater impact on sensitive biodiversity assets (Paragraph 2.3.1) and cause "significant negative effects" on land with high performing landscape and Greenbelt attributes (Paragraph 2.10.4 - 2.10.5 of Sustainability Report Addendum, October 2019),
* 'The Consolidated Changes' would reallocate housing away from the Brentwood/Shenfield Urban Area where the demand for housing is greatest and where it is near existing community and transport infrastructure THEN direct 35% of the Boroughs housing allocation to a single 257 ha Greenfield site which is heavily dependent on the timing and delivery of expensive infrastructure. The spatial strategy presents a greater risk to the housing trajectory and this is discussed in section 2 below. (Paragraph 2.9.1 - 2.9.4 of Sustainability Report Addendum, October 2019).
Representations to Brentwood Local Development Plan - Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation
19) (October 2019) Tesco Stores Ltd, Brentwood CM15 9BZ (FINAL)
GL Hearn Page 6 of 14
FOCUSSED CHANGE 1: POLICY R01 (I): DUNTON HILLS GARDEN VILLAGE STRATEGIC ALLOCATION
National Planning Policy Context - Tests for 'Soundness'
2.1 We acknowledge the Council's adoption of the new higher LHN figure of 454 dwellings per annum (dpa). The requirement equates to 2,270 net dpa in years 1 to 5. Paragraph 73(c) of the NPPF (2019) dictates that where there has been a significant under delivery of housing over the previous three years BBC should include a 20% buffer (moved forward from years 6 to 15 in the plan period). To comply with the NPPF (2019) and for 'the Consolidated Changes' to be found 'sound' BBC must identify a supply of specific and deliverable sites for years 1 to 5 with a capacity for 2,725 net dwellings (545 dpa).
2.2 Appendix 1 'Schedule of Focussed Changes to Brentwood Pre-Submission Local Plan' of 'The Consolidated Changes' (Page 7) provides a breakdown of the site allocation for the plan period. The method used to calculate the 'Allocation Total' does not accord with the methodology stated in the NPPF (2019). Paragraph 22 of the NPPF (2019) states that Plans should look ahead over a minimum of 15 years from adoption and therefore the completions included for years 2016/17 and 2017/18 (363 net homes or 5% of the allocation total) should be discounted as the plan has not yet been adopted and is unlikely to be adopted until after 2021.
2.3 The 'Allocation Total' includes 926 net homes with extant permissions as of 01/04/2018. The NPPF (2019) Part (a), page 66 provides one such definition of deliverable: "sites which do not involve major development and have planning permission, and all sites with detailed planning permission, should be considered deliverable until permission expires, unless there is clear evidence that homes will not be delivered within five years"
2.4 'The Consolidated Changes' does not mention when the extant permissions were granted therefore it is impossible to know when they will expire or likely be implemented. It would be reasonable to assume that most [if not all] 926 dwellings included within the extant permissions had been granted circa. 18 months prior to April 2018 (i.e. granted around October 2016). The expiration or implementation of all 926 dwellings should have occurred around October 2019. Since October 2019 precedes the adoption of the local plan then 926 dwellings should be discounted from the 'Allocation Total'. Unless BBC can provide evidence that the permissions for all 926 dwellings will still be extant at the point that the Local Plan is adopted then 926 dwellings should be discounted from the 'Allocation Total'.
Representations to Brentwood Local Development Plan - Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation
19) (October 2019) Tesco Stores Ltd, Brentwood CM15 9BZ (FINAL)
GL Hearn Page 7 of 14
2.5 Paragraph 70 of the NPPF (2019) states that windfall sites should only be included in the anticipated housing calculation if there is compelling evidence to suggest they are a reliable source of supply. Compelling evidence should be realistic having regard to (i) the strategic housing land availability assessment, (ii) expected future trends (iii) historic windfall delivery rates. Paragraph 4.17 of The Brentwood Local Plan Pre-submission Document (February 2019) and Housing and Economic Land Availability Assessment (2018) provides the basis for the projected supply of 410 dwellings on windfall sites. The allocation of windfall sites is based exclusively on past delivery records and has not had regard to either (i) land availability or (ii) the impact of future trends affecting the delivery of housing on windfall sites. In the absence of compelling evidence 410 dwellings should be discounted from the 'Allocation Total'.
2.6 Table 1 below provides a revised 'Allocation Total' for the plan period which correctly discounts (1) 'Completions 2016/2017/18' (2) 'Extant permissions' and (3) 'Windfall Allowances'. The Revised 'Allocation Total' in Table 1 has been formulated using the correct method defined in Paragraphs 22 and 70, and Page 66, Part (a) of the NPPF (2019).
[Table 1: see attachment]
2.7 Table 2 provides a revision to the housing trajectory for the plan period which appropriately commences in 2021/2020 [in line with the correct method defined in Paragraph 22 of the NPPF (2019)]. The delivery rates for DHGV has been reduced to reflect the likely rates of delivery for a strategic site of this kind. Based on empirical evidence undertaken by Savills on behalf of Barret Homes (see Urban Extensions - Assessment of Delivery Rates, October 2014) DHGV may only deliver up to 120 dpa. The figures contained in Table 2 below represents the highest expected yield pa. The expected delivery rate of up to 120 dpa is supported by observations of 78 urban extensions on greenfield sites. 32% of case studies had been located within the south east of England and are an accurate proxy for estimating expected housing delivery rates at DHGV. BBC has not provided any evidence to suggest that delivery rates will exceed 120 dpa and therefore the revised housing trajectory in table 2 should be 'material' when assessing the 5 year housing land supply and the overall 'soundness' of 'The Consolidated Changes'.
