This local plan will only be sound if the vital points as set out in question 5 are adhered to: no building on Green Belt, keep Blackmore a village not an attempt to make it into a mini-town. Also need to consider how it will affect the local water supply, etc, etc,etc. The vital points must be listened to - GREEN BELT, SCHOOL, GP SURGERY, PARKING, HEAVIER TRAFFIC, WATER SUPPLY, FLOODING.

Addendum is unsound as main issues of development are ignored. Outrageous to build on Green Belt; extra pressure on traffic is not being addressed with two more cars per property resulting in mayhem, parking already impossible and is a danger for parents and children, and pavements being used for parking by all vehicles, so we need to walk in the road. The school is oversubscribed, resulting in car use to transport children elsewhere. Medical centre is overflowing and can't keep up with existing demand, more residents will exacerbate this. Should listen to our concerns, planners are ignoring the urgent issues. Unfair on village and other brownfield sites should be used.
This local plan will only be sound if the vital points as set out in question 5 are adhered to: no building on Green Belt, keep Blackmore a village not an attempt to make it into a mini-town. Also need to consider how it will affect the local water supply, etc, etc,etc. The vital points must be listened to - GREEN BELT, SCHOOL, GP SURGERY, PARKING, HEAVIER TRAFFIC, WATER SUPPLY, FLOODING.

A much better solution would be to reprovide the units lost from the Shenfield and Blackmore allocations on sustainable sites in and around Brentwood. The site at Spital Lane is an ideal candidate, being located on the edge of the town close to services and facilities, having minimal impact on the openness of the Green Belt, and as per the Environment Agency comments on the most recent planning application, being capable of accommodating six houses without any risk of flooding. We therefore advocate that Spital Lane be allocated for housing in the emerging plan, along with other suitable smaller sites identified in the SHLAA, to make up the housing numbers lost in Shenfield and Blackmore.

The proposed reduction in housing numbers in Shenfield and Blackmore is problematical for two reasons.
First, because it reduces housing numbers in sustainable settlements where growth is needed, and puts them in a less sustainable location.
Second, because in relocating the units to the proposed strategic allocation at Dunton Hills, the provision of these units will inevitably occur later in the plan period, when the focus should be on early provision to address the current housing land supply shortfall.
A much better solution would be to reprovide the units lost from the Shenfield and Blackmore allocations on sustainable sites in and around Brentwood.
The site at Spital Lane is an ideal candidate, being located on the edge of the town close to services and facilities, having minimal impact on the openness of the Green Belt, and as per the Environment Agency comments on the most recent planning application, being capable of accommodating six houses without any risk of flooding.
We therefore advocate that Spital Lane be allocated for housing in the emerging plan, along with other suitable smaller sites identified in the SHLAA, to make up the housing numbers lost in Shenfield and Blackmore.

This site should be removed from the LDP and the village plan implemented which makes use of available brownfield sites and meets village requirements not those of developers. Brownfield sites already offered should be used and more investigation into including other brownfield opportunities undertaken (e.g.Stondon Massey where development is actively encouraged).

The addition of housing on this scale will increase the population, overcrowding, congestion and traffic hazards putting a strain on infrastructure which has remained unchanged for many years. New housing developments are surrounding Blackmore which have not been included in the LDP. This site is greenbelt and should be excluded as there are brownfield sites available. The area is subject to serious flooding and access is narrow and dangerous. There would also be adverse affects to the natural environment and nature of the village. Purely developer-led, this site was excluded from the LDP in 2016 and should be excluded again.

Greenfield site object to any development.

Site should be removed from LDP totally.

See above. Investigate building in Stondon Massey which welcomes more housing and has space. Put in new housing in Blackmore that utilises Brownfield sites and has far less impact on the environment and infrastructure which is already under enormous strain-try getting an appointment at the doctor's surgery!

It fails to take into account the number of dwellings being built outside BBC domain which will impact heavily on the village-65 in all that when added to the proposed total of 50 will effect infrastructure including schools and doctors surgery,flooding, parking, congestion. This reveals the woeful lack of investment in the area beforehand to improve such matters. Re-opening this LDP allows other sites to be investigated like Stondon Massey where there is a welcome need for housing as well as prefered Brownfield sites in Blackmore which could lead to the building of 26 more houses in a controlled manner.

The 2 sites in Shenfield which have good public transport & infrastructure could take these homes

Greenbelt these should be reduced to zero

I sent in my concerns with regards to the new housing development in February of
this year. My views on the revised LDP have not changed and I feel that any new
development to the two sites will alter the landscape, add extra vehicles to the village which will cause major disruption within the village and to the one shop that we have.
I moved to Blackmore 4 years ago, it took my husband and I two years to find where we wanted to spend our retirement and in the plans it clearly stated that there would be no building on the fields surrounding Woollard Way which is why we decided to buy and I now feel this is a contradiction and we should have been informed of any future developments that have been put in place.
We also like the quietness of the village and personally we paid for this benefit which
if the housing sites go ahead is not only disrupting our lives as others within the
village but also village way of life which is what we so wanted. English heritage
should be a major factor and development on villages that need building up.
I would appreciate if you can again take my views into consideration.

Removal of the site from the LDP and move the homes into the Shenfield or Dunston site or even take into consideration the new dwellings proposed along Red Rose Farm ( brown field site ) that no-one has objected to.

This site has recieved a reduction of 10 dwellings but Shenfield has only had a reduction of 30 dwellings. The shenfield site is already well supported by schools, shops and a good road structure with infrastructure put in place for a residential area. R25 is green belt land that has a narrow single lane available to support it, which is subject to flooding

R25 has to be removed from the LDP as it is not suitable.

The provision for 30 new homes on R25 is ridiculous. The site is green belt land and should only be used after more suitable sites have been exhausted.
The local services including the village school is at full capacity along with the doctor's surgery which has a 3 week wait for appointments.
There is currently 66 new homes already being built or in advanced stages of planning in and around the surrounding area which are not considered in the LDP. All of these new homes will use Blackmore as a hub and therefore the already stretched services.
The only access to the site is via Redrose Lane which is an extremely narrow country lane with no footpath, hedges on either side and is prone to flooding. This road is not suitable for the increased traffic the development will cause.

We note that it is proposed to decrease the amount of housing on this allocation site to address comments made as part of the previous consultation. As an infrastructure provider we closely monitor housing growth in our region to align our planned investment with additional demand for water recycling infrastructure. Therefore we have no comments to make relating to the focused change to Policy R25.

Dear Sirs,

I have previously commented on the proposed plans for sites labelled as R25 and R26 (Woollard Way and Orchard Piece) of the LDP. I re-iterate my views previously posted to yourselves in this regard. Furthermore, the recent flooding to the north of England and particularly Fishlake, only go to demonstrate the danger of flooding to areas that have a history in this regard. Blackmore is one of these areas and this increased risk and the other concerns previously I have expressed remain.

I therefore object to the current proposals.

Regards

Removal from the LDP

There is no proven need for a development of this size in Blackmore. By even reducing numbers you admit that the original proposal was flawed

The Plan, as amended by the focussed changes, is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified and their inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.
Brentwood Borough Council should amend the plan to retain R25 and R26 as Green
Belt and not allocate these sites for housing.

