MM19
Object
Schedule of Potential Main Modifications
Representation ID: 29469
Received: 30/10/2021
Respondent: Mr Andrew Borton
Legally compliant? No
Sound? No
Blackmore is located in a critical drainage area. The development of a GREEN FIELD site will impact on a village that floods regularly throughout the year. No SUDS will be as efficient as a green field.
Blackmore is located in a critical drainage area. The development of a GREEN FIELD site will impact on a village that floods regularly throughout the year. No SUDS will be as efficient as a green field.
Support
Schedule of Potential Main Modifications
Representation ID: 29481
Received: 03/11/2021
Respondent: Essex County Council
3. Effective
The Water Framework Directive (WFD) is a driver for the need for water quality improvements. However, the inclusion of the paragraph as originally submitted within the section relating to SuDS was confusing because ECC as LLFA do not use the criteria associated with water body status to assess pollution control delivered by SuDS.
The proposed modifications to paragraph 5.68 are considered acceptable.
This addresses ECC’s Reg.19 Rep 22290 and the position in the Statement of Common Ground (F17D) between BBC and ECC.
3. Effective
The Water Framework Directive (WFD) is a driver for the need for water quality improvements. However, the inclusion of the paragraph as originally submitted within the section relating to SuDS was confusing because ECC as LLFA do not use the criteria associated with water body status to assess pollution control delivered by SuDS.
The proposed modifications to paragraph 5.68 are considered acceptable.
This addresses ECC’s Reg.19 Rep 22290 and the position in the Statement of Common Ground (F17D) between BBC and ECC.
Object
Schedule of Potential Main Modifications
Representation ID: 29489
Received: 03/11/2021
Respondent: Mr Richard Thwaite
Legally compliant? No
Sound? No
An additional 70 houses on higher ground from the ancient centre of the village will increase the flooding risk due to additional run-off to a Grade I listed Church and priory, as well as those houses in the centre of the village that already have been flooded in the past and are in a high flood risk area. Completely unsatisfactory to build houses in an area that is already prone to flooding. It won't be possible to build 70 houses and associated roads and pavements without creating more run-off than would have been if they had been left as fields.
An additional 70 houses on higher ground from the ancient centre of the village will increase the flooding risk due to additional run-off to a Grade I listed Church and priory, as well as those houses in the centre of the village that already have been flooded in the past and are in a high flood risk area. Completely unsatisfactory to build houses in an area that is already prone to flooding. It won't be possible to build 70 houses and associated roads and pavements without creating more run-off than would have been if they had been left as fields.
Object
Schedule of Potential Main Modifications
Representation ID: 29610
Received: 05/11/2021
Respondent: Mrs Helen Whalley
Legally compliant? Yes
Sound? No
The existing current sewerage system in Blackmore is already at more than capacity.
More houses will make the situation worse and the number of houses proposed will make the situation much worse.
The existing current sewerage system in Blackmore is already at more than capacity.
More houses will make the situation worse and the number of houses proposed will make the situation much worse.
Object
Schedule of Potential Main Modifications
Representation ID: 29623
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
4. Not Consistent with National Policy
ECC as Lead Local Flood Authority (LLFA) for BBC are satisfied in principle with the amended policy for BE08 Sustainable Drainage.
However, criterion D needs to include reference to Flood Risk Assessment to ensure the link to the Flood Risk Policy in the Local Plan is clear to applicants and decision makers.
3. Not Effective
4. Not Consistent with National Policy
ECC as Lead Local Flood Authority (LLFA) for BBC are satisfied in principle with the amended policy for BE08 Sustainable Drainage.
However, criterion D needs to include reference to Flood Risk Assessment to ensure the link to the Flood Risk Policy in the Local Plan is clear to applicants and decision makers.
Object
Schedule of Potential Main Modifications
Representation ID: 29835
Received: 25/11/2021
Respondent: Mr Graham Hesketh
Legally compliant? No
Sound? No
Pages 45- Blackmore has a critical drainage problem which will be further hindered in its capacity to cope if green fields with their permeable surfaces are replaced and 70 new homes built upon them. I doubt whether a Sustainable Drainage System (SuDS) will provide a workable solution.
I am writing in response to the multitude of “Main Modifications”(MM) arising from the 8 month public examination of the flawed Brentwood Borough Council’s Local Development Plan. Before starting on my comments I think it is now appropriate to add the following words, maybe of wisdom, that have been uttered recently by a certain politician that certainly according to the Council of the Protection of Rural England (CPRE) puts a different light on the subject of housing proposals.
At his speech to the Conservative Party Conference in early October 2021 the Prime Minister Boris Johnson, asserted that that there was no reason that the countryside should be lost to new unaffordable homes, saying ‘you can… see how much room there is to build the homes that young families need… beautiful homes, on brownfield sites in places where homes make sense’. He could not be more explicit – ‘there is no reason to allow the countryside and local green spaces to be opened up ‘to unscrupulous developers building unaffordable homes.’ This statement from the CPRE now appears to be massively encouraging for local groups and campaigners up and down the country who have fought tooth and nail to protect their local green spaces and to continue to have a say in the planning system which after reading the MM has looked to have been ignored. Perhaps now local groups and campaigners can finally be heard rather than “unscrupulous developers” who are determined to turn our green belt into a mass of houses without due consideration of the needs and desires of the local community, as it looks like in the MM which suggests a reversion back to the original plan of building 40 houses on site R25 (up from 30) and 30 on site R26 (up from 20).