[Table 2: See attachment]
2.8 Short term: 'The Consolidated Changes' must identify a supply of specific and deliverable sites capable of providing 545 dpa in years 1 to 5. Table 1 demonstrates that the Plan would fall short in meeting LHN in years 1 and 2 by a significant margin (-429 and -274 dwellings respectively).
2.9 Long term: 'The Consolidated Changes' would fall short in allocating a suitable number of housing sites over the plan period by 3,177 dwellings (see Table 2).
Local Plan Legal Compliance
Significant cross boundary impacts
2.10 Section 33A of the Act and Paragraph 24 of the NPPF (2019) imposes a duty on BBC to cooperate with adjoining Local Authorities on issues that would have significant and/or cross boundary impacts on other areas. The duty imposed on BBC requires constructive and active engagement on an on-going basis. Cooperation between adjoining Local Authorities must take place before 'The Consolidated Changes' are submitted to the Secretary of State for examination.
2.11 DHGV is located within close proximity to the administrative boundaries of Basildon and Thurrock Council. Both Councils have objected to the allocation of 2,700 homes in previous consultations. The objections raised are very likely to intensify following the allocation of an additional 70 homes at DHGV. Basildon Council made the following objection during the March 2019 (Regulation 19) consultation:
"Basildon Council would like to seek assurances written into Policy R01(II) that it will be invited by Brentwood Council to become more involved in the detailed design and delivery of the new village.
This will ensure that the strategic and cross-boundary impacts covered by the Duty to Cooperate and raised during the Council's response to the Plan at Regulation 18 and 19 stages are managed effectively during the development's implementation stages (assuming it is considered sound), alongside the Basildon Borough Local Plan's own implementation. Delivery of DHGV will commence in 2022/23 at a rate of 100 homes per annum, climbing to 300 homes per annum by 2026/27. This seems overly optimistic given that the allocation is currently within Green Belt, requires masterplanning and will need to go through a planning application and elements of the condition discharge process before development can commence.
No evidence is provided as to how the housing trajectory has been developed. No evidence or any form of a development framework/ masterplan for DHGV explains how the proposed accelerated rate of delivery will be possible. The Plan and the Transport Assessment fails to investigate the possible impacts on Basildon's road and rail infrastructure arising from commuters or other road users choosing to access facilities within the Basildon Borough instead.
The need for new connections into Basildon was not mentioned as being necessary to make it sustainable. No evidence was present to demonstrate that DHGV's growth demands have been evaluated in combination with the projected demands from Basildon Local Plan. The Plan should not assume that such growth can just be absorbed by the nearby infrastructure and services in Basildon and investment through developer contributions".
2.12 Details of the other objections from neighbouring Local Authorities have been reproduced in Box 2.2, on page 9 of the SA Report Addendum (October 2019).
2.13 The objections from Basildon and Thurrock Council are clear indicators that there has been insufficient engagement with adjoining Local Authorities over important cross boundary issues. 'The Consolidated Changes' should not be adopted until all concerning Local Authorities have discharged their duties to cooperate [in addressing all the issues relating to DHGV] as required by the Act and NPPF (2019).
Unmet housing need
2.14 BBC confirm that adjoining Local Authorities are unwilling and unable to take any identified housing need from the Borough.
CONCLUSION
3.1 We therefore conclude that additional work is still required in order to make the 'The Consolidated Changes' 'sound' and legally compliant. BBC must increase the number of allocations for housing in sustainable locations and preferably near the urban area. BBC must address the Boroughs' short-term housing needs (5 year housing land supply) and long-term LHN for the entirety of the plan in order to be considered 'sound'. Therefore to address this matter we recommend that the Sawyers Hall Farm site (ref: 024a and 024b) is allocated as this site is available for development now. Table 2 (above) provides a 'best case' housing forecast and shows the greatest housing shortfall in years 1 and 2. Any delay in implementing DHGV in line with the revised housing trajectory (see table 1 and 2) would result in housing shortfalls in years 3 to 5 and potentially the remainder of the plan period. The planning for DHGV will require a substantial amount and the timely delivery of new infrastructure to address the impact of development and overcome the objections raised by consultees and adjoining Local Authorities. We have demonstrated categorically that the implementation of DHGV will not correspond to the Council's own housing trajectory. The Sawyers Hall Farm site would support the delivery of up to 450 new homes in years 1 and 2 and would contribute significantly towards helping BBC meet its local development needs and preparing a 'sound' Local Plan for timely adoption.
3.2 This report highlighted the risks posed by the current strategy in meeting the LHN over the period of the plan. 'The Consolidated Changes' have not been prepared in accordance with legal and procedural requirements set out in the Act and NPPF (2019). The policies contained within the plan have not been positively prepared, nor have they been justified, or if adopted would be effective in delivering enough housing to meet the Borough's Local Housing Needs (LHN). GL Hearn concludes that the plan [if not changed in accordance with recommendation to increase housing allocation closer to the urban area) would not be found 'sound' by the appointed Inspector.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26860

