Policy R19: Land at Priests Lane, Shenfield (page 292)

Showing comments and forms 31 to 60 of 544

Object

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

Representation ID: 26715

Received: 25/11/2019

Respondent: Mrs. Margaret Cartwright

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

This site is brownfield and therefore in accordance with the government and local policy for brownfield sites to be prioritised over green belt then this number should not be amended. It also requires maximum densities to be maintained in such occassions

Change suggested by respondent:

The allocation for 75 houses should remain in order to avoid development on green belt land

Full text:

This site is brownfield and therefore in accordance with the government and local policy for brownfield sites to be prioritised over green belt then this number should not be amaended. It also requires maximum densities to be maintained in such occassions

Object

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

Representation ID: 26729

Received: 26/11/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation:

NPPF para 31 requires planning policies to be underpinned by relevant and up to date evidence.

BBC need to be satisfied reduction in dwelling numbers is supported by appropriate evidence base, including:
- demonstrating site makes effective and efficient use of land (paragraphs 117, 118, 122 and 123 of the NPPF)
- is economically viable (paragraph 67)
- updated transport evidence base fully assesses
transport implications.

Proposed policy change does not address ECC's Pre-Submission Reg.19 consultation representations to this policy (March 2019).

ECC's position has not changed on this matter.

Change suggested by respondent:

As a result of the reduction in dwelling numbers for this site allocation BBC should include, within the Plan evidence and supporting text for this Policy, details to demonstrate that the site allocation makes effective and efficient use of land, and is economically viable.

BBC should also update its transport evidence base for the Local Plan to fully assess the transport implications of the change in dwellings numbers on this site allocation.

The policy needs to be further changed to address ECC's representations to this policy made to the Pre-Submission Regulation 19 Local Plan consultation in March 2019.

Full text:

2. Justified
3. Effective
4. Consistent with National Policy

Paragraph 31 of the NPPF requires planning policies to be underpinned by relevant and up to date evidence.

BBC will need to be satisfied that the reduction in dwelling numbers on this site is supported by the appropriate evidence base, including demonstrating that the site allocation makes effective and efficient use of land (paragraphs 117, 118, 122 and 123 of the NPPF), and is economically viable (paragraph 67).

BBC will need to be satisfied that the transport implications of the change in dwelling numbers on this site allocation are fully assessed through an updated transport evidence base for the Local Plan.

The proposed change to this policy does not address ECC's representations to this policy made to the Pre-Submission Regulation 19 Local Plan consultation in March 2019.
See
ECC 93 / BBC 22474
ECC 94 / BBC 22476
ECC 95 / BBC 22477

ECC's position has not changed on this matter.

Object

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

Representation ID: 26734

Received: 26/11/2019

Respondent: Mrs Annette Moorhouse

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Despite the reduction in the number of houses proposed I am still concerned about the additional traffic the development will create. A traffic survey has not been carried out and although multiple access has been suggested all the traffic will still come out onto Priests Lane.

Change suggested by respondent:

If only 45 houses are being proposed what will be the designated use for the remaining land? This needs to be used for the schools expansion or something along those lines. The multiple access cannot be guaranteed and the only main access is unsafe.

Full text:

Despite the reduction in the number of houses proposed I am still concerned about the additional traffic the development will create. A traffic survey has not been carried out and although multiple access has been suggested all the traffic will still come out onto Priests Lane.

Object

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

Representation ID: 26738

Received: 26/11/2019

Respondent: Miss katherine Webster

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

I have made an objection (referee 26711) re the change to the Priests lane site. I would like to add a comment to that objection, but was unable to amend the submitted comment. I would like to add that the utilities already seem to be operating at maximum satisfactory capacity, as we have low water pressure and frequently have drops in electricity supply when usage is high. Local residents are concerned that the infrastructure is not adequate to absorb the additional housing, and this continues to be the case even with a lower number.

Full text:

I have made an objection (referee 26711) re the change to the Priests lane site. I would like to add a comment to that objection, but was unable to amend the submitted comment.
I would like to add that the utilities already seem to be operating at maximum satisfactory capacity, as we have low water pressure and frequently have drops in electricity supply when usage is high. Local residents are concerned that the infrastructure is not adequate to absorb the additional housing, and this continues to be the case even with a lower number.

Object

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

Representation ID: 26740

Received: 26/11/2019

Respondent: Mrs Helen Pearson

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Whilst the reduction in dwellings is welcome, the number is not legally binding, and will give the developers the opportunity to bid to build a higher number of houses.
This land was designated an Open Urban Space, and as such seen as a valuable green lung to the area, once built on this will be lost for ever.
The access points to the potential development have not been identified. Where ever they are built they will have to join Priests Lane itself which has many hazards.
There is no possible point at which a new road can link with Priests Lane that would have a clear view of on coming traffic due to the bends in the road.
Priests Lane has the problems of congestion at peak times, necessitating traffic from the potential development trying to turn into queuing traffic. Priests Lane has speeding cars at other times meaning that the cars turning from the new access points will not have enough time to turn onto the road.
There is only a pavement down one side of Priests Lane
this alternates from side to side, pedestrians need to cross this busy road at dangerous bends in order to walk down the road.
Priests Lane is narrow and at two pinch points there is not enough room for two vehicles to pass. Pedestrians feel vulnerable on these narrow pavements as traffic literally skims by them as they walk.
There have been many accidents along Priests Lane, for the most part unrecorded as the police only record accidents involving casualties.
The road does not meet the current safety guide lines and to build another junction turning onto this road would exaserbate the present dangers to all road users.

Change suggested by respondent:

Remove site R19 form the plan

Full text:

I am contacting you with regards to the development of the land at Priests Lane, Brentwood, sites 044 and 178.

Whilst the reduction in dwellings is welcome, the number is not legally binding, and will give the developers the opportunity to bid to build a higher number of houses.

This land was designated an Open Urban Space, and as such seen as a valuable green lung to the area, once built on this will be lost for ever.

The access points to the potential development have not been identified. Where ever they are built they will have to join Priests Lane itself which has many hazards.
There is no possible point at which a new road can link with Priests Lane that would have a clear view of on coming traffic due to the bends in the road.

Priests Lane has the problems of congestion at peak times, necessitating traffic from the potential development trying to turn into queuing traffic. Priests Lane has speeding cars at other times meaning that the cars turning from the new access points will not have enough time to turn onto the road.

There is only a pavement down one side of Priests Lane
this alternates from side to side, pedestrians need to cross this busy road at dangerous bends in order to walk down the road.

Priests Lane is narrow and at two pinch points there is not enough room for two vehicles to pass. Pedestrians feel vulnerable on these narrow pavements as traffic literally skims by them as they walk.

There have been many accidents along Priests Lane, for the most part unrecorded as the police only record accidents involving casualties.

The road does not meet the current safety guide lines and to build another junction turning onto this road would exaserbate the present dangers to all road users.

Object

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

Representation ID: 26746

Received: 26/11/2019

Respondent: Basildon Borough Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising
car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.