BRENTWOOD LOCAL PLAN
REGULATION 19 ("FOCUSSED CHANGES")
CONSULTATION RESPONSE
ON BEHALF OF
BLACKMORE, HOOK END & WYATTS GREEN PARISH COUNCIL
BLACKMORE VILLAGE HERITAGE ASSOCIATION
1. This joint representation is made on behalf of:
1.1. The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2. The Blackmore Village Heritage Association ('BVHA')
Introduction
2. This representation supplements, but does not replace, the previous joint
representation made by the Parish Council and BVHA dated 18 March 2019 - a copy
of which is attached for ease of reference.
3. The contents of the 18 March 2019 representation will not be repeated but the Parish
Council and BVHA maintain and rely upon their previous representation(s).
4. The Parish Council and BVHA wish to make further representations following the
publication of Brentwood Borough Council's ('BBC') Focussed Changes to the Pre-
Submission Local Plan (Regulation 19) dated October 2019.
Context
5. Both the Parish Council and BVHA remain strongly opposed to the proposed
allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land
north of Orchard Piece, Blackmore) for housing development. The proposed
allocations, following the "focussed changes", are for "around 30 new homes" at R25
and for "around 20 new homes" at R26.
6. The Parish Council and BVHA say that BBC can meet its Local Housing Need ('LHN')
on preferable sites to R25 and R26. Further, the Parish Council and BVHA say that
the LHN can be met without sites R25 and R26 at all.
Dunton Hills Garden Village (Site R01)
7. The Dunton Hills Garden Village is BBC's key strategic allocation. The Parish Council
and BVHA acknowledge that the site is well located and is to be designed in such a
way so to maintain characteristics of Green Belt openness.
8. The focussed changes seek to re-schedule the delivery of housing; previously 2,700
in the plan period but now 2,770 (i.e. an additional 70). There is no change to the
approximate total yield which remains at 4,000. Therefore, all BBC have done is
brought forward the number of housing to be delivered from the Dunton Hills Garden
Village site. That dwelling yield is, by reference to net developable area (and not
gross area), at a density of 31.1 dwellings per hectare.
9. BBC have not considered the impact of increasing densities on the Dunton Hills
Garden Village site. The most modest of increases to densities will, by virtue of the
size of the site, result in a not insignificant increase in dwelling yield. For example, an
increase of just 0.9 dwellings per hectare results in an indicative dwelling yield of
4,112 - or an additional 112 dwellings. An increase in the order of 112 dwellings
would negate the need for development in less sustainable locations, such as sites
R25 and R26.
10. The NPPF encourages making effective use of land (Chapter 11) and achieving
appropriate densities (paragraphs 122 and 123 NPPF). Figure 6.1. indicates that the
greatest need is for two-bedroom units with nearly 40% of the need for one- and
two-bedroom units. Clearly, higher densities can be achieved where there is a predominance
of smaller dwellings.
The more sustainable Shenfield Sites (R18 and R19)
11. The focussed changes reduce the proposed allocation on sites R18 and R19 to 35 and
45 dwellings respectively. The reduced allocations being 20 and 30 homes
respectively. Thus, the focussed changes reduce the allocation on sites R18 and R19
by 50 dwellings in total.
12. The focussed changes seek a total allocation of 50 on sites R25 and R26 (n.b. 30 and
20 dwellings respectively).
13. It therefore follows that if the allocation for R18 and R19 were unmoved/unchanged
then there would be no need for the Blackmore sites (i.e. R25 and R26).
14. Indeed, there are good reasons not to reduce the allocations on R18 and R19 but
instead, particularly with increased densities on the Dunton Hills Garden Village site
in the Plan period, simply remove sites R25 and R26 from the Plan.
15. It is undoubtedly the case that sites R18 and R19 are in more sustainable locations.
Which is evidenced by:
15.1. Shenfield being designated as "Settlement Category 1" - whereas
Blackmore (currently) designated as "Settlement Category 3". Please note that
the Parish Council and the BVHA repeat previous representations as why they
believe that Blackmore is more properly "Settlement Category 4".
15.2. Blackmore benefits from two bus routes/services (nos 31 and 61) whereas
Shenfield numerous; up to 14 services. More specifically, both Shenfield sites are
within walking distance of bus stops benefitting from connections to 7 or more
services. Furthermore, Shenfield benefits from a main line train station with
excellent connections to London, East Anglia and beyond.
15.3. Shopping and Leisure facilities in Blackmore are extremely limited and
residents undoubtedly rely on private-motor car to meet their
requirements/needs. Shenfield however benefits from a large range of shops and
leisure facilities and so no need to rely upon private motor-car.
15.4. The Sustainability Appraisal (October 2019) evidences that the Shenfield
sites (R18 and R19) clearly outperform the Blackmore sites (R25 and R25) as
follows:
15.4.1. R18 - (site ref 186) of the 17 categories against which a site is
judged, this site performs "poorly" against 7 of the criteria but with "no
issues" in respect of the remaining 10 criteria;
15.4.2. R19 (site ref 044) scores "poorly" against 7 criteria, "well" in one
criterion and with "no issues" in respect of the remaining 9 criteria;
15.4.3. R25 (site ref 077) scores "particularly poorly" in 3 criteria, "poorly"
in 3 criteria, "well" in 1 criterion but with "no issues" in respect of the
remaining 10 criteria. Of the latter, this includes flooding which, for reasons
previously given, the Parish Council and the BVHA say that the site does
have an issue with flooding and, at its highest, performs "poorly".
15.4.4. R26 (site 076) scores "particularly poorly" in 2 criteria, "poorly" in 4
criteria, "well" in 1 criterion but with "no issues" in respect of the remaining
10 criteria. Again, the Parish Council and BVHA say that there is an issue
with flooding, or the potential risk of flooding on site R26.
16. Thus, the Shenfield sites are superior and should be allocated for development
before, and in preference to, the Blackmore sites.
17. The proposed allocation for sites R18 and R19 should revert to the pre-focussed
changes allocation, i.e. an additional 50 dwellings, which would entirely negate the
need to allocate sites R25 and R26.
Other Comments re the Shenfield sites
18. In a similar vein to the above, increasing densities on the Shenfield sites (R18 and
R19) would likely negate the need for the Blackmore sites in the current Plan period.
By reference to net developable area the proposed densities are 25.2 dwellings per
hectare on site R18 but only 11.7 dwellings per hectare on site R19. Pre-focussed
changes these were 39.6 and 19.5 dwellings per hectare for sites R18 and R19
respectively.
19. By comparison, densities for sites R25 and R26 - post focussed changes - are at
12.1dpa and 30.4dpa respectively.
20. Paragraph 122 NPPF sets out that the desirability of maintaining an area's prevailing
character could be taken into account. One would ordinarily expect the Blackmore
sites, being in a village setting, to have a lower housing density than those in more
urban areas (i.e. the Shenfield sites). This is not the case; R26 is proposed at a
higher density than both R18 and R19. In addition, R25 is proposed at a higher
density than R19. There is no clear explanation for this.
21. It is entirely unclear why the proposed density on site R19 is so low, especially given
its location and it being surrounded on its north, east and western sides by existing
residential dwellings at a greater density than the proposed allocation.
22. In short, site R18 could take a higher density than 25.2dpa; site R19 definitely can
take a higher density of housing (than 11.7dpa) and should do.
23. Further, the inclusion of sites R18 and R19 will not result in unacceptable coalescence
with existing settlements nor would it lead to erosion of the Green Belt. Both R18 and
R19 are constrained by existing built-form development and, in the case of site R19,
further constrained by a railway line. Thus, development on either may not properly
be viewed as the "thin edge of the wedge".
Development in Blackmore
24.Removing sites R25 and R26 does not prevent development in Blackmore but it is
acknowledged that their removal would make development in Blackmore less likely
and limited to "windfall" sites.
25. As Blackmore sits within the Green Belt, the NPPF, and indeed emerging policy NE10,
does permit new development in the Green Belt subject to set criteria being met.
26. Indeed, there are sites in Blackmore that have recently been permitted
notwithstanding the lack of a formal designation/allocation. Likewise, it is entirely
probable that additional development will come forward/take place in Blackmore.
27. With the above point in mind, the Parish Council and BVHA "point to" the site known
as Red Rose Farm. That site is "previously developed land" within the NPPF
definition; a fact confirmed by a Lawful Development Certificate that has been issued
by BBC (ref: 19/00243/s191) - a copy of which is appended for reference. Further,
the Red Rose Farm site is currently the subject of a pending application for the
erection of 12 dwellings (to include 4 affordable dwellings)(ref: 19/01013/FUL).
28. If the pending Red Rose Farm application is successful, as would appear likely as the
Parish Council and BVHA understand that there is a recommendation for approval
subject to completion of a s106 agreement, then a contribution to housing supply will
be made in the village of Blackmore.
29. Further, if the unallocated Red Rose Farm site is granted permission then it is entirely
foreseeable that such would have an impact on the timing of delivery of any
additional dwellings in Blackmore; including sites R25 and R26 if allocated.
30. But the Red Rose Farm site very much illustrates the Parish Council and BVHA's case
that there are other sites which are far more preferable for development than the
"virgin" Green Belt land that is sites R25 and R26.
31. Thus, sites R25 and R26 should be removed.
Development adjacent to Blackmore but in Epping Forest District Council
32. There have been recent planning permissions, but also applications awaiting
determination, for residential development within Epping Forest District Council that
are "on the doorstep" of Blackmore. Examples being 35 units at the Norton Heath
Riding Centre (references EPF/1402/19 and EPF/0396/19) and 5 units at Ashlings
Farm (references EPF/0834/19 and EPF/1859/19). No doubt other examples could be
given.
33. Such developments "just on the border" of Epping Forest will undoubtedly rely upon
Blackmore to meet their needs. Indeed, Blackmore is the nearest primary school to
these Epping sites. Both the Parish Council and BVHA say that Blackmore cannot
support these developments on the border of Epping Forest in addition to the
proposed development at sites R25 and R26.
34. The Parish Council and BVHA further say that any applicable planning
obligation/infrastructure payment from these Epping sites will not be invested into
Blackmore; thus Blackmore takes the strain with none of the benefit.
35. Moreover, the existence of the Epping Forest permissions/applications does not
appear to have been taken into account by BBC in considering the sustainability of
sites R25 and R26.
36. The Parish Council and BVHA therefore say that the case for the inclusion of R25 and
R26 is undermined in turn.
Summary/Conclusion
37. The Parish Council and BVHA recognise that proposed allocation on sites R25 and
R26 has been reduced following "focussed changes". However, both the Parish
Council and BVHA maintain that the LHN can be met on more suitable and/or
sustainable sites elsewhere in the Borough.
38.BBC have not considered increasing housing density on the Dunton Hills Garden
Village site. A modest increase in density may negate the need for both the Shenfield
(R18 and R19) and Blackmore (R25 and R26) sites.
39. The Shenfield sites are clearly in more sustainable locations (as confirmed by the
Sustainability Appraisal scores) but are surrounded by built form development but
also transport links/infrastructure. Thus, the inclusion of sites R18 and R19 will not
lead to coalescence nor erode the countryside/Green Belt. Sites R18 and R19 should
be allocated in preference to the Blackmore sites (R25 and R26).
40. There is no need for the Blackmore sites if the allocation on the Shenfield sites is
reinstated. Namely, the 50 dwellings removed from sites R18 and R19 would, if
reinstated, entirely negate the need to allocate sites R25 and R26. Moreover, there is
no evidence that BBC have considered increasing housing density on sites R18 and
R19; both of which could take a higher housing density but particularly the latter.
41. In light of the above, the Plan, as amended by the focussed changes, is not sound
with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be
justified and their inclusion of these sites is contrary to national policy, particularly
with regards to sustainable development and Green Belt land policies within the
NPPF.
42. Brentwood Borough Council should amend the plan to retain R25 and R26 as Green
Belt and not allocate these sites for housing.
HOLMES & HILLS LLP
Dated 20 November 2019