Received: 26/11/2019

Respondent: Mrs Christina Atkins

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP.

Change suggested by respondent:

Allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP.

Full text:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic AllocationThe allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree. Would make much more sense as Buses and Trains are close for
people to go to work.

Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
A - I agree - we should prioritise building on sites with, or close to, existing infrastructure. We should prioritise building on sites that are close or near to existing
infrastructure.

Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
A - I agree - the site should be removed from the LDP. I feel the site should be completely removed from the LDP. A reduction of ten houses would not change the fundamental problems in connection with the infrastructure and services of of Blackmore Village not to mention that a Development like this would complete spoil the uniqueness of this Village which has much history.

Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed.
A - I agree - these sites are developer led and should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish).
A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
A - I agree - Sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). It is important to build on Brownfield Sites before we carry out any destruction to Green Belt Land.

Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area.A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01.
A - I agree - the Honeypot Lane site should be reinstated.

Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
A - I agree - the allocation in Blackmore is disproportionate and unsound.

Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
A - Strongly agree.

Q - Additional comments
A - We do not need anymore houses in Blackmore as we are a sustainable Village as we are, anymore Housing would be horrendous for this village. Would have to mention more Traffic, Flood Risk, Doctor Services, School etc.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26881

Received: 26/11/2019

Respondent: Iceni Projects Limited

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation:

The proposed modifications are further delaying the delivery of housing until later in the Plan period pushing out 70 dwellings from Years 7 - 9 to Years 15 - 17. While this is a modest number of homes it demonstrates the significant challenge the Council is facing in the delivery of housing in the early years of the Plan period; The Pre-Submission Plan is seeking to deliver just a 1% buffer on top of the minimum LHN of 454 dwellings. The Sustainability Appraisal accompanying the Consultation warns against this approach, stating that there is an over reliance on Dunton Hills Garden Village for housing delivery "which leads to an increased degree of risk in respect of delays to delivery.

Change suggested by respondent:

In order to address the soundness issues we consider that the housing target should be reviewed with regard to the new evidence and that further sources of land supply should be identified, not only to deal with shortfalls over the plan period in total, but also specifically within its first 10 years. Land to the north of West Horndon railway station is available, suitable and deliverable and can contribute to meeting this shortfall. Importantly, it can come forward independently of the wider area of growth being promoted by EASL to the south of the settlement (in Thurrock Borough). The Brentwood Local Plan needs to seriously consider early delivery to ensure the Plan provides sufficient housing for Five Year Housing Land Supply, and for years 5 - 10. Early delivery of West Horndon would assist DHGV coming forward as it would act as a catalyst for housing delivery in this area of Brentwood and enhance the attractiveness of DHGV from a purchaser's perspective. It would also help a Local Plan inspector determine that Brentwood's Local Plan is sound; as is self-evident from the present draft of the Local Plan that Brentwood's ability to meet its housing needs is inextricably linked with the release of Green Belt land, primarily at DHGV. The failure to adopt a local plan would not only result in Brentwood being unable to address its housing needs, it would deprive DHGV of the policy context in which to come forward as a planning application proposal, thereby exacerbating the deficit. We had previously set out in the West Horndon Delivery Statement (Appendix 1 to our March 2019 representations) that the site could deliver first completions by 2024. This would mean that significant numbers of homes could be delivered within the first 5 - 10 years of the plan period helping to address the soundness issues identified. We trust these representations clarify our position and that they are taken into consideration in the advancement of the Local Plan.