Full text:


RE: BASILDON BOROUGH COUNCIL REPRESENTATION TO THE ADDENDUM OF FOCUSSED CHANGES TO THE PRE-SUBMISSION LOCAL PLAN (REG 19)
This letter serves as the approved response from Basildon Borough Council to the Brentwood Borough Council's Addendum of Focussed Changes to the Pre-submission Local Plan (Reg 19).
As a neighbouring authority, a Duty to Cooperate public body and a key partner in the Association of South Essex Local Authorities (ASELA), Basildon Borough Council has taken the opportunity to review and consider the potential implications for Basildon Borough that may arise from Brentwood Borough Council's Addendum of Focussed Changes.
It is noted that the Addendum of Focussed Changes is proposing the redistribution of 70 proposed dwellings from the "Central Brentwood Growth Corridor" to the Dunton Hills Garden Village (DHGV). Basildon Council objects to the proposal to create a standalone new village (DHGV) to the west of the joint administrative boundary as previously indicated in our responses to Brentwood's Local Plan consultations in February 2016, March 2018 and March 2019. Basildon Council maintains the view that there currently remains a lack of credible and robust technical evidence to justify that a new village in this Green Belt location is the best option for meeting Brentwood Borough's housing needs, and continues to have doubts whether this allocation would be found sound at Examination in Public. In giving this view, Basildon Council is apprehensive that the scale of development proposed, which amounts to over a third of the borough's entire housing provision for the plan period, could be supported by infrastructure in the absence of a clear delivery plan. It remains unclear, if the proposal were to be approved, how it will relate in terms of access and connectivity to the Basildon urban area given that the nearest Town Centre and acute healthcare facilities are all within Basildon Borough.
Focussed Changes 1 - 5 (Redistribution of housing)
Basildon Council objects to the Focussed Changes 1 - 5, as they do not seem to have been informed by evidence or the Sustainability Appraisal as required by National Policy. The amendments effectively redistributes 70 proposed dwellings from the 'Central Brentwood Growth Corridor', which has opportunities to embrace more sustainable modes of transport, to a Green Belt location with a less developed public transport infrastructure. The reasons for the amendments do not seem to be supported by the evidence and appear to be based solely on the considerable number of objections received in response to the Pre-Submission Local Plan consultation in March 2019. The Brentwood Sustainability Appraisal October 2019 concludes that;
"It is difficult to draw strong conclusions, with the primary considerations being: A) decreasing the homes assigned to the Brentwood/Shenfield urban area by 50 may serve to reduce traffic through the problematic town centre AQMA, but any benefit would be marginal, and equally these are accessible locations suited to minimising car dependency; and B) increasing the number of homes assigned to DHGV by 70 is potentially associated with a degree of risk, noting the ongoing work being undertaken in respect of improving air quality along the A127 within Basildon Borough, and noting consultation responses received."
Paragraph 16 of the NPPF advises amongst other things that Plans should be prepared with the objective of contributing to the achievement of sustainable development. Basildon Council has considered the two Growth Corridors identified in the Brentwood Borough Local Plan. It has reflected however that there are fundamental distinctions between them, which do not appear to have influenced site selection choices in a justified way. The Central Brentwood Growth Corridor is the location of nationally and regionally managed and maintained infrastructure - the A12 & M25 (Highways England) and the Elizabeth Line (maintained by Network Rail and operated by Transport for London) and East Anglia Line (maintained by Network Rail and operated by Abellio East Anglia). Growth in this location would maximise this infrastructure investment. The South Brentwood Growth Corridor meanwhile, consists the A127 (maintained by Essex County Council) and Essex Thameside Line (maintained by Network Rail and operated by c2c).
It is not considered that the two corridors offer comparable choices in terms of the strategic importance or capacity of transport connections, and using the Sustainability Appraisal and other evidence, the Plan should select sites within the Central Brentwood Growth Corridor that provide opportunity for extensions to towns and villages that can encourage more sustainable travel choices and take advantage of the strategic infrastructure available. This would encourage commuting behaviour to shift away from private car use and therefore make this location a more sustainable and viable option to concentrate growth. Such an alternative approach would be justified by evidence and align with national policy.
Housing Trajectory
Basildon Council objects to the housing trajectory, particularly on the reliance on DHGV to deliver at an accelerated rate of construction and early within the plan-period. The housing trajectory included within the Addendum of Focussed Changes with regard to Dunton Hills Garden Village assumes that delivery will commence in 2022/23 (within the next five years) starting with 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 the extent of the Green Belt, requires master planning and will need to be subject to an Examination in Public in order to determine whether it should be allocated, before going through the planning application process and elements of the condition discharge process before development on site can even commence. Development commencement on-site will meanwhile be reliant on essential utility and infrastructure provision. No evidence was provided within the Reg19LP or the Addendum of Focussed Changes as to how the housing trajectory in general has been developed. Furthermore, there is no specific evidence published setting out the evidence base or any form of a development framework/ masterplan for the Dunton Hills Garden Village which explains how the proposed accelerated rate of delivery will be possible to achieve. Early residents of the Dunton Hills Garden Village, should it be approved, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, the Dunton Hills Garden Village will require new primary and secondary school provision. However, whilst the Brentwood Infrastructure Delivery Plan shows the primary provision in particular being delivered early, it is not economically viable to operate a school with low pupil numbers, and it may be the case that the village grows for a number of years with these pupils travelling to other schools in the locality, whilst operational primary and then secondary education provision is secured.
The Council therefore seeks for evidence to be provided demonstrating a realistic delivery trajectory for DHGV so that the potential short-medium term pressures on services and facilities in nearby settlements can be assessed, understood and planned for by service providers and neighbouring authorities. This will help ensure adequate mitigation provisions can be put in place to reduce any potential negative impacts on Basildon Borough residents living nearby.
Transport and Infrastructure impacts of DHGV
The Addendum of Focussed Changes provided an opportunity for the Brentwood Local Plan to clarify matters relating to transport and infrastructure mitigation measures on the surrounding areas. The DHGV is within close proximity of the administrative boundaries with Basildon & Thurrock Boroughs, and Basildon Council still remains concerned by the lack of mitigation measures on potential infrastructure impacts and is disappointed that Brentwood Council have not taken the opportunity to address this through the Addendum of Focussed Changes.
Basildon Council are aware that Brentwood see themselves as a standalone housing market Area, however development in the proximity of administrative boundaries will have cross boundary infrastructure impacts that need to be addressed but both the Reg19 LP and the Addendum of Focussed changes do not appear to have addressed. It is noted that the need for new connections into Basildon Borough in terms of walking, cycling, public transport or road do not appear to be mentioned as being necessary to make it sustainable
The transport mitigation measures included in the pre submission local plan are concentrated within Brentwood and ignore the fact that Laindon Station, has more platforms and has greater commutable capacity than West Horndon and could become an alternative choice for residents of the Dunton Hills Garden Village. Furthermore, early residents of the Dunton Hills Garden Village, will rely on some services and facilities outside the 'village' to meet their initial needs. As an example, Dunton Hills Garden Village is proposing new primary and secondary school provision. However, until such a time as the critical mass for new homes is established, it is more likely that Basildon Borough's facilities in Laindon will be picking up the demands of new users arising from the new settlement.
While using Basildon Infrastructure like the station, schools and the hospital, there will be added pressure on the A127, Basildon road network and public transport services.
It is questionable whether it can be adequately demonstrated by the Brentwood Local Plan that the allocations chosen, represent the most sustainable option without identifying and testing the viability of specific highway mitigation measures that will be necessary to make them deliverable and sustainable. Without this work, Brentwood Borough could find its ability to unlock the capacity to deliver new communities and homes, particularly at an accelerated pace becomes hindered by a lack of infrastructure capacity.
It should not be assumed that such growth can just be absorbed by the nearby infrastructure and services and Basildon Council expects policies in the Brentwood Local Plan to make it clear that S106/CIL or other funding receipts will be spent outside Brentwood Borough to sufficiently address where negative direct or residual impacts could otherwise occur.
This concludes the Council's representation. If you wish to discuss any of the matters raised above, please do not hesitate to contact the planning policy team who will make arrangements to meet with you.
Yours sincerely,
Christine Lyons
Head of Planning