MM14-19 Flood risk and drainage issues
MM14C
Page 37- Over the 25 years of living here in Blackmore it has become far more obvious that the sewerage system around Blackmore is or is now in a state where over capacity is apparent. I believe this is one of the reasons why Blackmore was previously not considered a suitable site for further development. However, Blackmore was suddenly included in the Local Development Plan as a result of the volte-face at Reg 18.
46 MM19G
Pages 45- Blackmore has a critical drainage problem which will be further hindered in its capacity to cope if green fields with their permeable surfaces are replaced and 70 new homes built upon them. I doubt whether a Sustainable Drainage System (SuDS) will provide a workable solution.
Page 161 MM78
At present heavy rain (and with the prospect of climate change this increases) brings with it inevitable flooded areas within the village which are well documented. If and I say this with much reservation, these proposals are adopted then surely an investigation by the Environmental Agency must be a priority before sites R25/26 are adopted into the final LDP. The absence of engagement with the local community and the knowledge it has when such events occur is a serious omission of the soundness of the LDP.
Page 164
During the December/February hearings in 2020/21 heavy rain once again highlighted the problems with flooding in this area. The source of this flooding once the rain falls is the River Wid which rises just north of Blackmore and flows under as well as over the eastern side of Redrose Lane. Whilst these hearings were going on Redrose lane was impassable on 10 separate occasions. Access to site R26 from the Chelmsford Road was nigh impossible. Building on this site even with the ‘mitigration’ measures put forward is a poor consideration of judgment as emergency vehicles could be impeded by ongoing flooding which is certainly not going to improve. There is also a major consideration of using Redrose Lane as the access point to this proposed site due not only to the flooding nature but also to the danger to the frequent walkers, cyclists and horse riders who use this narrow lane which is just about safe for two normal sized vehicles to use. As for gaining access into site R26 through Orchard Piece, then there must be for the residents of this quiet cul-de-sac a great possibility of the destruction of their normal peace and quiet as well as more traffic with all its potential dangers.
Getting back to the flooding issue/and surface water ran off which is an ongoing event here in Blackmore evidence suggests there has been no SuDS yet developed or invented that will absorb the vast and significant levels of surface water the village has seen over the 25 years I have lived here and has suffered from. It will certainly not be resolved by allowing over 4 hectares of quality farmland sitting uphill from the village in the Green Belt to be concreted and tarmaced over. Documentary evidence submitted with pictures of flooding over the years, climate change and all that comes with it and a recent Sustainability Appraisal by AECOM (September 2021) suggesting that ’the proposal to increase housing density in Blackmore potentially gives rise to a degree of risk and negative effects’ (2.15.2.) This certainly gives the impression this is an issue that is not going away and AECOM further state ‘it will be important to receive the views of the Environmental Agency through the forthcoming consultation’.
MM81
Page 171-
The term ‘exceptional circumstances’ is as broad as it is long but sites R25/26 are suggested areas that should be released due to them. What is the definition of this term? What is meant by ‘Redrose Lane is a defendable boundary’ when there is existing housing on the north side and a new development on a brownfield site has just been completed and is now fully occupied. (Surely this development in which the Blackmore Village Heritage Association supported should be taken into consideration and deducted from the proposed 70 houses and not snaffled up as a windfall site by the BBC) Furthermore, brownfield sites have been identified by local groups but dismissed by the local council surely flying in the face of the Prime Minister assertion that no green fields should be built upon. Having listened to the session with the Brentwood Borough Council, developers and their legal teams on the 3rd February 2021 I can find no substance in their arguments as to what are ‘exceptional circumstances’ and can only conclude this is a developer led submission.
MM107/108
Pages 236-241 relating to R25/26 land to north of Blackmore declares that this site is indeed located in a ‘critical drainage area’ which relates to previous comments made above. With the increase in the numbers of dwellings from 50 to 70 there is a greater risk factor to regard flooding, drainage capacity, infrastructure issues regarding road and road safety, school and health services which are already under severe strain. There is no parade of shops but 2 public houses, a small Co-op for day to day needs and a tea shop/café. The BBC’s focused Consultation in November 2019 recognized the concerns about infrastructure but again the National Planning Policy Frame (NPPF) appears to be retrofitted to accommodate these plans, although with the concerns of our PM in his October address there is a glimmer of hope for a complete rethink here!