The Plan, as amended by the focussed changes, is not sound with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be justified and their inclusion of these sites is contrary to national policy, particularly with regards to sustainable development and Green Belt land policies within the NPPF.
Brentwood Borough Council should amend the plan to retain R25 and R26 as Green
Belt and not allocate these sites for housing.

BRENTWOOD LOCAL PLAN
REGULATION 19 ("FOCUSSED CHANGES")
CONSULTATION RESPONSE
ON BEHALF OF
BLACKMORE, HOOK END & WYATTS GREEN PARISH COUNCIL
BLACKMORE VILLAGE HERITAGE ASSOCIATION
1. This joint representation is made on behalf of:
1.1. The Blackmore, Hook End and Wyatts Green Parish Council ('the Parish Council');
and
1.2. The Blackmore Village Heritage Association ('BVHA')
Introduction
2. This representation supplements, but does not replace, the previous joint
representation made by the Parish Council and BVHA dated 18 March 2019 - a copy
of which is attached for ease of reference.
3. The contents of the 18 March 2019 representation will not be repeated but the Parish
Council and BVHA maintain and rely upon their previous representation(s).
4. The Parish Council and BVHA wish to make further representations following the
publication of Brentwood Borough Council's ('BBC') Focussed Changes to the Pre-
Submission Local Plan (Regulation 19) dated October 2019.
Context
5. Both the Parish Council and BVHA remain strongly opposed to the proposed
allocation of Sites R25 (Land north of Woollard Way, Blackmore) and R26 (Land
north of Orchard Piece, Blackmore) for housing development. The proposed
allocations, following the "focussed changes", are for "around 30 new homes" at R25
and for "around 20 new homes" at R26.
6. The Parish Council and BVHA say that BBC can meet its Local Housing Need ('LHN')
on preferable sites to R25 and R26. Further, the Parish Council and BVHA say that
the LHN can be met without sites R25 and R26 at all.
Dunton Hills Garden Village (Site R01)
7. The Dunton Hills Garden Village is BBC's key strategic allocation. The Parish Council
and BVHA acknowledge that the site is well located and is to be designed in such a
way so to maintain characteristics of Green Belt openness.
8. The focussed changes seek to re-schedule the delivery of housing; previously 2,700
in the plan period but now 2,770 (i.e. an additional 70). There is no change to the
approximate total yield which remains at 4,000. Therefore, all BBC have done is
brought forward the number of housing to be delivered from the Dunton Hills Garden
Village site. That dwelling yield is, by reference to net developable area (and not
gross area), at a density of 31.1 dwellings per hectare.
9. BBC have not considered the impact of increasing densities on the Dunton Hills
Garden Village site. The most modest of increases to densities will, by virtue of the
size of the site, result in a not insignificant increase in dwelling yield. For example, an
increase of just 0.9 dwellings per hectare results in an indicative dwelling yield of
4,112 - or an additional 112 dwellings. An increase in the order of 112 dwellings
would negate the need for development in less sustainable locations, such as sites
R25 and R26.
10. The NPPF encourages making effective use of land (Chapter 11) and achieving
appropriate densities (paragraphs 122 and 123 NPPF). Figure 6.1. indicates that the
greatest need is for two-bedroom units with nearly 40% of the need for one- and
two-bedroom units. Clearly, higher densities can be achieved where there is a predominance
of smaller dwellings.
The more sustainable Shenfield Sites (R18 and R19)
11. The focussed changes reduce the proposed allocation on sites R18 and R19 to 35 and
45 dwellings respectively. The reduced allocations being 20 and 30 homes
respectively. Thus, the focussed changes reduce the allocation on sites R18 and R19
by 50 dwellings in total.
12. The focussed changes seek a total allocation of 50 on sites R25 and R26 (n.b. 30 and
20 dwellings respectively).
13. It therefore follows that if the allocation for R18 and R19 were unmoved/unchanged
then there would be no need for the Blackmore sites (i.e. R25 and R26).
14. Indeed, there are good reasons not to reduce the allocations on R18 and R19 but
instead, particularly with increased densities on the Dunton Hills Garden Village site
in the Plan period, simply remove sites R25 and R26 from the Plan.
15. It is undoubtedly the case that sites R18 and R19 are in more sustainable locations.
Which is evidenced by:
15.1. Shenfield being designated as "Settlement Category 1" - whereas
Blackmore (currently) designated as "Settlement Category 3". Please note that
the Parish Council and the BVHA repeat previous representations as why they
believe that Blackmore is more properly "Settlement Category 4".
15.2. Blackmore benefits from two bus routes/services (nos 31 and 61) whereas
Shenfield numerous; up to 14 services. More specifically, both Shenfield sites are
within walking distance of bus stops benefitting from connections to 7 or more
services. Furthermore, Shenfield benefits from a main line train station with
excellent connections to London, East Anglia and beyond.
15.3. Shopping and Leisure facilities in Blackmore are extremely limited and
residents undoubtedly rely on private-motor car to meet their
requirements/needs. Shenfield however benefits from a large range of shops and
leisure facilities and so no need to rely upon private motor-car.
15.4. The Sustainability Appraisal (October 2019) evidences that the Shenfield
sites (R18 and R19) clearly outperform the Blackmore sites (R25 and R25) as
follows:
15.4.1. R18 - (site ref 186) of the 17 categories against which a site is
judged, this site performs "poorly" against 7 of the criteria but with "no
issues" in respect of the remaining 10 criteria;
15.4.2. R19 (site ref 044) scores "poorly" against 7 criteria, "well" in one
criterion and with "no issues" in respect of the remaining 9 criteria;
15.4.3. R25 (site ref 077) scores "particularly poorly" in 3 criteria, "poorly"
in 3 criteria, "well" in 1 criterion but with "no issues" in respect of the
remaining 10 criteria. Of the latter, this includes flooding which, for reasons
previously given, the Parish Council and the BVHA say that the site does
have an issue with flooding and, at its highest, performs "poorly".
15.4.4. R26 (site 076) scores "particularly poorly" in 2 criteria, "poorly" in 4
criteria, "well" in 1 criterion but with "no issues" in respect of the remaining
10 criteria. Again, the Parish Council and BVHA say that there is an issue
with flooding, or the potential risk of flooding on site R26.
16. Thus, the Shenfield sites are superior and should be allocated for development
before, and in preference to, the Blackmore sites.
17. The proposed allocation for sites R18 and R19 should revert to the pre-focussed
changes allocation, i.e. an additional 50 dwellings, which would entirely negate the
need to allocate sites R25 and R26.