Object

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

Representation ID: 26766

Received: 26/11/2019

Respondent: Mr Russell Pearson

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

I am contacting you with regards to the development of the land at Priests Lane, Brentwood, sites 044 and 178.
Whilst the reduction in dwellings is welcome, the number is not legally binding, and will give the developers the opportunity to bid to build a higher number of houses.
This land was designated an Open Urban Space, and as such seen as a valuable green lung to the area, once built on this will be lost for ever.
The access points to the potential development have not been identified. Where ever they are built they will have to join Priests Lane itself which has many hazards.
There is no possible point at which a new road can link with Priests Lane that would have a clear view of on coming traffic due to the bends in the road.
Priests Lane has the problems of congestion at peak times, necessitating traffic from the potential development trying to turn into queuing traffic. Priests Lane has speeding cars at other times meaning that the cars turning from the new access points will not have enough time to turn onto the road.
There is only a pavement down one side of Priests Lane
this alternates from side to side, pedestrians need to cross this busy road at dangerous bends in order to walk down the road.
Priests Lane is narrow and at two pinch points there is not enough room for two vehicles to pass. Pedestrians feel vulnerable on these narrow pavements as traffic literally skims by them as they walk.
There have been many accidents along Priests Lane, for the most part unrecorded as the police only record accidents involving casualties.
The road does not meet the current safety guide lines and to build another junction turning onto this road would exaserbate the present dangers to all road users.

Change suggested by respondent:

Remove site R19 from the plan

Full text:

Dear Sir/ Madam,

I am contacting you with regards to the development of the land at Priests Lane, Brentwood, sites 044 and 178.

Whilst the reduction in dwellings is welcome, the number is not legally binding, and will give the developers the opportunity to bid to build a higher number of houses.

This land was designated an Open Urban Space, and as such seen as a valuable green lung to the area, once built on this will be lost for ever.

The access points to the potential development have not been identified. Where ever they are built they will have to join Priests Lane itself which has many hazards.
There is no possible point at which a new road can link with Priests Lane that would have a clear view of on coming traffic due to the bends in the road.

Priests Lane has the problems of congestion at peak times, necessitating traffic from the potential development trying to turn into queuing traffic. Priests Lane has speeding cars at other times meaning that the cars turning from the new access points will not have enough time to turn onto the road.

There is only a pavement down one side of Priests Lane
this alternates from side to side, pedestrians need to cross this busy road at dangerous bends in order to walk down the road.

Priests Lane is narrow and at two pinch points there is not enough room for two vehicles to pass. Pedestrians feel vulnerable on these narrow pavements as traffic literally skims by them as they walk.

There have been many accidents along Priests Lane, for the most part unrecorded as the police only record accidents involving casualties.

The road does not meet the current safety guide lines and to build another junction turning onto this road would exacerbate the present dangers to all road users.
Yours sincerely
Russell Pearson

Object

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

Representation ID: 26767

Received: 26/11/2019

Respondent: Ursuline Sisters

Agent: JTS Partnership LLP

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation:

Strongly object to the 5 proposed changes, particularly to R19 (change 3). The basis of this objection is that the proposed delivery of the housing, as set out within Appendix 1 of the Consultation Document is not achievable or viable, and that the Plan should be considered as unsound. Furthermore the reallocation of the 30 units from Policy R19 is not justified or supported by any evidence and ignores the evidence presented by the landowner.

In respect of the reduction in numbers at Policy R19 Land at Priests Lane, there is no justification or evidential support for such a reduction. The landowner has provided
Highways evidence to support much higher degrees of provision that will see the efficient use of land as required by the NPPF. Also highlighted are the many highway and pedestrian improvements that will enhance pedestrian accessibility and the wider highway network.
There is great uncertainty about the ability to deliver the full DHGV allocation within the Plan Period. With a significant reliance on that allocation to achieve the full Housing Supply, it is not sustainable to remove the provision delivery of achievable units from other
sites where such can be delivered in the early part of the Plan Period. The projected delivery of the DHGV allocation in terms of its commencement and the ongoing
delivery rate through the Plan Period is considered to be unrealistic and unviable. It relies on achieving the delivery of the first units within 2 to 3 years of the Adoption of the Local Plan and then delivering housing at a very high rate through the final 7 years of the Plan Period. While these targets may be achievable in the best case scenario, the NLP study supports the opinion that for large projects, delivery is likely to take a much greater
amount of time. The Council provide no evidence to support such lofty targets. These best case scenario projections should not be adopted as realistic delivery targets
through the Plan Period. Reallocating 70 units to the latter stages of the Housing Trajectory only increase the likelihood of a failure to meet the full housing supply through the Plan Period.

Change suggested by respondent:

Return the indicative dwelling yield to 75. Do not make the Addendum changes to the plan.

Full text:

1.1 The following representations are made on behalf of The Ursuline Sisters Brentwood
Charitable Incorporated Organisation (CIO) - "the Sisters" - and form two parts.
1.2 Firstly, specific comment is made on the proposed changes to Policy R19 (Land at Priests
Lane, Shenfield) - Focussed Change 3, the large part of which is land within the Sisters'
ownership.
1.3 Secondly, representations are made on the soundness of the approach set out within the
Addendum of Focussed Changes to the Pre-Submission Local Plan (the "Consultation
Document"), which sees the reduction in allocation numbers across four sites and their
reallocation to the Dunton Hills Garden Village Strategic Allocation (sites under Policy R18,
R25 and R26) to within the latter part of the Plan Period - Focussed Changes 1-5.
1.4 The proposed changes to these four allocations sees a total loss of 70 units and their
reallocation to the Dunton Hills Garden Village Strategic Allocation (DHGV), increasing its
allocation to 2,770 units (Policy R01).
1.5 In respect of the Land at Priests Lane, Shenfield, a loss of 30 units is proposed to a
provision of "around 45 homes".
1.6 In responding, we confirm The Sisters' objection to the 5 focussed changes as set out
within this Consultation Document. The basis of this objection is that the proposed delivery
of the housing, as set out within Appendix 1 of the Consultation Document is not achievable
or viable, and that the Plan should be considered as unsound. Furthermore the
reallocation of the 30 units from Policy R19 is not justified or supported by any evidence
and ignores the evidence presented by the landowner.
2.0 Focussed Change 3
Lack of Evidence to Support Reduction
2.1 It is noted generally that the Focussed Changes Consultation is centred upon five key
Policies in relation to four housing sites. The objective to achieve some reduction in
housing numbers on those identified sites and to lump the reduced number into the key
Dunton Hills Garden Village Strategic location. We strongly object to the general thrust of
that approach as it will leave the Plan unsound. Brentwood Council are relying too strongly
on one strategic release which has knock-on consequences for the plan as a whole. The
focus of this objection is in relation to Policy R19 (Land at Priests Lane, Shenfield)
reduction from "around 75" to "around 45 homes".
2.2 There is no explanation for the proposed decrease. The Local Authority evidence base
initially accepted and proposed in the Consultation Plan, January 2016, Priests Lane was
suitable for 130 dwellings. The land owners and their agents had worked closely with
Brentwood Council Officers and Essex County Council Highway Officers to show that in
terms of highway infrastructure the site was capable of accommodating at least that amount
of housing.
2.3 It had also been acknowledged by Officers during the course of many years discussion that
the Priests Lane site was the Council's most sustainable housing site. That position has
not changed.
2.4 There have been significant poorly informed objections from local residents and it is political
pressure that has brought the continued reduction in housing on the subject site.
2.5 We had shared with the Local Authority many reports that the land owners had secured
including two from Waterman Infrastructure and Environment Limited that had helped assist
the masterplanning of the site and which reflected concerns raised by residents as to the
unsuitability of Priests Lane and criticisms of the condition of the local footway links. The
conclusion from the Pedestrian Environment Review is that there is a good system of
footpath links, that third party criticism relates predominantly to highway maintenance
issues and that as a consequence of development the introduction of formal crossing points
in one or two locations would be a major benefit to the local footpath network providing
significant improvements to pedestrian safety and ease of access to the key centres of
Brentwood and Shenfield.
2.6 The Highways Technical Note concluded that the site is ideally located in a sustainable
location that MfS visibility splays are achievable. Predicted traffic impact and junction
assessments demonstrate that a potential residential development of up to 130 dwellings
will have a limited impact on the immediate and wider highway network. Finally that a
development of up to 130 residential units can be accommodated in this location accessed
from Priests Lane via a draft Essex Design Guide Type D "Access Road" arrangement.
Deliverability
2.7 This is one of the most, if not the best deliverable site within the Borough. It has remained
vacant for some 18 years and is easy to develop with no constraints. Flood Risk
Assessment has been prepared and a Drainage Strategy developed, there are no
ecological or tree constraints. All previous versions of the Consultation Local Plan, 17, 18
and 19 had shown the early deliverability of this site. From the baseline year of 2016/2017
the site is shown as delivering some houses, in 2020/2021 with realistic numbers for 2021,
2022, and 2023. It is possible given the status of the land its interest from the housing
industry that nearly all the housing could be brought forward by the end of 2022. Thus it
falls in a small category of allocated sites that will come forward in the early Plan period.
There is an over reliance by the Local Authority on larger sites not assured until the middle
to latter part of the Plan period. Indeed, full deliverability will not be achieved by 2030-
2033.
3.0 Focussed Change 1 - 5
3.1 The Focused Change 1 proposes changes to Policy R01 (I): Dunton Hills Garden Village
Strategic Allocation (DHGV) (page 252 of the Pre Submission Local Plan, February 2019).
Section B and D are amended to increase the DHGV housing provision from 2,700 to
2,770.
3.2 Appendix 1 of the Consultation Document sets out the projected delivery through the Plan
Period from 2016/17 to 2032/33. The first line of that table shows the DHGV allocation
delivery (page 10 of the appendix) and the first column erroneously states a change from
2700 to 2750 - this should read 2770. The final 3 columns of that line represent the final 3
years of the plan period. They show the additional 70 units to be delivered in these years,
with 25, 25 and 20 units through years 2030/31, 2031/32 and 2032/33 respectively.
3.3 These 70 units are taken from the following sites in the following Years in the Plan Period:
* Focussed Change 2 - Land at Crescent Drive Shenfield (+5 units) - Year 2023/23
* Focussed Change 2 - Land at Crescent Drive, Shenfield (-25 units) - Year 2023/24
* Focussed Change 3 - Land at Priests Lane, Shenfield (-30 Units) - Year 2022/23
* Focussed Change 4 - Land North of Wollard Way, Blackmore (-10 units) - Year
2024/25
* Focussed Change 5 - Land South of Redrose Lane/North of Orchard Piece,
Blackmore (-10 units) - Year 2022/23
3.4 The Focussed Changes 2 - 5 therefore see the reduction in delivery of 70 Units through
the Plan Period Years 2023 - 2025, with them redistributed to DHGV through Years 2030
to 2033.
3.5 Before considering the ability of the DHGV allocation to deliver within the stated timeframe,
it is important to note that projected delivery through the early years of the Plan Period,
2016 - 2022, is only 264 dwellings per annum (dpa) which falls way below the annualised
requirement of 456dpa - See Consultation Document Appendix 1. Indeed the proposed
loss of 35 units from 2022/23 sees its provision also fall below the average requirement, to
440. The first 7 years of the 17 year Plan Period is projected to deliver 2,027 units of the
required total provision of 7,752. This sees the remaining 10 years needing to make a
provision of 5,725, of which 2770 is proposed for the DHGV allocation. This equates to
48% of all supply in the latter 10 years of the Plan Period. In overall terms DHGV accounts
for 35% of provision.
3.6 The Plan is, therefore, significantly reliant on the DHGV allocation to meet the overall
supply of housing and in particular in the latter 10 years of the Plan Period from 2023 to
2033 to achieve significantly higher levels of provision to offset the 'slow start'.
3.7 It is therefore imperative that the projected timing and rate of delivery of the DHGV
allocation is realistic and viable. Where it is not, the Plan will fail to meet Policy SP02
housing delivery objective. Where this delivery timetable cannot be viewed as robust, the
Plan must be deemed as being unsound.
3.8 There are significant concerns about the robustness of this delivery timetable and this
position is only compounded by these focussed changes which remove deliverable unit
numbers from the early/middle part of the Plan Period and add them on to the end.
3.9 The current delivery programme identifies that the DHGV allocation is anticipated to begin
delivering units in the Year 2022/23, with the first 100 of the 2770 allocation being made
and the remainder being delivered in the following 9 years at an average of 297 dpa.