Full text:

I write on behalf of my client, Estates and Agency Strategic Land (EASL), in relation to the aforementioned consultation. This submission follows previous representations we have submitted, most recently to the Pre-Submission Local Plan (Regulation 19) in March 2019. EASL is promoting land west of Thorndon Avenue, West Horndon which constitutes the most sustainable undeveloped site in Brentwood Borough given its proximity to West Horndon railway station (one of just four stations in the Borough) which is wholly underutilised infrastructure. The site is self-contained with strong defensible boundaries, enclosed by existing industrial and residential development and roads. There is no technical evidence accompanying the Local Plan which identifies any fundamental constraints in bringing this site forward. In fact, the evidence supports the allocation of this site, particularly to assist with housing delivery in the early years of the Plan period. For information, EASL is also promoting land to the south of the railway line, which largely defines the existing community of West Horndon. This land, which lies within the administrative area of Thurrock, has been identified as a potential location for a new settlement in the Issues and Options Draft (Regulation 18) Thurrock Local Plan. EASL is therefore uniquely placed to contribute to the transformational change of land within the environs of West Horndon railway station, both to the benefit of Brentwood Borough and Thurrock. These representations raise the following matters for consideration - * The proposed modifications are further delaying the delivery of housing until later in the Plan period pushing out 70 dwellings from Years 7 - 9 to Years 15 - 17. While this is a modest number of homes it demonstrates the significant challenge the Council is facing in the delivery of housing in the early years of the Plan period; * The SA accompanying the Consultation states that the Local Housing Need (LHN) figure has increased from 350 to 454 dwellings. The Consultation does not provide any evidence to demonstrate what this figure is based on, albeit it is closely related to the capped standardised method for the Borough of 452 dwellings. However, the PPG requires the Planning Authority to seek to meet the uncapped figure, which in the case of Brentwood would require the delivery of 469 dwellings per annum. Moreover, the Council has failed to consider the increased housing figure that will occur as a result of Crossrail's opening, which it is estimated will give rise to an additional need of 1,000 dwellings over the Plan Period; In terms of housing supply the Pre-Submission Plan is seeking to deliver just a 1% buffer on top of the minimum LHN of 454 dwellings. The Sustainability Appraisal accompanying the Consultation warns against this approach, stating that there is an over reliance on Dunton Hills Garden Village for housing delivery "which leads to an increased degree of risk in respect of delays to delivery (the very reason why a buffer over-and-above the housing requirement is appropriate;" * The Focused Consultation demonstrates that it is imperative that the Council consider the allocation of additional sites. Land at West Horndon is available, suitable and deliverable and can contribute to meeting this shortfall. The land does not require any significant infrastructure and therefore can come forward in the early part of the Plan period to assist the Council in meeting its short to medium term housing needs. The changes put forward by Brentwood Council primarily seek to address the projected reduction in developable capacity of four site allocations, equating to a reduction of some 70 units (Policy Allocations R18, R19, R25 and R26). The Council seek to offset this loss by allocating 70 additional units within the Dunton Hills Garden Village Strategic Allocation (Policy R01(I)). We consider, not only are these changes unsound but that they also highlight and exacerbate the previous soundness concerns we had raised with the Local Plan by placing too much emphasis on Dunton Hills Garden Village (GC) to meet a large majority of the identified housing need in the Borough. The Housing Trajectory set out at Appendix 1 of the Addendum document (proposed amendment 13) identifies that the 70-unit reduction across the four sites reduces supply across years (7 - 9) 2022/23 - 2024/25 of the Plan i.e. within the first 10 years of the plan period. However, the replacement of these units comes at the back end of the plan period through the Dunton Hills GC allocation; between 2030/31 - 2032/33 (years 15 - 17 of the plan). We further note that there is an error in the 'allocation total' row on page 14 of the consultation document. The totals in rows 'year 12' and 'year 13' have been incorrectly increased by a total of 20 units whereas this increase should occur in row 'year 17' taking account of the numbers in the table above this. We are concerned with the approach of delaying much needed housing to the latter years of the plan period as this approach is contrary to national policy. The National Planning Policy Framework 2019 (NPPF), at paragraph 67, requires that local plans should identify a sufficient supply of specific, deliverable sites for years one to five; and specific, developable sites or broad locations for growth for years 6-10 and, where possible, for years 11-15 of the plan. Therefore, the NPPF clearly advocates an approach of securing housing delivery in the early part of the plan period. If the Council were to consider that the available delivery from allocated sites were to reduce by 70 units within the Plan's first 10-years, then in order to support soundness, the focus must be on replacing these units with the same initial 10-year period and not delaying this to years 15-17. The rationale for the increase of 70 units at Dunton Hills GC is set out in paragraph 5 of the Addendum of Focused Changes document. This explains that the total capacity of the site is 4,000 units (with 2,500 units of these to be delivered within the plan period). As such bringing forward additional units within the period will require a faster rate of delivery. The Addendum of Focused Changes document does not however, provide any evidence of how these faster rates can be facilitated. The only reference to justifying the uplift is provided in the Sustainability Appraisal (SA) Report Addendum (October 2019), which states at paragraph 2.9.3: "discussions between the Council and the site promoter have served to indicate that the 70 homes additionally assigned to the site through the Focussed Changes are deliverable within the plan period, and indeed can be delivered in a timely fashion such that the Local Plan housing delivery trajectory is unaffected". No further information is provided as to where the additional units would fall within the phasing of the development and as such, we raise issue with the insufficient evidence to support this increase. In addition to the redistribution of 70 dwellings, the Sustainability Appraisal (SA) (October 2019) has confirmed that the Local Housing Need has increased to 454 dwellings per annum. The SA states that there are updates to the evidence-base since January 2019, including the new higher Local Housing Need (LHN) figure for Brentwood Borough, which is 454 dwellings per annum. 