Other Comments re the Shenfield sites
18. In a similar vein to the above, increasing densities on the Shenfield sites (R18 and
R19) would likely negate the need for the Blackmore sites in the current Plan period.
By reference to net developable area the proposed densities are 25.2 dwellings per
hectare on site R18 but only 11.7 dwellings per hectare on site R19. Pre-focussed
changes these were 39.6 and 19.5 dwellings per hectare for sites R18 and R19
respectively.
19. By comparison, densities for sites R25 and R26 - post focussed changes - are at
12.1dpa and 30.4dpa respectively.
20. Paragraph 122 NPPF sets out that the desirability of maintaining an area's prevailing
character could be taken into account. One would ordinarily expect the Blackmore
sites, being in a village setting, to have a lower housing density than those in more
urban areas (i.e. the Shenfield sites). This is not the case; R26 is proposed at a
higher density than both R18 and R19. In addition, R25 is proposed at a higher
density than R19. There is no clear explanation for this.
21. It is entirely unclear why the proposed density on site R19 is so low, especially given
its location and it being surrounded on its north, east and western sides by existing
residential dwellings at a greater density than the proposed allocation.
22. In short, site R18 could take a higher density than 25.2dpa; site R19 definitely can
take a higher density of housing (than 11.7dpa) and should do.
23. Further, the inclusion of sites R18 and R19 will not result in unacceptable coalescence
with existing settlements nor would it lead to erosion of the Green Belt. Both R18 and
R19 are constrained by existing built-form development and, in the case of site R19,
further constrained by a railway line. Thus, development on either may not properly
be viewed as the "thin edge of the wedge".
Development in Blackmore
24.Removing sites R25 and R26 does not prevent development in Blackmore but it is
acknowledged that their removal would make development in Blackmore less likely
and limited to "windfall" sites.
25. As Blackmore sits within the Green Belt, the NPPF, and indeed emerging policy NE10,
does permit new development in the Green Belt subject to set criteria being met.
26. Indeed, there are sites in Blackmore that have recently been permitted
notwithstanding the lack of a formal designation/allocation. Likewise, it is entirely
probable that additional development will come forward/take place in Blackmore.
27. With the above point in mind, the Parish Council and BVHA "point to" the site known
as Red Rose Farm. That site is "previously developed land" within the NPPF
definition; a fact confirmed by a Lawful Development Certificate that has been issued
by BBC (ref: 19/00243/s191) - a copy of which is appended for reference. Further,
the Red Rose Farm site is currently the subject of a pending application for the
erection of 12 dwellings (to include 4 affordable dwellings)(ref: 19/01013/FUL).
28. If the pending Red Rose Farm application is successful, as would appear likely as the
Parish Council and BVHA understand that there is a recommendation for approval
subject to completion of a s106 agreement, then a contribution to housing supply will
be made in the village of Blackmore.
29. Further, if the unallocated Red Rose Farm site is granted permission then it is entirely
foreseeable that such would have an impact on the timing of delivery of any
additional dwellings in Blackmore; including sites R25 and R26 if allocated.
30. But the Red Rose Farm site very much illustrates the Parish Council and BVHA's case
that there are other sites which are far more preferable for development than the
"virgin" Green Belt land that is sites R25 and R26.
31. Thus, sites R25 and R26 should be removed.
Development adjacent to Blackmore but in Epping Forest District Council
32. There have been recent planning permissions, but also applications awaiting
determination, for residential development within Epping Forest District Council that
are "on the doorstep" of Blackmore. Examples being 35 units at the Norton Heath
Riding Centre (references EPF/1402/19 and EPF/0396/19) and 5 units at Ashlings
Farm (references EPF/0834/19 and EPF/1859/19). No doubt other examples could be
given.
33. Such developments "just on the border" of Epping Forest will undoubtedly rely upon
Blackmore to meet their needs. Indeed, Blackmore is the nearest primary school to
these Epping sites. Both the Parish Council and BVHA say that Blackmore cannot
support these developments on the border of Epping Forest in addition to the
proposed development at sites R25 and R26.
34. The Parish Council and BVHA further say that any applicable planning
obligation/infrastructure payment from these Epping sites will not be invested into
Blackmore; thus Blackmore takes the strain with none of the benefit.
35. Moreover, the existence of the Epping Forest permissions/applications does not
appear to have been taken into account by BBC in considering the sustainability of
sites R25 and R26.
36. The Parish Council and BVHA therefore say that the case for the inclusion of R25 and
R26 is undermined in turn.
Summary/Conclusion
37. The Parish Council and BVHA recognise that proposed allocation on sites R25 and
R26 has been reduced following "focussed changes". However, both the Parish
Council and BVHA maintain that the LHN can be met on more suitable and/or
sustainable sites elsewhere in the Borough.
38.BBC have not considered increasing housing density on the Dunton Hills Garden
Village site. A modest increase in density may negate the need for both the Shenfield
(R18 and R19) and Blackmore (R25 and R26) sites.
39. The Shenfield sites are clearly in more sustainable locations (as confirmed by the
Sustainability Appraisal scores) but are surrounded by built form development but
also transport links/infrastructure. Thus, the inclusion of sites R18 and R19 will not
lead to coalescence nor erode the countryside/Green Belt. Sites R18 and R19 should
be allocated in preference to the Blackmore sites (R25 and R26).
40. There is no need for the Blackmore sites if the allocation on the Shenfield sites is
reinstated. Namely, the 50 dwellings removed from sites R18 and R19 would, if
reinstated, entirely negate the need to allocate sites R25 and R26. Moreover, there is
no evidence that BBC have considered increasing housing density on sites R18 and
R19; both of which could take a higher housing density but particularly the latter.
41. In light of the above, the Plan, as amended by the focussed changes, is not sound
with the inclusion of sites R25 and R26. The inclusion of sites R25 and R26 cannot be
justified and their inclusion of these sites is contrary to national policy, particularly
with regards to sustainable development and Green Belt land policies within the
NPPF.
42. Brentwood Borough Council should amend the plan to retain R25 and R26 as Green
Belt and not allocate these sites for housing.
HOLMES & HILLS LLP
Dated 20 November 2019