3.10 There are two issues in respect of this programme. Firstly, the achievability of the DHGV
delivery start date; and the subsequent rate of delivery from there on.
DHGV Housing delivery commencement
3.11 At the date of this consultation, the Plan predicts delivery at DHGV to commence within the
next 3 - 4 years. The Council's current LDS sets out a timetable for the Adoption of the
Plan (Regulation 26) to be achieved by Q3 of 2020. From this point of Adoption, delivery of
housing on the DHGV will need to be achieved within 2-3 years.
3.12 Credible research by NLP1 indicates that sites over 2,000 dwellings take an average of
around seven years from the submission of the first planning application to the delivery of
the first dwellings on site.
3.13 In the case of DHGV, very little work has been undertaken to form part of the Evidence
Base to demonstrate that the delivery of housing is achievable within 2 or 3 years from the
best case Adoption of the Local Plan.
3.14 While this research shows that Greenfield Sites do come forward at a quicker rate, the
DHGV site presents a significant number of challenges in masterplanning and bringing
forward development. These include large areas of the site being sited within the Flood
Zone 3, its location within the Green Belt, the need to make highways improvements at key
junctions and work to improve air quality along the A127 within Basildon. Furthermore
there is a need to work cooperatively with the adjoining Basildon Council to ensure
settlement coalescence is avoided and discussions between the Councils have taken place
in respect of agreeing a Landscape Corridor. While a study has been undertake and
signed off by both, Brentwood Borough Council has not utilised this work in determining the
extent of development and thus this issue remains unresolved.
3.15 Masterplanning of the site has not yet commenced. Development across the allocation will
likely involve multiple outlets (house builders) and while this can see increased housing
delivery rates, the key matter will be agreeing and publishing a masterplan which will allow
for planning applications from the various outlets to come forward. The challenges to
achieving a masterplan, as highlighted in para. 2.14 above, to address the site specific
needs of the allocation are substantial and will require significant work to resolve prior to
the completion of a masterplan and the commencement of the first phase of development.
1 Start to Finish - How Quickly do Large Scale Housing Sites Deliver/ (November 2016)
3.16 The NLP study identifies that for larger sites (+2000 units) the average time from the first
application to permit development and the delivery of the first unit is 0.8 years. Working
backwards from the current delivery timetable, this would require detailed planning
permission to be granted for the first phase of development by the end of 2022 at the latest.
This leaves approximately 2 years from the projected Adoption of the Local Plan to submit
and achieved detailed planning permission. In light of the limited amount of work
undertaken to date in setting out a masterplan, this timeframe is considered as very
unrealistic.
3.17 The NLP study identifies that for the larger sites, the time taken to achieve planning
permission from the validation of the first application to the granting of planning consent
which permits development of dwellings on site is 6.1 years. This takes no account of the
discharging of conditions as well as all necessary building control approval prior to
development commencing on site. The NLP analysis highlights that it has been possible
for large sites within their study data to achieved planning within 2 years. However this
represents the best case scenario. Where a median average is applied, such extremes at
either end of the scale would be discounted. 2 years should not be used as a reasonable
expectation in this case. There will be many site specific issues that will have to be
resolved at the masterplan and phasing stages and such work will take considerable time.
3.18 This analysis supports our conclusion that the projected commencement of delivery of the
DHGV is extremely optimistic to the degree that it is considered unrealistic. The evidence
base provides no detailed support to this Housing Trajectory and a failure to deliver
substantial amount of housing on this projected timeframe will see the failure of the Plan to
meet the housing need.
3.19 The approach to remove proposed units from other allocations during the first half of the
plan period and redistribute them to the end of the Plan Period is unsustainable that only
further increases the likelihood of the Plan failing. As such the Plan should be considered
unsound on the basis of the unviable nature of the Housing Trajectory.
3.20 The approach should be the opposite of that being undertaken through these focussed
changes. Rather than adding greater requirement for the DHGV allocation housing in the
Plan Period, other sites that are deliverable in the short to medium term should be
assessed to achieve greater housing numbers and efficiencies to offset against the
significant risk that the DHGV allocation will not deliver the very high numbers of housing
necessary to meet the overall supply.
Rate of Delivery
3.21 The Housing Trajectory predicts that the DHGV allocation will see the delivery of 100
dwellings in its first year (2022/23) with this gradually increasing to 300 dpa by 2026/27.
The final three years predict 270-275 dpa.
3.22 These rates of delivery represent very high figures. Such delivery is highly questionable
both in terms of the physical rate of delivery and their absorption rates (sales). The NPL
study highlights an average rate of delivery for schemes of +2000 dwellings of 161 dpa.
The highest annual average build rate of the 70 schemes assessed was 321 dpa, but this
only delivered for 3 years and that project (Cranbrook, East Devon) required significant
public sector money to enable phase 2 to commence and drive forward its completion.
3.23 The projected delivery rates for the DHGV allocation are therefore at the upper end of what
the NLP study considered achievable. It is not sound to base the projected delivery of
housing at such high rates simply to accommodate the required provision within the Plan
Period. Furthermore where any delay occurred to the commencement of this delivery even
greater demand would be put on the rate of delivery going forward.
3.24 Finally, the reallocation of 70 units within these Focussed Changes from the early/middle
part of the Plan Period to the latter three years increases the likelihood of such provision
not being achieved in the Plan Period. This is unsound where such delivery is achievable
in the early part of the Plan Period. It represents a systematic approach by the Council to
minimise delivery of housing in certain areas of the Borough in favour in placing further
demand on the DHGV allocation.
3.25 Such rates of delivery are not considered to be reasonable or realistic. The Plan provides
no robust evidence to support either this rate of delivery or the ability to commence delivery
by 2022/23 and thus the proposed Housing Trajectory should be considered as unviable
and the Plan unsound.
4.0 Summary & Conclusion
4.1 In respect of the reduction in numbers at Policy R19 Land at Priests Lane, there is no
justification or evidential support for such a reduction. The landowner has provided
Highways evidence to support much higher degrees of provision that will see the efficient
use of land as required by the NPPF. Also highlighted are the many highway and
pedestrian improvements that will enhance pedestrian accessibility and the wider highway
network.
4.2 There is great uncertainty about the ability to deliver the full DHGV allocation within the
Plan Period. With a significant reliance on that allocation to achieve the full Housing
Supply, it is not sustainable to remove the provision delivery of achievable units from other
sites where such can be delivered in the early part of the Plan Period.
4.3 The projected delivery of the DHGV allocation in terms of its commencement and the ongoing
delivery rate through the Plan Period is considered to be unrealistic and unviable. It
relies on achieving the delivery of the first units within 2 to 3 years of the Adoption of the
Local Plan and then delivering housing at a very high rate through the final 7 years of the
Plan Period. While these targets may be achievable in the best case scenario, the NLP
study supports the opinion that for large projects, delivery is likely to take a much greater
amount of time. The Council provide no evidence to support such lofty targets.
4.4 These best case scenario projections should not be adopted as realistic delivery targets
through the Plan Period. Reallocating 70 units to the latter stages of the Housing
Trajectory only increase the likelihood of a failure to meet the full housing supply through
the Plan Period.