Annexe 2 MM116 Appendix 2
The Strategic Policy BE09 refers to “Sustainable Means of Travel and Walkable Streets” but with 70 extra homes (plus the others on the previously mentioned brownfield site) this will inevitably led to more cars, journeys congestion to the village centre and more pollution in the most remote part of the borough surely flying in the face of the concerns that will be addressed at Cop26 in November. Furthermore, the narrow lanes around the village with no pavements do not make it an ideal walkable area but highly dangerous with the ever increasing traffic that is inevitable from such developments, with poor public transport set within a rural environment.
SO3 considers opportunities to “Deliver Sustainable Communities”. Blackmore is already a sustainable thriving village in what is described a “Borough of Villages” but building 70 extra homes will not increase employment opportunities or enhance community facilities that are already overstretched. Other villages nearby (Stondon Massey for example) do need regeneration and are calling out for it.
Other reference points in the MM paper as in Page 3 like “promoting sustainable mobility” cannot be made by building in Blackmore. On Page 4 “Creating environmental net gain “ must be taken with a pinch of salt as the taking away of 4 hectares of green land will DESTROY wildlife habitat not enhance it.
Looking again at the Sustainability Appraisal September 2021 Page 5 comments on “Community and wellbeing”. I suggest BBC has little understanding of the community that the inhabitants of Blackmore have built up here over the decades. How the report can comment that it is “difficult to conclude that concerns are significant” is not correct. (see statement by Boris Johnson below)
On Page 9 “Omission Sites” are mentioned. What a contradictory state of affairs when you have a long standing site in Honeypot Lane and able to accommodate about 200 homes voted out of the LDP at an ECM in November 2018 due to site access and being on the Green Belt whilst Blackmore is voted in despite even having more difficult access issues and wait for it being on the Green Belt. Adding to the village another 20% of housing stock to the 350 already here flies in the face of logic.
Before I finish let me refer you once again to Boris Johnson who said this in 2006.
“The trouble with her (economist Kate Barker) proposal to develop the less idyllic pieces of the Green Belt is that one man’s pylon-infested dump is another man’s rural dream; and no sooner do the Barker homes march on to the pylon-infested dump than the developers start looking greedily at the really green spaces nearby, and soon big yellow machines are slicing up the fields and linking one village with the next”. Today 70 homes tomorrow many, many more and probably not affordable as 25% target of the proposed 70 new homes to go to locals was instantly dismissed by the planning inspector and the Council’s own barrister as ridiculous. At least we agree on something!
Object
Schedule of Potential Main Modifications
Representation ID: 29858
Received: 25/11/2021
Respondent: Mrs Edna Williams
Legally compliant? No
Sound? No
All developments should have SuDS...in order to reduce surface water
See attached representation
Object
Schedule of Potential Main Modifications
Representation ID: 30256
Received: 30/11/2021
Respondent: Mr Richard Reed
Legally compliant? No
Sound? No
Various points around the village of Blackmore are already prone to flooding.
See attached
Object
Schedule of Potential Main Modifications
Representation ID: 30260
Received: 30/11/2021
Respondent: Mrs Terri Reed
Legally compliant? No
Sound? No
This is a critical drainage area. It is important to maintain natural drainage. By building on such areas, you will create problems for the future. Short term gain in meeting the LDP requirements without due consideration to the impact on the environment and community will in turn create a long term problem.
See attached
Object
Schedule of Potential Main Modifications
Representation ID: 30385
Received: 03/12/2021
Respondent: Mr John Lester
Legally compliant? Not specified
Sound? No
Blackmore frequently floods at various locations around the village. It is identified as a Critical Drainage Area. By removing green fields and replacing with concrete this will not help this problem.
See attached representation
Object
Schedule of Potential Main Modifications
Representation ID: 30420
Received: 03/12/2021
Respondent: Ms Patricia Taylor
Legally compliant? Not specified
Sound? No
The suggestion that SuDS will resolve this situation is not viable and if built upon, the present greenbelt fields R25 and R26 will not allow water to soak away, inevitably causing flooding to nearby properties. Climate change needs to be taken into account – we are experiencing flooding on an increasingly regular basis.
See attached.
Object
Schedule of Potential Main Modifications
Representation ID: 30493
Received: 04/12/2021
Respondent: Mrs Lucille Foreman
Legally compliant? Not specified
Sound? No
As Blackmore is in a critical drainage area a green field will provide a more permeable surface than a housing development.
See attached representation
Object
Schedule of Potential Main Modifications
Representation ID: 30500
Received: 04/12/2021
Respondent: Mr Colin Foreman
Legally compliant? Not specified
Sound? No
As Blackmore is in a critical drainage area a green field will provide a more permeable surface than a housing development.
See attached representation
Object
Schedule of Potential Main Modifications
Representation ID: 30582
Received: 06/12/2021
Respondent: Mrs Elaine Smith
Legally compliant? No
Sound? No
I’m deeply concerned with drainage and flood risk already in Blackmore without adding more houses. In heavy rain there is flooding on Redrose Lane rendering it impassable, also Chelmsford Road floods cutting off exists to Chelmsford and Ingatestone. When the River Wid ‘overtops’ its not just rain water but also sewerage being discharged onto the streets and endangering public health. In storm conditions church street also floods.
See attached