452 is the minimum figure identified in the Government standardised method, the starting point as it were for assessing the housing requirement for the Borough as detailed in Table 1 (see attached). It is unclear whether the Local Planning Authority intend to amend the Pre-Submission Local Plan to take account of the revised LHN figure - this would appear to be a prerequisite since the housing need section, and specifically section 4.11 onwards, is predicated on a LHN figure of 350. The Local Plan needs to be updated to state that the 452 new households is the minimum LHN figure. Moreover, there does not appear to be any additional evidence supporting this consultation which justifies the LHN figure. As detailed in the EASL representations on the Pre-Submission Plan (March 2019), the minimum local housing need figure is however influenced by a cap. The uncapped housing need for Brentwood is for 469 dpa (as shown in Table 1 above). Over the 17 year plan period this would equate to a need for 7,973 dwellings. Para 2a-007-20190220 in the Planning Practice Guidance (PPG) states that: "The cap reduces the minimum number generated by the standard method, but does not reduce housing need itself. Therefore strategic policies adopted with a cap applied may require an early review and updating to ensure that any housing need above the capped level is planned for as soon as is reasonably possible. Where the minimum annual local housing need figure is subject to a cap, consideration can still be given to whether a higher level of need could realistically be delivered. This may help prevent authorities from having to undertake an early review of the relevant policies." The actual (or full) level of housing need shown by the standard method is therefore 7,973 dwellings. This is 220 dwellings above the housing requirement in the Plan. The PPG is clear that consideration should be given to whether this level of housing need can realistically be delivered. Moreover, as detailed in full in our previous set of representations, the Council has failed to take into account the increased housing figure as a result of Crossrail's opening, which it is estimated will give rise to a need of 1,000 dwellings over the Plan period. Land at West Horndon is available, suitable and deliverable and can contribute to meeting this shortfall. The land does not require any significant infrastructure and therefore can come forward in early part of the Plan period to assist the Council in meeting the short to medium term housing needs. The Pre-Submission Local Plan detailed the need to provide for a 'buffer' over-and-above LHN (identified in the Sustainability Appraisal as 454 dpa) in order to ensure a robust housing supply trajectory (recognising the risk of unanticipated delays to deliver at one or more sites). The Focused Changes confirms that the Council will not be providing a buffer and instead only to meet the minimum housing requirement. The housing supply is detailed further below. Policy SP02 in the Pre-Submission Plan makes provision for 7,752 new dwellings over the 17 year plan period 2016-33. This is equivalent to 456 dwellings per annum. It thus marginally exceeds the capped standard method figure by less than 1%. Effectively it aligns with the minimum need figure.
The Council is also proposing to delay the delivery of housing in the early years with a stepped trajectory to provide 310 dpa to 2023 and a higher target of 584 homes per year thereafter. Totalling 7,752 units over the plan period 2016-2033 (paragraphs 1.16 - 1.21 of the Local Plan). For the reasons given we considered these figures should be treated as minimums as the actual (or full) level of housing need shown by the standard method is 7,973 dwellings. This is 220 dwellings above the housing requirement in the Plan which demonstrates that the Council need to allocate additional sites. As a result of the stepped trajectory and the increased LHN, the Local Plan will not meet the LHN figure of 454 until 2024. All of the above seeks to further exacerbate the soundness issues we had previously raised regarding the Local Plan and its level of proposed housing delivery. Clearly, the reduction of 70 units from the first 10 years of the plan period further undermines its soundness. The SA undertaken is critical of the proposed changes stating that it causes greater uncertainty. The Council's SA states at Para 9.9.11 that: "...to concentrate housing at DHGV to a greater extent, potentially leading to a degree of increased risk in respect of delivering the Borough-wide housing requirement, has uncertain negative implications for the achievement of 'Housing' objectives." The SA emphasises the proposed changes increases the level of uncertainty stating that - "On this basis, the conclusion reached in January 2019 in respect of the Pre-submission Plan (see para 9.9.10) broadly holds true for the Pre-submission Plan plus Focussed Changes. However, this conclusion is now associated with a greater degree of uncertainty. First and foremost, this is on the basis that LHN, and therefore the annual housing requirement, is now understood to equate to 454 dpa, such that the proposed supply figure of 456 dpa can no longer be said to put in place a significant 'buffer' over-and-above the housing requirement. Secondly, the Focussed Changes will result in the housing supply being focused at DHGV to a greater extent, which leads to an increased degree of risk in respect of delays to delivery (the very reason why a buffer over-and-above the housing requirement is appropriate), albeit this risk is uncertain and may be marginal". (Our emphasis)
The SA previously assessed a range of alternatives in order to deliver the Council's housing requirement. Given that the LHN figure has altered significantly, it is considered that a fresh assessment of the alternatives should be undertaken in order to ascertain whether a more proactive and positive strategy for accommodating housing growth in the Borough can be identified. The assessment of the alternative options on a LHN figure of 350 dwelling is now simply irrelevant. In this regard, it is important to understand the respective merits of sites options through the SA process. For example, we have previously raised, in our representations to the Brentwood Local Plan Sustainability Appraisal (SA)(March 2019), that there were a number of identified effects within the SA we disagreed with. Our alternative assessment for West Horndon stated, with respect to air quality: "The spatial development strategy for the Brentwood Local Plan should seek to limit traffic through existing Air Quality Management Areas (AQMAs), which are primarily located along the A12 in proximity to Brentwood. From this perspective, development at West Horndon should be considered the preferred option. Growth in this location will be in proximity to an existing train station, thereby minimising the need for car travel, as well as resulting in improvements to the village centre to improve facilities for residents. As such, no significant negative effects in relation to air quality are anticipated." We further consider that locating growth in inherently sustainable locations, such as at West Horndon, is important to consider in the context of wider air quality matters including, air quality management of the A127. In order to address the soundness issues we consider that the housing target should be reviewed with regard to the new evidence and that further sources of land supply should be identified, not only to deal with shortfalls over the plan period in total, but also specifically within its first 10 years. Land to the north of West Horndon railway station is available, suitable and deliverable and can contribute to meeting this shortfall. Importantly, it can come forward independently of the wider area of growth being promoted by EASL to the south of the settlement (in Thurrock Borough). The Brentwood Local Plan needs to seriously consider early delivery to ensure the Plan provides sufficient housing for Five Year Housing Land Supply, and for years 5 - 10. Early delivery of West Horndon would assist DHGV coming forward as it would act as a catalyst for housing delivery in this area of Brentwood and enhance the attractiveness of DHGV from a purchaser's perspective. It would also help a Local Plan inspector determine that Brentwood's Local Plan is sound; as is self-evident from the present draft of the Local Plan that Brentwood's ability to meet its housing needs is inextricably linked with the release of Green Belt land, primarily at DHGV. The failure to adopt a local plan would not only result in Brentwood being unable to address its housing needs, it would deprive DHGV of the policy context in which to come forward as a planning application proposal, thereby exacerbating the deficit. We had previously set out in the West Horndon Delivery Statement (Appendix 1 to our March 2019 representations) that the site could deliver first completions by 2024. This would mean that significant numbers of homes could be delivered within the first 5 - 10 years of the plan period helping to address the soundness issues identified. We trust these representations clarify our position and that they are taken into consideration in the advancement of the Local Plan.