Object

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

Representation ID: 26774

Received: 22/11/2019

Respondent: Turn2us

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

The AFC does not address the potential implications for the provision of accommodation for older people in light of the concerns it has identified in respect of proposed allocation R19. It neither explains why the site's potential to accommodate a care home is unaffected by the concerns it identifies, nor propose anything to address potential shortfall of this form of specialist accommodation assuming its potential to be provided here is affected.

Change suggested by respondent:

Allocate additional site to delivery at least 70 additional homes in the early years of the plan period (2022/23 - 2024/25). Site 219 (land at Rayleigh Road, Hutton) represents an ideal site to respond to the above.

Full text:

1.0 Introduction and background
1.1 This representation on the Brentwood Borough Council's Addendum of Focussed Changes to the Pre Submission Local Plan (AFC) is made by Strutt & Parker on behalf of Turn2Us.
1.2 Turn2Us is a national, registered charity with a mission to fight poverty in the UK and Ireland, helping individuals who are struggling financially to gain access to financial help. Each year the charity assists several million people in a range of different ways. It has seen a steady increase in the number of people turning to the charity for help in recent years. The charity receives no Government funding. It is through donations and legacies that it raises funds, and the charity is committed to ensuring long-term financial sustainability
1.3 Turn2Us is the freeholder of the majority of the area of land between Hutton Village, Rayleigh Road and Church Lane. A small portion of this land, located immediately adjacent to the existing settlement and adjoining Rayleigh Road and Hutton village, measuring 2.4 ha is being actively promoted by Turn2Us for residential allocation in the Council's new Local Plan.
1.4 Strutt & Parker have made representations on the Brentwood Borough Pre-Submission Local Plan (February 2019) (PSLP) on behalf of Turn2Us and in relation to this land at Rayleigh Road, Hutton (site reference 219 in the Council's plan-making process).
1.5 Concerns regarding the soundness of the PSLP set out in our representations made remain, but are not repeated here to avoid duplication.
1.6 This representation focuses on the proposed focussed changes to the PSLP, set out in the consultation draft of the AFC. These comprise the following:
1. Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation): Increase from "at least 2,700" to "at least 2,770 homes in the plan period";
2. Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes";
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3. Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes";
4. Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes"; and
5. Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".
1.7 The AFC explains that the modifications are proposed due to concerns raised through consultation on the PSLP relating to proposed allocations R18, R19, R25 and R26, necessitating a reduction in the number of additional homes these proposed allocations can suitably accommodate (Focussed Changes 2-5).
1.8 The AFC explains that the total loss of 70 homes across the four aforementioned sites will be off-set through proposed focussed change to increase the number of new homes provided at Dunton Hill Garden Village (Focussed Change 1). However, the AFC 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).
1.9 We have a number of concerns with the proposed approach to addressing the shortfall that Focussed Changes 2-5 necessitate by simply stating that Dunton Hills Garden Village will deliver at a greater rate than previously suggested, 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.
1.10 The PSLP as amended by the AFC remains unsound. However, in our view it is capable of being made sound. Our concerns and suggested approach to addressing these is set out in this representation.
2.0 Concerns with proposed focussed changes
2.1 The AFC identifies that the number that proposed allocations R18, R19, R25 and R26 will deliver is required to be reduced by a total of 70 from the figure identified in the PSLP.
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2.2 The AFC explains that the justification for this reduction is, in short, that these four sites are no longer considered suitable to accommodate the quantum of development identified in the PSLP.
2.3 We have no details of the evidence supporting this view, providing a revised assessment of the sites' capacities; and none appear to have been published as part of the consultation.
2.4 However, it must be recognised that the NPPF requires:
a) Local Plans to provide a strategy to meet housing needs with sufficient flexibility to be able to respond to rapid change; and
b) Housing requirements to be considered as minimums.
2.5 In light of the above requirements, it is necessary for the Council to take a conservative and precautionary approach in assessing the potential capacity of sites for housing for the purposes of demonstrating that the strategy will meet housing needs. This does not of course mean that policies should restrict capacities, merely that the trajectory should not be overly optimistic as to what may be delivered.
2.6 As such, regardless of whether the proposed focussed changes to R18, R19, R25 and R26 are ultimately implemented following the current consultation, the trajectory accompanying the Local Plan cannot rely on these sites to deliver the number of dwellings originally proposed in the PSLP.
2.7 In terms of the AFC's proposed solution to addressing the shortfall resulting from the revised assessment of proposed allocations, this is evidently unsound - it is neither justified, consistent with national policy nor effective. Furthermore, it fails to ensure the Local Plan can be considered positively prepared.
Projected first year of completions for Dunton Hills Garden Village
2.8 Appendix 1 to the PSLP provided a housing trajectory based on the proposed allocations. This suggested that 100 dwellings will be completed at Dunton Hills Garden Village in 2022/23. From 2023/24, projected completions fluctuated between 150 and 300 dwellings per annum.
4
2.9 The AFC sets out a revised trajectory to respond to the proposed focussed changes. This shows no change to the number of dwellings projected for Dunton Hills Garden Village in any year between 2022/23 and 2029/30, and that the first homes (totalling 100 for the year) will still be completed in 2022/23.
2.10 Within our representations on the PSLP (see paragraphs 35-38) we explained that it was wholly unrealistic to suggest that 100 dwellings could be delivered at Dunton Hills Garden Village as soon as 2022/23. At the time of our PSLP representations, it was based on an optimistic assumption that the Brentwood Borough Local Plan would be adopted in 2019. Clearly there is now no such prospect. Indeed, given the current stage in the process and the extent of delays, even adoption before the end of 2020 would now be challenging.
2.11 The PSLP proposes that Dunton Hills Garden Village will comprise around 4,000 dwellings (2,700 to be delivered by 2033). A study by NLP (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? (November 2016)) reviewed 70 strategic sites which have delivered / will deliver more than 500 dwellings. The study reviewed sites varied in size (from 504 to 15,000 dwellings) and location. The study identified that the average planning approval period for schemes comprising more than 2,000 dwellings was 6.1 years. Following planning approval, the study found that a period of 0.8 years could be expected before the first completions on such sites. In short, it would be appropriate to allow for a period of 7 years from anticipated first planning application before first completions. Indeed, given the NPPF requirement to ensure a flexible strategy, it would be prudent to allow for longer.
2.12 Given the delays to the Local Plan process, and assuming - optimistically - that the Brentwood Borough Local Plan will be adopted in 2020, the trajectory should not show completions at Dunton Hills Garden Village until 2027/28 at the earliest, unless robust evidence can be provided to demonstrate that it will come forward quicker than other schemes of comparative size.
2.13 Not only does the above give rise to significant concerns that the PSLP will not ensure housing needs are met in the early years of the plan period, it demonstrates that it would be wholly inappropriate to assume Dunton Hills Garden Village will accommodate an even greater number of dwellings by 2033 than the PSLP did.
5
Proposed changes to Dunton Hill Garden Village delivery rate
2.14 The housing trajectory within the AFC shows that the number of dwellings per annum to be delivered at Dunton Hills Garden Village will increase from 250 to 275 for 2030/31 and 2031/32, and from 250 to 270 in 2032/33.