Remove R25 and R26 from the plan

Local Development Plan
As a resident of Blackmore I am writing with regard to the Local Development Plan. I have very grave concerns that the proposed plan does not address the concerns of local residents.
I. The development encroaches on to Green Belt land which is a statutory green belt around London and should remain so.
2. The proposed development, although reduced, will put a huge strain on the local infrastructure.
i) The area is prone to flooding.
ii) Local services sre already over stretched
iii) The road access is inadequate
3. The area already has significant development close by at Nine Ashes and Fingrith Hall Lane. The Residents of these development use the services provided by Blackmore but the revised plan does not take account of this.
4.
Ina addition no allowances have been made by Brentwood Council of plans recently approved build over 15 dwellings on Red Rose Farm site and Spriggs Lane.
The plan will significantly increase the population and traffic of the parish. The village cannot realistically support such an increase, especially in the light of adjacent developments who already use the services of Blackmore.
Yours truly,
M Boreham

Such a small reduction in the planned number of houses to be built will make little difference when it comes to infrastructure, etc. bearing in mind the already proposed developments off of Fingrith Hall Lane, Red Rose Lane and Spriggs Lane

Remove R25 & R26 from the LDP

Please note these comments are in addition to the BVHA survey that I have also completed
* The Addendum of Focussed Changes is drafted involving 5 sites and the changes are all interconnected. The way BBC have set up this Consultation site means we must select a single Site for each comment and every change has an implication and effect on the other sites. Therefore I have entered them in "Change 4" but they apply equally to "Change 5" and will all have implications for the other sites. I have also entered them in the Sustainability Section as that is where I found the comments that I am objecting to.
* It should be recorded that each item I have entered is a separate representation and should be logged as such. It has been publicised that Blackmore created c500 responses to the previous consultation. However if you look at these actual responses stored on the BBC portal you will see that in fact for R25 there are 1,026 separate respondents and for R26 there are 1,035 respondents. In addition many of these respondents raise multiple objection when their individual response is reviewed. e.g. Ref 23127 has 11 different objections but is only counted as 1 representation. It would seem that there has been deliberate understatement of the magnitude of local feeling about the inequities of the foisted upon Blackmore by the LDP. To put these numbers in perspective the BBC site shows the representations on other sites as: R01 15 comments; R02 29 comments; R03 18 comments.
* The Addendum of Focussed Changes is presented as a single plan affecting 5 sites, but the individual elements do not have equal merit. All negative aspects relate to R18 & R19, whilst none relate to R25 & R26. Consequently R25 &R26 should be removed entirely and their allocation transferred to R01, R18 or R19
* The Addendum of Focussed Changes has recognised a problem with the LDP and looks to reduce the damaging impact on the worst affected Allocated Sites based on a Council view that removal of any specific site was not "possible". In fact, it is possible to remove a site at this stage, just as it is at the next stage (if so directed by the Inspector). This artificially designated "Major" change of removing a site was shelved. Possibly as it had the negative potential consequence of getting BBC censured, or even possibly having the control of the process taken away from them by central government. Whilst the "Major" change was not palatable for BBC, it is the right option, and better than a superficial "Minor" reduction in numbers on R25 & R26.
* There should be a section106 payment made to assist the Council to make improvements to the local environment where housing developments are planned. In the LDP this is only mentioned in relationship to R01 and the plans being made for that site. There is no mention of s106 for either R25 & R26, and there is no plan at all by BBC to bolster the infrastructure in this area which is already past breaking point. In addition the adjoining Epping Forest District Council continue to site housing developments on the border of Blackmore Village. There has been no consultation between EFDC & BBC about this problem and if EFDC do receive any s106 it will not find itsway to BBC to assist the village that has to bear the burden without any support. Even before BBC consider adding to the normal load by introduction of the LDP
* The Sustainability Objectives specifically raise the need for Gypsy and Traveller communities to have SUITABLE access to services and health care. BBC spent resident's money fighting one unauthorised occupation of land in Blackmore and won. Regrettably they have now smuggled this land-grab in to the LDP as a new official site with no debate or notice. This increases the burden on Blackmore services and infrastructure. which is unable to deal with the existing increase of housing proposed by the LDP. If this is left in the LPD there should be some recognition by completely removing the new house burden R25 & R26 imposed on the village.
* SA Report Addendum 2.5.6 -refers to delivery of new homes alongside infrastructure, but NOTHING has been considered or planned for Blackmore. R25 & R26 should be removed entirely from the LDP and their allocation transferred to R01 unless an appropriate infrastructure improvement plan can be incorporated into the Plan to facilitate the development.
* SA Report Addendum 2.11.3 - recognises that the existing planned reduction of 20 homes at R25/R26 is insufficient to affect the retention of agricultural land. To facilitate this objective R25 & R26 should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - R25 & R26 fail at least 8 of the stated Objectives required for the LDP. These sites should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - This report discusses how developing some sites would, or would not, successfully achieve the objective of reducing Car Dependency. However this test has not been applied to R25 & R26 which require absolute total Car Dependency for any new homes. R25 & R26 should be removed entirely from the plan to meet the LDP goal of reducing car dependency.
* SA Non-Tech Summary - raises "omission sites" incl Honeypot Lane R022 and considers the benefits/disadvantages of their reintroduction. Honeypot Lane was eminently more suitable than any of the 4 sites now seeking reduction in the Focussed Changes, yet was removed without the opportunity for proper review in November 2018. The only reasons I have heard for the removal are a) the site was in the area of a Council member who would need to consider the views of voters b) There is a short pinch point in the access road to the site which would make development access difficult. However the pinch point is still wider than the entire length of Redrose Lane which is being suggested for development of both R25 & R26. The Honeypot Lane site, inexplicably, is still not considered as an alternative to the Northern Villages Allocation. R022 should be re-included in the Plan as this would allow all R18, R19, R25, & R26 to be completely removed and also not require an increased burden being added to R01.