Attachments:

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26891

Received: 29/11/2019

Respondent: L Apostolides

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Dunton Hills Garden Village Strategic Allocation The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP. I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R26 from the plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
The GP surgery can not cope with the number of patients now and the schools are not large enough for more children
Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26896

Received: 29/11/2019

Respondent: Mr Alex Atkins

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R25 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree,
I agree that brownfield sites should be released first before any building
can be completed on greenfield
Comment: :
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated


Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26904

Received: 29/11/2019

Respondent: Mr Christopher Atkins

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree,
Before distruction of Greenbelt land all Brownfield Sites should be
used.
Comment: :
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure, No point building houses in a rural area where there is no infrastructure as it makes living more difficult to reach services.

Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
,
The houses needed can go elsewhere on the LDP so as not to spoil a
very quaint unique village.
COMMENT: :
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
,
No building on Greenbelt land in
Blackmore.
COMMENT: :
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
This village is sustainable as it is, anymore houses would be horrendous and completely spoil the village.
Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26909

Received: 26/11/2019

Respondent: Mr Joseph W E Atkins

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree,
Green belt land should not be used at all, Brownfield Sites should be
used.
Comment: :
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure, Infrastructure should be considered at all costs when residential development takes place as it's pointless placing people in a rural area
with little infrastructure i.e Health Centre, Transport and many other services that people have to drive to.

Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
,
The Development proposed for Blackmore should've removed from the
Plan as Blackmore cannot sustain any further houses.
COMMENT: :
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
,
Red rose Farm is a Brownfield site and a proposed development of 12
houses will deliver part of our own village plan so it should therefore
replace R26 kits entirity. Green belt land should not be built on,
Brownfield should always be considered first.
COMMENT: :
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated

Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
Blackmore is Greenbelt Land and Brownfield Sites should be used before the destruction of Green Belt Land.
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26914

Received: 26/11/2019

Respondent: Ms Lynn Baggott

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure, Has a far better infrastructure: - Shops - Station - Bus service - Doctor's- School
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
,
A months wait at the doctors surgery Buses that run every 2 hours to
Brentwood and Chelmsford A school that is full Potential to floods
COMMENT: :
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated.

Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26919

Received: 26/11/2019

Respondent: Mr David Hall

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove policies R25 and R26 from the LDP.

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree

Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019). Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
A - I agree - we should prioritise building on sites with, or close to, existing infrastructure.

Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019). To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
A - I agree - the site should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed.
A - I agree - these sites are developer led and should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish).
A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
A - I agree - Sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm)

Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area.A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01.
A - I agree - the Honeypot Lane site should be reinstated.

Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
A - I agree - the allocation in Blackmore is disproportionate and unsound.

Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
A - Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26924

Received: 26/11/2019

Respondent: Mr Authur Austin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated.
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP. Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26925

Received: 26/11/2019

Respondent: Mr Authur Austin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated.
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP. Strongly agree

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26929

Received: 29/11/2019

Respondent: Mrs Gillian Hall

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 & R26

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure
#21
COMPLLETTE
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SSttaarrtteedd:: Weeddnneessddaayy,, Noovveembbeerr 2200,, 22001199 22::1144::0099 PPM
LLaasstt Mooddiiffiieedd:: Weeddnneessddaayy,, Noovveembbeerr 2200,, 22001199 22::1188::5588 PPM
TTiimee SSppeenntt:: 0000::0044::4499
IIPP Addddrreessss:: 55..7700..8899..117700
Page 1
61 / 165
Blackmore and the LDP SurveyMonkey
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated
62 / 165
Blackmore and the LDP SurveyMonkey
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26932

Received: 26/11/2019

Respondent: Mr. Clive Austin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated.
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP. Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26939

Received: 29/11/2019

Respondent: Mr Harry Austin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R26 and R25 from the plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated.
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP. Strongly agree

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26940

Received: 26/11/2019

Respondent: Mr Kevin Hall

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 & R26. Increase houses in Dunton and Priests Lane

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure
#4
COMPLLETTE
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SSttaarrtteedd:: Moonnddaayy,, Noovveembbeerr 1188,, 22001199 88::5566::5566 AAM
LLaasstt Mooddiiffiieedd:: Moonnddaayy,, Noovveembbeerr 1188,, 22001199 99::0066::2255 AAM
TTiimee SSppeenntt:: 0000::0099::2288
IIPP Addddrreessss:: 9900..119977..116666..223377
Page 1
10 / 132
Blackmore and the LDP SurveyMonkey
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated
11 / 132
Blackmore and the LDP SurveyMonkey
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
These proposed developments should be removed for all the reasons stated within the last consultation. a tiny reduction will make no difference to the
fundimental issued raised previously.
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26945

Received: 26/11/2019

Respondent: Mrs. Jill Austin

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 and R26 from plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP. Strongly agree

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26954

Received: 26/11/2019

Respondent: Mr. Chris Hamilton

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 & R26

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure
#26
COMPLLETTE
Coolllleeccttoorr:: Weebb LLiinnkk 11 ((Weebb LLiinnkk))
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TTiimee SSppeenntt:: 0000::1100::3388
IIPP Addddrreessss:: 9922..99..112255..117700
Page 1
76 / 192
Blackmore and the LDP SurveyMonkey
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated
77 / 192
Blackmore and the LDP SurveyMonkey
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
In summary, there are many options available that are far more appropriate
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Support

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26959

Received: 26/11/2019

Respondent: Mrs Mandy Hamilton

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25 & R26

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be
reinstated
80 / 192
Blackmore and the LDP SurveyMonkey
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any
further comments you wish to record.
Respondent skipped this question
Q15 CONCLUSION:Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26964

Received: 26/11/2019

Respondent: Mr Jack Stevens

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP

Change suggested by respondent:

Remove R25 and R26 from the Plan.