2.15 However, no evidence has been presented as justify the increase in projected delivery rate for these years.
2.16 The projected delivery rates for Dunton Hill Garden Village set out within the PSLP were already ambitious - the NLP study referred to previously found that the average delivery rate for schemes comprising over 2,000 dwellings was only 161 dwellings per annum.
2.17 The further increase proposed by the AFC is not justified; is ineffective in ensuring delivery; and risks a shortfall in the timely provision of housing, rendering the Local Plan inconsistent with the NPPF and incapable of being considered positively prepared.
Delivery of homes delayed and five-year housing land supply
2.18 There is an acute need for new homes within Brentwood Borough. The provision of new homes within the early years of the plan period is critical.
2.19 As we noted at paragraph 31 of our representations on the PSLP, the Borough currently is significantly short of having a five-year housing land supply as required by the NPPF. It would be wholly inappropriate to delay provision of housing.
2.20 The AFC proposes that the reduction in supply from sites identified as contributing to housing delivery from as early as 2020/21 be compensated for by an increase in the number of new homes to be provided between 2030/31 and 2032/33. In short, upon identifying that fewer homes will be delivered in the early years of the plan period, it is proposed to rectify this through increasing delivery at the end of the plan period. Such an approach is, in our view, wholly inappropriate, and contrary to the NPPF's call to significantly boost the supply of homes.
2.21 We identified within our PSLP representations that the PSLP would not ensure a five-year housing land at all points in the plan period (particularly in the early years).
6
Rather than rectify this defect such that the Local Plan is capable of being found sound, the AFC merely exacerbates this flaw.
Reliance on Dunton Hills Garden Village
2.22 As noted early within this representation, the Local Plan is not simply required to provide a strategy for meeting development needs - the NPPF requires it to be sufficiently flexible to be able to respond to rapid change.
2.23 As such, it is critical that the Local Plan is not overly reliant on a limited number of sites.
2.24 However, the PSLP placed great reliance on Dunton Hills Garden Village to meet development needs.
2.25 Rather than address this concern, the AFC has simply placed even greater reliance on Dunton Hills Garden Village to meet the Borough's needs.
2.26 Such reliance on a single scheme is neither effective nor consistent with national policy.
Specialist accommodation for an ageing population
2.27 Proposed allocation R19 is one of the sites the Council has revised down the projected capacity of. In the case of R19, down from 75 to 45 dwellings. The AFC states that the reasons for the reduction in projected contribution from this site include inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitat impacts; and flooding.
2.28 The PSLP also suggested that there was "potential" for proposed allocation to accommodate a care home of around 40 beds. As noted in our PSLP representations, the PSLP provides little confidence there is reasonable prospect of a care home being delivered through development of this site.
2.29 In light of the additional concerns now set out in the AFC, prospects of provision of specialist accommodation to meet the needs of older people are further diminished.
7
Overview
2.30 The Council acknowledges four proposed sites may not be able to suitably accommodate the numbers previously cited in the PSLP. As such, the Local Plan housing trajectory must be amended to reflect these doubts, and suitable contingency measures should be put in place. Such measures are necessary irrespective of whether or not the policies relating to these four proposed allocations are modified to refer to the quantum of development the Council now consider the sites suitable to accommodate.
2.31 The modifications proposed by the AFC fail to ensure the Local Plan is capable of being found sound. The modifications place further reliance on one site (Dunton Hills Garden Community) to meet development needs, and further reduce the ability of the Local Plan to be able to respond to changing circumstances.
2.32 There is no justification for the suggestion that the delivery rate of Dunton Hills Garden Village can be increased for the three years the AFC suggests, and the number of new homes delivered through this site through the plan period increased. The assumed delivery rate prior to the AFC was already ambitious. In addition, the projected first year for completions is looking increasingly unrealistic given the delays to the Local Plan.
2.33 The AFC acknowledges that fewer dwellings will be delivered by the PSLP in the early years of the plan period, but the proposed increase to compensate for this is not until the end of the plan period, leaving a shortfall in the short term.
2.34 The AFC does not address the potential implications for the provision of accommodation for older people in light of the concerns it has identified in respect of proposed allocation R19. It neither explains why the site's potential to accommodate a care home is unaffected by the concerns it identifies, nor propose anything to address potential shortfall of this form of specialist accommodation assuming its potential to be provided here is affected.
2.35 The AFC not only fails to ensure the Local Plan is sound, but it actually exacerbates problems that were present in the PSLP.
8
2.36 We consider the issues acknowledged within the AFC can be addressed and the PSLP can be made capable of being found sound. We set out the suggested approach to achieving this within Section 4 of this representation.
3.0 Other soundness concerns resulting from delays to the Local Plan
3.1 As we noted in our PSLP representations (paragraph 12) the NPPF requires strategic policies to look ahead over a minimum of 15 years from the date of adoption. Within the same paragraph we noted that even assuming (optimistically) adoption of the Local Plan in 2019, the PSLP would only cover a 14-year period and as such does not conform to national policy.
3.2 It is now clear that the Local Plan will not be adopted in 2019. Adoption before the end of 2020 is considered optimistic. Before the end of 2021 is more realistic. As such, the Local Plan's strategic policies would - as currently proposed - only last for 13 years at best; more likely, they would cover a 12-year period from adoption.
3.3 This is evidently contrary to the NPPF's requirement to cover a minimum of 15 years.
4.0 Curing defects
4.1 In order to address the issues set out within this representation, it is necessary to ensure the Local Plan compensates for the reduction of 70 dwellings to be delivered in the early years of the plan period resulting from the revised capacity assessment of four proposed allocations in an effective and justified manner, and one which ensures the Local Plan is consistent with national policy and positively prepared. In this instance, this necessitates identifying additional allocation(s) which:
a) Together, in total, will deliver at least 70 additional homes; and
b) Can deliver this number of homes in the early years of the plan period (2022/23 - 2024/25).
4.2 Furthermore, additional allocations should also include those which will contribute towards meeting the accommodation needs of older people, given that the Council has identified concerns relating to a proposed allocation in which the PSLP states there is potential for a care home.
9
4.3 As a site capable of delivering approximately 60 homes along with extra care accommodation (Use Class C2), allocation of site 219 (land at Rayleigh Road, Hutton) represents an ideal site to respond to the above.
4.4 As set out within our representations on the Local Plan, the Council already has sufficient evidence to demonstrate site 219 is suitable, available, and achievable for residential development along with extra care accommodation; can be delivered in the short term; and that its allocation would be justified, effective, consistent with national policy, and contribute towards ensuring the Local Plan is positively prepared.
4.5 In addition, and separately, it is imperative to amend the PSLP to ensure the Local Plan will contain strategic policies which cover at least 15 years. As such, the plan period should be extended to 2036 and modifications proposed to ensure development needs for this period are addressed.
4.6 For the avoidance of doubt, the above actions are considered necessary in relation to the matters addressed by the AFC. We have identified separate and additional concerns (along with suggested actions to cure such defects) in respect of the soundness of the PSLP as a whole within our previous representations made at the appropriate time. These concerns remain.