Remove R25 and R26 from the plan

Text submitted online.
The Addendum of Focussed Changes is drafted involving 5 sites and the changes are all interconnected. The way BBC have set up this Consultation site means we must select a single Site for each comment and every change has an implication and effect on the other sites. Therefore I have entered them in "Change 4" but they apply equally to "Change 5" and will all have implications for the other sites. I have also entered them in the Sustainability Section as that is where I found the comments that I am objecting to.
* It should be recorded that each item I have entered is a separate representation and should be logged as such. It has been publicised that Blackmore created c500 responses to the previous consultation. However if you look at these actual responses stored on the BBC portal you will see that in fact for R25 there are 1,026 separate respondents and for R26 there are 1,035 respondents. In addition many of these respondents raise multiple objection when their individual response is reviewed. e.g. Ref 23127 has 11 different objections but is only counted as 1 representation. It would seem that there has been deliberate understatement of the magnitude of local feeling about the inequities of the foisted upon Blackmore by the LDP. To put these numbers in perspective the BBC site shows the representations on other sites as: R01 15 comments; R02 29 comments; R03 18 comments.
* The Addendum of Focussed Changes is presented as a single plan affecting 5 sites, but the individual elements do not have equal merit. All negative aspects relate to R18 & R19, whilst none relate to R25 & R26. Consequently R25 &R26 should be removed entirely and their allocation transferred to R01, R18 or R19
* The Addendum of Focussed Changes has recognised a problem with the LDP and looks to reduce the damaging impact on the worst affected Allocated Sites based on a Council view that removal of any specific site was not "possible". In fact, it is possible to remove a site at this stage, just as it is at the next stage (if so directed by the Inspector). This artificially designated "Major" change of removing a site was shelved. Possibly as it had the negative potential consequence of getting BBC censured, or even possibly having the control of the process taken away from them by central government. Whilst the "Major" change was not palatable for BBC, it is the right option, and better than a superficial "Minor" reduction in numbers on R25 & R26.
* The Sustainability Objectives specifically raise the need for Gypsy and Traveller communities to have SUITABLE access to services and health care. BBC spent resident's money fighting one unauthorised occupation of land in Blackmore and won. Regrettably they have now smuggled this land-grab in to the LDP as a new official site with no debate or notice. This increases the burden on Blackmore services and infrastructure. which is unable to deal with the existing increase of housing proposed by the LDP. If this is left in the LPD there should be some recognition by completely removing the new house burden R25 & R26 imposed on the village.
* SA Report Addendum 2.5.6 -refers to delivery of new homes alongside infrastructure, but NOTHING has been considered or planned for Blackmore. R25 & R26 should be removed entirely from the LDP and their allocation transferred to R01 unless an appropriate infrastructure improvement plan can be incorporated into the Plan to facilitate the development.
* SA Report Addendum 2.11.3 - recognises that the existing planned reduction of 20 homes at R25/R26 is insufficient to affect the retention of agricultural land. To facilitate this objective R25 & R26 should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - R25 & R26 fail at least 8 of the stated Objectives required for the LDP. These sites should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - This report discusses how developing some sites would, or would not, successfully achieve the objective of reducing Car Dependency. However this test has not been applied to R25 & R26 which require absolute total Car Dependency for any new homes. R25 & R26 should be removed entirely from the plan to meet the LDP goal of reducing car dependency.
* SA Non-Tech Summary - raises "omission sites" incl Honeypot Lane R022 and considers the benefits/disadvantages of their reintroduction. Honeypot Lane was eminently more suitable than any of the 4 sites now seeking reduction in the Focussed Changes, yet was removed without the opportunity for proper review in November 2018. The only reasons I have heard for the removal are a) the site was in the area of a Council member who would need to consider the views of voters b) There is a short pinch point in the access road to the site which would make development access difficult. However the pinch point is still wider than the entire length of Redrose Lane which is being suggested for development of both R25 & R26. The Honeypot Lane site, inexplicably, is still not considered as an alternative to the Northern Villages Allocation. R022 should be re-included in the Plan as this would allow all R18, R19, R25, & R26 to be completely removed and also not require an increased burden being added to R01.

Remove R25 and R26 from the plan

Text submitted online.
The Addendum of Focussed Changes is drafted involving 5 sites and the changes are all interconnected. The way BBC have set up this Consultation site means we must select a single Site for each comment and every change has an implication and effect on the other sites. Therefore I have entered them in "Change 4" but they apply equally to "Change 5" and will all have implications for the other sites. I have also entered them in the Sustainability Section as that is where I found the comments that I am objecting to.
* It should be recorded that each item I have entered is a separate representation and should be logged as such. It has been publicised that Blackmore created c500 responses to the previous consultation. However if you look at these actual responses stored on the BBC portal you will see that in fact for R25 there are 1,026 separate respondents and for R26 there are 1,035 respondents. In addition many of these respondents raise multiple objection when their individual response is reviewed. e.g. Ref 23127 has 11 different objections but is only counted as 1 representation. It would seem that there has been deliberate understatement of the magnitude of local feeling about the inequities of the foisted upon Blackmore by the LDP. To put these numbers in perspective the BBC site shows the representations on other sites as: R01 15 comments; R02 29 comments; R03 18 comments.
* The Addendum of Focussed Changes is presented as a single plan affecting 5 sites, but the individual elements do not have equal merit. All negative aspects relate to R18 & R19, whilst none relate to R25 & R26. Consequently R25 &R26 should be removed entirely and their allocation transferred to R01, R18 or R19
* The Addendum of Focussed Changes has recognised a problem with the LDP and looks to reduce the damaging impact on the worst affected Allocated Sites based on a Council view that removal of any specific site was not "possible". In fact, it is possible to remove a site at this stage, just as it is at the next stage (if so directed by the Inspector). This artificially designated "Major" change of removing a site was shelved. Possibly as it had the negative potential consequence of getting BBC censured, or even possibly having the control of the process taken away from them by central government. Whilst the "Major" change was not palatable for BBC, it is the right option, and better than a superficial "Minor" reduction in numbers on R25 & R26.
* The Sustainability Objectives specifically raise the need for Gypsy and Traveller communities to have SUITABLE access to services and health care. BBC spent resident's money fighting one unauthorised occupation of land in Blackmore and won. Regrettably they have now smuggled this land-grab in to the LDP as a new official site with no debate or notice. This increases the burden on Blackmore services and infrastructure. which is unable to deal with the existing increase of housing proposed by the LDP. If this is left in the LPD there should be some recognition by completely removing the new house burden R25 & R26 imposed on the village.
* SA Report Addendum 2.5.6 -refers to delivery of new homes alongside infrastructure, but NOTHING has been considered or planned for Blackmore. R25 & R26 should be removed entirely from the LDP and their allocation transferred to R01 unless an appropriate infrastructure improvement plan can be incorporated into the Plan to facilitate the development.
* SA Report Addendum 2.11.3 - recognises that the existing planned reduction of 20 homes at R25/R26 is insufficient to affect the retention of agricultural land. To facilitate this objective R25 & R26 should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - R25 & R26 fail at least 8 of the stated Objectives required for the LDP. These sites should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - This report discusses how developing some sites would, or would not, successfully achieve the objective of reducing Car Dependency. However this test has not been applied to R25 & R26 which require absolute total Car Dependency for any new homes. R25 & R26 should be removed entirely from the plan to meet the LDP goal of reducing car dependency.
* SA Non-Tech Summary - raises "omission sites" incl Honeypot Lane R022 and considers the benefits/disadvantages of their reintroduction. Honeypot Lane was eminently more suitable than any of the 4 sites now seeking reduction in the Focussed Changes, yet was removed without the opportunity for proper review in November 2018. The only reasons I have heard for the removal are a) the site was in the area of a Council member who would need to consider the views of voters b) There is a short pinch point in the access road to the site which would make development access difficult. However the pinch point is still wider than the entire length of Redrose Lane which is being suggested for development of both R25 & R26. The Honeypot Lane site, inexplicably, is still not considered as an alternative to the Northern Villages Allocation. R022 should be re-included in the Plan as this would allow all R18, R19, R25, & R26 to be completely removed and also not require an increased burden being added to R01.