Full text:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP A - I agree - Dunton Hills can accommodate the houses planned for Blackmore Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely. A - I agree Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019). Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations. A - I agree - we should prioritise building on sites with, or close to, existing infrastructure. R25 Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019). To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development. A - I agree - the site should be removed from the LDP. Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. A - I agree - these sites are developer led and should be removed from the LDP. Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish). A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP. Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure. A - I agree - Sites R25 and R26 should be removed completely from the LDP. Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed. A - I agree - the allocation in Blackmore is disproportionate and unsound. Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP. A - Strongly agree R26 Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety. A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. A - I agree - these sites are developer led and should be removed from the LDP. Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish). A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP. Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure. A - I agree - Sites R25 and R26 should be removed completely from the LDP. Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area. A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01. A - I agree - the Honeypot Lane site should be reinstated. Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed. A - I agree - the allocation in Blackmore is disproportionate and unsound. Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP. A - Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26969

Received: 26/11/2019

Respondent: Mr Ronald Quested

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP

Change suggested by respondent:

Remove R25 and R26 from the Plan.

Full text:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP A - I agree - Dunton Hills can accommodate the houses planned for Blackmore Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019) Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely. A - I agree Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019). Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations. A - I agree - we should prioritise building on sites with, or close to, existing infrastructure. R25 Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019). To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development. A - I agree - the site should be removed from the LDP. Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. A - I agree - these sites are developer led and should be removed from the LDP. Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish). A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP. Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure. A - I agree - Sites R25 and R26 should be removed completely from the LDP. Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed. A - I agree - the allocation in Blackmore is disproportionate and unsound. Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP. A - Strongly agree R26 Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety. A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. A - I agree - these sites are developer led and should be removed from the LDP. Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish). A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP. Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure. A - I agree - Sites R25 and R26 should be removed completely from the LDP. Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area. A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01. A - I agree - the Honeypot Lane site should be reinstated. Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed. A - I agree - the allocation in Blackmore is disproportionate and unsound. Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP. A - Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26976

Received: 26/11/2019

Respondent: Mr John Adkins

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore.

Full text:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic AllocationThe allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree

Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
A - I agree - we should prioritise building on sites with, or close to, existing infrastructure.

Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
A - I agree - the site should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed.
A - I agree - these sites are developer led and should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish).
A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
A - I agree - Sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm)

Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area.A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01.
A - I agree - the Honeypot Lane site should be reinstated.

Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
A - I agree - the allocation in Blackmore is disproportionate and unsound.

Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
A - Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26981

Received: 26/11/2019

Respondent: Ms Anne Adkins

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore.

Full text:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic AllocationThe allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree

Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
A - I agree - we should prioritise building on sites with, or close to, existing infrastructure.

Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
A - I agree - the site should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed.
A - I agree - these sites are developer led and should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish).
A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
A - I agree - Sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm)

Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area.A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01.
A - I agree - the Honeypot Lane site should be reinstated.

Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
A - I agree - the allocation in Blackmore is disproportionate and unsound.

Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
A - Strongly agree.

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26986

Received: 28/11/2019

Respondent: Mr Matthew Aiken

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore.

Full text:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic AllocationThe allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree

Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
A - I agree - we should prioritise building on sites with, or close to, existing infrastructure.

Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
A - I agree - the site should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed.
A - I agree - these sites are developer led and should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish).
A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
A - I agree - Sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm)

Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area.A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01.
A - I agree - the Honeypot Lane site should be reinstated.

Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
A - I agree - the allocation in Blackmore is disproportionate and unsound.

Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
A - Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26991

Received: 26/11/2019

Respondent: Kerry Allardyce

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore.

Full text:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic AllocationThe allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Q - FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
A - I agree

Q - FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
A - I agree - we should prioritise building on sites with, or close to, existing infrastructure.

Q - FOCUSSED CHANGE 4 - PART A POLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
A - I agree - the site should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART B The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed.
A - I agree - these sites are developer led and should be removed from the LDP.

Q - FOCUSSED CHANGE 4 - PART C At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore Parish).
A - I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
A - I agree - Sites R25 and R26 should be removed completely from the LDP.

Q - FOCUSSED CHANGE 5: PART A POLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
A - I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm)

Q - FOCUSSED CHANGE 5 - PART B R26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area.A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01.
A - I agree - the Honeypot Lane site should be reinstated.

Q - FOCUSSED CHANGE 5 - PART C SOUNDNESS AND HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
A - I agree - the allocation in Blackmore is disproportionate and unsound.

Q - CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
A - Strongly agree

Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26992

Received: 26/11/2019

Respondent: Mr Michael Bacon

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q - FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation. The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
A - I agree - Dunton Hills can accommodate the houses planned for Blackmore

Change suggested by respondent:

Remove R25ad R26 from the plan

Full text:

Q2 DATA PROTECTION:All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic AllocationThe allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019)Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites.Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP
Q8 FOCUSSED CHANGE 4 - PART BThe sites proposed are
developer led and still have not been properly assessed against
local housing needs.These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP
Q9 FOCUSSED CHANGE 4 - PART CAt the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART DAlso within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm)
Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area.A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated.
Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
I am former resident of Blackmore and am aware that building on this scale is totally disproportionate, and will cause massive disruption to life in this small
village.
Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP.
Strongly agree