Support

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

Representation ID: 26787

Received: 25/11/2019

Respondent: Historic England

Representation:

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

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: 26805

Received: 26/11/2019

Respondent: mr simon Fleming

Legally compliant? No

Sound? No

Duty to co-operate? Not specified

Representation:

The reason for the change to Policy R19 is purely due to representations from local residents and political pressure. The relevance of these concerns when considering site 178 in isolation have already been disputed. Based on the evidence on air quality, biodiversity, climate change mitigation, Ccmmunity and well-being, economy and employment, heritage, flooding, housing, landscape, waste, water the R19 change is not justified. This latest reduction from 75 to 45 could adversely affect the scheme viability.

Change suggested by respondent:

The reasonable strategy would be to remain at 75 houses for site R19.

Full text:

Brentwood Borough Council have proposed a number of focussed changes to the Pre-Submission Local Plan.
My representations relate primarily to Focussed Change 3 [Policy R19 (Land at Priest's Lane, Shenfield): Reduction from "around 75" to "around 45" homes] and the effect on the proposed Dunton Hills Garden Village (DHGV).
My representations consider whether the Change meets the Test of Soundness as set out in paragraph 35 of the National Planning Policy Framework.
Policy R19 covers an area of urban open space in Shenfield. This comprises two independent sites, the 4.5 Ha Ursuline School Playing fields (HELAA ref 044) and my 0.6 Ha Land off Bishop Walk (HELAA ref 178). Although these two sites have different use histories and planning attributes (site 178 is a disused private stables and paddock), the Council have set policy R19 to cover both together (please refer to my previous representations objecting to this approach).
The reason for the change to Policy R19 is purely due to representations from local residents concerning development on R19 and another nearby site. The Addendum document paragraph 1.3 explains that the key concerns included:
"inconsistency with the character of the local area in regard to density; implications of increased traffic and associated safety; highway access; development on urban open space; environmental and habitat impacts; and flooding."
The relevance of these concerns when considering site 178 in isolation have already been disputed.
However, in response to the representations, the Focussed Changes seek to remove 50 houses from the locality (30 of which from R19) and re-allocate them to the proposed DHGV development. This is despite the negative impacts identified by Aecom in their October 2019 Sustainability Appraisal.
2
Aecom's Sustainability Appraisal (SA) of the Brentwood Local Plan, with Addendum, dated October 2019:
Aecom have appraised the Focussed Changes with respect to twelve sustainability topics. It is important to highlight their findings as they relate to R19, and more particularly site ref 178.
Air quality: Site R19 is in close proximity to the town centre Air Quality Management Area (AQMA). The proposed reduction in housing numbers in the locality is 50 (30 reduction from R19). Aecom say that any reduction in pollution from omitting 50 houses would be "marginal", and so the opposite must also be true, that retaining 50 houses would also be "marginal".
Consequently the effect of adding or omitting just 30 houses on R19 will be less than "marginal" and for the smaller number of houses proposed on site 178 alone there would be virtually no effect at all.
Furthermore, Aecom also point out that as R19 is close to the town centre and schools (1km to the town centre and 2km to Brentwood Station), there will be a high incidence of walking, cycling and use of public transport, which will reduce the number of private car journeys. This is all to be encouraged for sustainability. Cars also have an alternative route to avoid the AQMA, and so the impact is reduced still further.
More significant is the adverse effect of reallocating the houses to DHGV and in paragraph 2.2.10 of the Aecom Addendum a red warning flag is raised: " ...in the light of the new evidence available which serves to highlight an air quality issue associated with the A127 corridor that might be said to be of national significance (on the basis that National Government is seeking to intervene). In the light of this new evidence there is an increased degree of concern associated with DHGV, from an air quality perspective and this is compounded, albeit marginally, by the Focussed Changes."
Overall, Aecom concluded that there are "uncertain negative effects" of reducing the housing numbers and diverting them to DHGV. Consequently, based on the air quality expert evidence, the R19 change is not justified.
Biodiversity: Aecom concluded that the effect of reducing the number of houses in the locality was "not likely to be significant". So given that adding or omitting 50 houses (30 on site R19) is not considered to be significant, the R19 change is not justified.
Climate Change Mitigation: No effect
Community and well-being: Paragraph 2.5.2 states that the primary concerns of local residents were the residential character and road access.
Site 178 already has a road access off Priest's Lane and so residents' concerns relate entirely to the Ursuline's School Playing Fields site 044, which does require a new road access and highways improvements.
Concerning residential character, there is already a conflict between the low density of the older houses in the area and the density ordinarily required by the planners in new developments. For example, Bishop Walk (the road off Priest's Lane from which site 178 is accessed) was built out twenty years ago at 15 dwellings per hectare, yet the current local plan requires double this density. This would not reflect the local character.
Following pressure from local residents, the numbers of houses included in the plan for R19 had already been reduced from 130 to 75, matching the 15 dwellings per hectare in Bishop Walk. Further pressure has now resulted in this focussed change to R19 to cut the numbers to 45 dwellings, which
3
is just 9 dwellings per hectare. This density is not consistent with National Policy to maximise the land use, does not represent sustainable development and no longer reflects the density in Bishop Walk.
Aecom have also expressed their concern that cutting the numbers in this way could adversely affect the scheme viability. I agree. The scheme will still require expensive road layouts, suds drainage schemes, services infrastructure, other site costs, management on-costs, fees and CIL etc and these are having to be spread over fewer and fewer houses.
The cut in numbers then conflicts with and jeopardises other policies in R19 looking to increase the supply of smaller units and discounted affordable units as the costs cannot reasonably be borne by the reduced scheme finances. As a solution, there needs to be some flexibility in these policies bearing in mind that the local character along Priest's Lane and Bishop Walk is for large high value houses, which is probably what the local residents are looking to replicate, whilst there is no local character to replicate for land along the Southernmost margins. With cheaper land values along these railway margins, this is logically where any subsidised housing units could be located.
It is noted that Aecom concluded that the Focussed Changes have a positive effect in respect of Community Objectives solely in recognition that the changes were in response to local pressure. Otherwise, the omission [or retention] of 30 units was said to be of "limited significance".
Economy and employment: No effect.
Heritage: No effect
Flooding: Despite concerns from residents about flooding (noted in paragraph 1.3 of the Focussed Changes document), Aecom confirmed site R19 is not subject to fluvial flood risk and the Environment Agency raised no objection to development.
Housing: Aecom were highly critical of the proposed change to shift the balance of housing away from the Brentwood/Shenfield urban area, where housing needs are highest, and instead concentrate housing at a single large site (DHGV), where there was an increased risk in terms of delivery. They also noted that the Local Housing Needs figure had also increased from 350 dwellings per annum on January 2019 to currently 454, effectively matching the proposed housing supply and wiping out the previous buffer of over-supply. Consequently delivery at DHGV is increasingly critical and increasingly risky. The expert assessment from Aecom was that the changes had "uncertain negative implications" and so the R19 change is not justified.
Landscape: Aecom reported that decreasing the number of homes on R19 and moving them to Green Belt land at DHGV only added to the Significant negative effects of developing on the Green Belt at DHGV. Consequently, the R19 change is not justified.
Soils: No effect
Waste: No effect
Water quality and water resources: No effect
4
Conclusion
I maintain that the proposed reduction in housing numbers at R19 is not justified as it is not "an appropriate strategy, taking into account the reasonable alternatives and based upon proportionate evidence." [NPPF para 35.b].
The original housing numbers considered reasonable by the planners were three times the 45 houses now proposed in the Focussed Change. This latest reduction from 75 to 45 has once again come about purely as a result of representations from local residents and political pressure. I have written previously explaining that most of the concerns relate to issues on the adjoining site, not site 178, and my representations remain on file for the inspector.
Turning to Aecom's updated Sustainability Appraisal, this provides an expert opinion on the Focussed Changes with respect to R19 and I put this forward as evidence to assess the soundness of the policies, with particular reference to site 178.
The only positive effect of the Focussed Change was with regard to Community objectives, because the Change was a response to local pressure. However this was only described as being of "limited significance".
All other significant effects of the Focussed Change were negative.
 Site 178 does not have an air quality issue. However, moving more houses to DHGV would have "an uncertain negative effect"on air quality at the already problematic A127.
 On Communities and wellbeing, there is a conflict in policies between maximising the density to achieve best value from the land, and the proposed reduction in numbers. As Aecom point out, this is now at a level when the scheme viability is called into question, and other policies in R19 for social housing, for example, are brought into conflict. This all looks like a political decision that has not been properly thought through.
 Aecom were highly critical of moving the housing away from the urban areas where they were most in demand. Also, locating them at DHGV was a risky option in terms of delivery within the plan period. The recent rise in the Housing Needs numbers has also wiped out any contingency within the supply, and so the risk of failing to meet the targets has increased
 Moving houses from R19 to DHGV increased the already significant negative effect on landscape as this involves building on the Green Belt.
Taking account of all the negative indications in Aecom's report, the conclusion is that adopting the Focussed Change at R19 would not be an appropriate strategy and the reasonable strategy would be to remain at 75 houses. The policy is not sound.

Object

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

Representation ID: 26806

Received: 26/11/2019

Respondent: Glenda Fleming

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation:

The proposal to reduce the numbers further to 45 has arisen solely because of concerns from the public. There is no evidence that this reduction in numbers on site R19 has any technical basis the alternative proposed by this Focussed Change is to move most of the development down to Dunton which is not as sustainable development. Reducing the numbers of houses at R19 could adversely affect the viability of the development. Reducing the density of development is not making best use of a valuable resource. The Focussed Change at R19 is unsound.

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: 26862

Received: 26/11/2019

Respondent: Mrs Christina Atkins

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

Site received 11% of total Reg 19 responses. 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 (e.g. Policies R25 and R26) and therefore should be built on before remote locations.

Change suggested by respondent:

This site is more suitable for residential development than more remote locations (e.g. Policies R25 and R26) and therefore should be built on before remote locations.

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: 26893

Received: 29/11/2019

Respondent: L Apostolides

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

Q: 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.

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: 26898

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 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.

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,
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: 26906

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 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.
No point building houses in a rural area where there is no infrastructure as it makes living more difficult to reach services.

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: 26911

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 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. 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.

Change suggested by respondent:

Remove R25 and 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,
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: 26916

Received: 26/11/2019

Respondent: Ms Lynn Baggott

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

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

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: 26921

Received: 26/11/2019

Respondent: Mr David Hall

Representation:

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.

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.

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: 26926

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 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.

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: 26931

Received: 29/11/2019

Respondent: Mrs Gillian Hall

Representation:

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.

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
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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: 26934

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 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.

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: 26942

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 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.

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: 26947

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 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

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: 26951

Received: 26/11/2019

Respondent: Mr Kevin Hall

Representation:

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.

Change suggested by respondent:

Remove site R25 &26

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
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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

Support

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

Representation ID: 26956

Received: 26/11/2019

Respondent: Mr. Chris Hamilton

Representation:

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.

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
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LLaasstt Mooddiiffiieedd:: SSuunnddaayy,, Noovveembbeerr 1177,, 22001199 11::2200::2233 PPM
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: 26961

Received: 26/11/2019

Respondent: Mrs Mandy Hamilton

Representation:

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.

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: 26966

Received: 26/11/2019

Respondent: Mr Jack Stevens

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

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.

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: 26971

Received: 26/11/2019

Respondent: Mr Ronald Quested

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation:

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.

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: 26974

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 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.

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