Remove R25 and R26 from the plan

Text submitted online.
The Addendum of Focussed Changes is drafted involving 5 sites and the changes are all interconnected. The way BBC have set up this Consultation site means we must select a single Site for each comment and every change has an implication and effect on the other sites. Therefore I have entered them in "Change 4" but they apply equally to "Change 5" and will all have implications for the other sites. I have also entered them in the Sustainability Section as that is where I found the comments that I am objecting to.
* It should be recorded that each item I have entered is a separate representation and should be logged as such. It has been publicised that Blackmore created c500 responses to the previous consultation. However if you look at these actual responses stored on the BBC portal you will see that in fact for R25 there are 1,026 separate respondents and for R26 there are 1,035 respondents. In addition many of these respondents raise multiple objection when their individual response is reviewed. e.g. Ref 23127 has 11 different objections but is only counted as 1 representation. It would seem that there has been deliberate understatement of the magnitude of local feeling about the inequities of the foisted upon Blackmore by the LDP. To put these numbers in perspective the BBC site shows the representations on other sites as: R01 15 comments; R02 29 comments; R03 18 comments.
* The Addendum of Focussed Changes is presented as a single plan affecting 5 sites, but the individual elements do not have equal merit. All negative aspects relate to R18 & R19, whilst none relate to R25 & R26. Consequently R25 &R26 should be removed entirely and their allocation transferred to R01, R18 or R19
* The Addendum of Focussed Changes has recognised a problem with the LDP and looks to reduce the damaging impact on the worst affected Allocated Sites based on a Council view that removal of any specific site was not "possible". In fact, it is possible to remove a site at this stage, just as it is at the next stage (if so directed by the Inspector). This artificially designated "Major" change of removing a site was shelved. Possibly as it had the negative potential consequence of getting BBC censured, or even possibly having the control of the process taken away from them by central government. Whilst the "Major" change was not palatable for BBC, it is the right option, and better than a superficial "Minor" reduction in numbers on R25 & R26.
* The Sustainability Objectives specifically raise the need for Gypsy and Traveller communities to have SUITABLE access to services and health care. BBC spent resident's money fighting one unauthorised occupation of land in Blackmore and won. Regrettably they have now smuggled this land-grab in to the LDP as a new official site with no debate or notice. This increases the burden on Blackmore services and infrastructure. which is unable to deal with the existing increase of housing proposed by the LDP. If this is left in the LPD there should be some recognition by completely removing the new house burden R25 & R26 imposed on the village.
* SA Report Addendum 2.5.6 -refers to delivery of new homes alongside infrastructure, but NOTHING has been considered or planned for Blackmore. R25 & R26 should be removed entirely from the LDP and their allocation transferred to R01 unless an appropriate infrastructure improvement plan can be incorporated into the Plan to facilitate the development.
* SA Report Addendum 2.11.3 - recognises that the existing planned reduction of 20 homes at R25/R26 is insufficient to affect the retention of agricultural land. To facilitate this objective R25 & R26 should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - R25 & R26 fail at least 8 of the stated Objectives required for the LDP. These sites should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - This report discusses how developing some sites would, or would not, successfully achieve the objective of reducing Car Dependency. However this test has not been applied to R25 & R26 which require absolute total Car Dependency for any new homes. R25 & R26 should be removed entirely from the plan to meet the LDP goal of reducing car dependency.
* SA Non-Tech Summary - raises "omission sites" incl Honeypot Lane R022 and considers the benefits/disadvantages of their reintroduction. Honeypot Lane was eminently more suitable than any of the 4 sites now seeking reduction in the Focussed Changes, yet was removed without the opportunity for proper review in November 2018. The only reasons I have heard for the removal are a) the site was in the area of a Council member who would need to consider the views of voters b) There is a short pinch point in the access road to the site which would make development access difficult. However the pinch point is still wider than the entire length of Redrose Lane which is being suggested for development of both R25 & R26. The Honeypot Lane site, inexplicably, is still not considered as an alternative to the Northern Villages Allocation. R022 should be re-included in the Plan as this would allow all R18, R19, R25, & R26 to be completely removed and also not require an increased burden being added to R01.

Remove R25 and R26 from the plan

Text submitted online.
The Addendum of Focussed Changes is drafted involving 5 sites and the changes are all interconnected. The way BBC have set up this Consultation site means we must select a single Site for each comment and every change has an implication and effect on the other sites. Therefore I have entered them in "Change 4" but they apply equally to "Change 5" and will all have implications for the other sites. I have also entered them in the Sustainability Section as that is where I found the comments that I am objecting to.
* It should be recorded that each item I have entered is a separate representation and should be logged as such. It has been publicised that Blackmore created c500 responses to the previous consultation. However if you look at these actual responses stored on the BBC portal you will see that in fact for R25 there are 1,026 separate respondents and for R26 there are 1,035 respondents. In addition many of these respondents raise multiple objection when their individual response is reviewed. e.g. Ref 23127 has 11 different objections but is only counted as 1 representation. It would seem that there has been deliberate understatement of the magnitude of local feeling about the inequities of the foisted upon Blackmore by the LDP. To put these numbers in perspective the BBC site shows the representations on other sites as: R01 15 comments; R02 29 comments; R03 18 comments.
* The Addendum of Focussed Changes is presented as a single plan affecting 5 sites, but the individual elements do not have equal merit. All negative aspects relate to R18 & R19, whilst none relate to R25 & R26. Consequently R25 &R26 should be removed entirely and their allocation transferred to R01, R18 or R19
* The Addendum of Focussed Changes has recognised a problem with the LDP and looks to reduce the damaging impact on the worst affected Allocated Sites based on a Council view that removal of any specific site was not "possible". In fact, it is possible to remove a site at this stage, just as it is at the next stage (if so directed by the Inspector). This artificially designated "Major" change of removing a site was shelved. Possibly as it had the negative potential consequence of getting BBC censured, or even possibly having the control of the process taken away from them by central government. Whilst the "Major" change was not palatable for BBC, it is the right option, and better than a superficial "Minor" reduction in numbers on R25 & R26.
* The Sustainability Objectives specifically raise the need for Gypsy and Traveller communities to have SUITABLE access to services and health care. BBC spent resident's money fighting one unauthorised occupation of land in Blackmore and won. Regrettably they have now smuggled this land-grab in to the LDP as a new official site with no debate or notice. This increases the burden on Blackmore services and infrastructure. which is unable to deal with the existing increase of housing proposed by the LDP. If this is left in the LPD there should be some recognition by completely removing the new house burden R25 & R26 imposed on the village.
* SA Report Addendum 2.5.6 -refers to delivery of new homes alongside infrastructure, but NOTHING has been considered or planned for Blackmore. R25 & R26 should be removed entirely from the LDP and their allocation transferred to R01 unless an appropriate infrastructure improvement plan can be incorporated into the Plan to facilitate the development.
* SA Report Addendum 2.11.3 - recognises that the existing planned reduction of 20 homes at R25/R26 is insufficient to affect the retention of agricultural land. To facilitate this objective R25 & R26 should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - R25 & R26 fail at least 8 of the stated Objectives required for the LDP. These sites should be completely removed from the plan and the allocation transferred to R01.
* SA Non-Tech Summary - This report discusses how developing some sites would, or would not, successfully achieve the objective of reducing Car Dependency. However this test has not been applied to R25 & R26 which require absolute total Car Dependency for any new homes. R25 & R26 should be removed entirely from the plan to meet the LDP goal of reducing car dependency.
* SA Non-Tech Summary - raises "omission sites" incl Honeypot Lane R022 and considers the benefits/disadvantages of their reintroduction. Honeypot Lane was eminently more suitable than any of the 4 sites now seeking reduction in the Focussed Changes, yet was removed without the opportunity for proper review in November 2018. The only reasons I have heard for the removal are a) the site was in the area of a Council member who would need to consider the views of voters b) There is a short pinch point in the access road to the site which would make development access difficult. However the pinch point is still wider than the entire length of Redrose Lane which is being suggested for development of both R25 & R26. The Honeypot Lane site, inexplicably, is still not considered as an alternative to the Northern Villages Allocation. R022 should be re-included in the Plan as this would allow all R18, R19, R25, & R26 to be completely removed and also not require an increased burden being added to R01.

These representations are submitted in response to the publication of:
Brentwood Borough Council Local Plan Consultation on Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)
We object to the following change to the Pre-Submission Local Plan:
* Policy R01 (I) (Dunton Hills Garden Village Strategic Allocation): Increase from "at least 2,770 homes in the plan period".
We support the following changes to the Pre-Submission Local Plan:
* Policy R18 (Land off Crescent Drive, Shenfield): Reduction from "around 55" to "around 35 homes".
* Policy R19 (Land at Priests Lane, Shenfield): Reduction from "around 75" to "around 45 homes".
* Policy R25 (Land north of Woollard Way, Blackmore): Reduction from "around 40" to around "30 homes".
* Policy R26 (Land north of Orchard Piece, Blackmore): Reduction from "around 30" to "around 20 homes".
We support the reduction in housing numbers at the allocation sites in Shenfield and Blackmore, as this is justified by the evidence base.
However, we object to the re-distribution of the 70 dwellings to the Dunton Hills Garden Village (DHGV) allocation, because it would mean that fewer homes would be delivered in the early years of the plan. The reliance on DHGV to deliver such a large proportion of the Borough's housing need within the early years of the plan is too great, particularly when smaller sites are available, some of which are brownfield.
Larger sites often take longer to deliver housing, because they typically have complex ownership structures and require significant investment in infrastructure. Research published by consultancy Nathaniel Lichfield & Partners (Start to Finish: How Quickly do Large-Scale Housing Sites Deliver? November 2016) found that for sites of over 2,000 dwellings, the average timeframe between the validation date of the planning application and the delivery of the first dwelling was just under seven years. This compares with just under three years for smaller sites of up to 99 dwellings and therefore, whilst it is justified to reduce the housing allocation at the sites in Shenfield and Blackmore, the 70 dwellings should be re-distributed to suitable smaller developments rather than being added to DHGV.
Smaller sites are often able to come forward more quickly than larger sites because they are typically in single ownership and require less investment in infrastructure. They also attract smaller, more local housebuilding companies that would not be present on larger sites, enable more early deliveries and constitute a more sustainable approach towards meeting the housing need.
Brownfield sites should also be prioritised in line with the requirements of the NPPF, which states in paragraph 137 that:
'before concluding that exceptional circumstances exist to justify changes to Green Belt boundaries, the strategic policy-making authority should be able to demonstrate that it has examined fully all other reasonable options for meeting its identified need for development'.
As a result, brownfield land should be utilised, with greenfield land being released only when all sustainably located, available and deliverable sites have been identified as allocations.
In contrast, Brentwood Borough Council propose relying entirely on the delivery of a single, large, greenfield site to be able to demonstrate and maintain a five-year supply in the early plan period - a method that has been criticised by several inspectors at Local Plan Examinations in Braintree District, Tendring District and Colchester Borough Council in relation to North Essex Garden Communities.
Due to the location of the Dunton Hills Garden Village allocation, a significant proportion of Brentwood's housing would be located on the Borough boundary with Basildon. The settlement would adjoin Basildon's Green Belt and although it was once intended for both Councils to locate settlements in this area, Basildon no longer propose this. It could therefore also be considered that the authorities have not complied with their duty to co-operate.
In conclusion, we object to the re-distribution of 70 dwellings into the Dunton Hills Garden Village allocation, considering instead that the dwellings should be re-allocated to more suitable smaller sites and brownfield land. Whilst we do not object to the principle of a new settlement, we do not consider that it should be relied upon to deliver such a significant proportion of the Borough's housing need within the timeframe envisaged, particularly when suitable alternative sites are available.

Remove from the LDP and place in either Dunton Village or one of the vacant brown field sites around Brentwood Town Centre

Blackmore village suffers with flooding, any planning extensions granted during the last 30 years have had to provide soakaways for the increase in rain water. Where is the excess water going from the proposedof new build homes. Blackmore was flooded as recently as 2015.
There is no infra structure or facilities to support the new builds. Green belt should not be built on when there are numerous vacant brown field sites around the Borough which already have the infrastructure to support them. I submitted numerous reasons in both my previous submissions refer you to these.

This should be completely removed

There are brownfield sits and other local housing developments on the fringe of the village that must be taken into consideration and this option

Proper assessment of the current and planned developments and this development completely from the plan

There are brownfield developments proposed and other housing on the firings of the village that meet the requirements without the need to consider what is developer led developments on green belt.

take this out of the plan

No insfrastructure
no public transport
schools and doctors already oversubscribed
no account taken of other developments forcing traffic and use of village amenities
no housing need analysis undertaken - just developer lead - no consultation with residents to add to the plan
no co-operation with neighbouring borought who have already approved the building of 36 homes at the top of Fingrith Hall Road

The proposal to build on this site must be cancelled for the reasons stated

The reduction in numbers does not address the issue of inappropriate development on green belt land. Government policy states that brownfield sites must be prioritised and focused change 2 and 3 should be pursued for the full allocation. In addition brownfield developments within the village area and additional housing on the perimeter of the parish meets the requirement and must be taken into consideration. Aside from the lack of local resources ie schools, doctors and lack of parking in the village increased volumes of traffic along restricted land for access track is not acceptable and makes the proposal unsound. The council has also failed to take into account the flood risk assessment completed by Essex Council and requirements to grow the supporting infrastructureIn addition brownfield developments within the village area and additional housing on the perimeter of the parish meets the requirement and must be taken into consideration. Aside from the lack of local resources ie schools, doctors and lack of parking in the village increased volumes of traffic along restricted land for access track is not acceptable and makes the proposal unsound. The council has also failed to take into account the flood risk assessment completed by Essex Council and requirements to grow the supporting infrastructure

Reduce the number to zero

My previous 2019 submission still stands. New sites on border or within Parish add 65 dwellings not included within LDP and not taken into account. All will use Blackmore infrastructure and facilities with no improvements planned. Red Rose Farm - brownfield - 12 dwellings not identified in LDP being built opposite proposed site. Stondon Massey requesting development but not in LDP. Oaktree Farm Plot 3 being included even though previously thrown out by the High Court. Illogical and sends wrong messages. The LDP not thought through and vague on numbers - uses 'around' to detail developments - open ended.

Delete the development from the LDP

Nothing has changed! The BBC's view that the village does not have the infrastructure to cope with development of this nature in its previous LDP proposal. Even with a reduction from 70 to 50 it is still far too much and does not take into account the numerous developments that are right on the village borders numbering some 65 dwellings. The extra traffic will cause a very real danger at Nine Ashes Road and Red Rose junction - right by the school, preschool, village hall and sports club and where the water floods across the road after rainfall.

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.

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 100 / BBC 22487
ECC 101 / BBC 22488
ECC 102 / BBC 22489
ECC's position has not changed on this matter.