Green Belt land should be retained unless all other avenues have been exhausted. In the case of the proposed additional housing to Blackmore, other more appropriate locations have not been considered in detail. There are NO EXCEPTIONAL circumstances and those put forward are spurious and without foundation

Brentwood Borough Council (BBC) need to clearly demonstrate what exceptional circumstances exist to take R25 and R26 out of the greenbelt in Blackmore. They have not done so and these sites should not be released. There has been no "objectively assessed housing needs" investigation.

The plan states that green belt land will be preserved and only released in exceptional circumstances. The plan does not explain what the exceptional circumstances are that mean that the greenbelt land that sites R25 and R26 are to be built on should be released. There are no exceptional circumstances that can justify the release of this land in an ancient and historic village that is already full to capacity with housing for the size of village, the roads and the blue infrastructure it currently has. It will create further flooding and risk damage to a Grade I listed church, it will raise traffic levels to an unsustainable level in the village and surrounding area and will damage an ecologically important area. There are far better locations both brownfield and greenbelt that are suitable for development than these 2 parcels of land in Blackmore. It is clear that this is a developer led proposal, and there are no exceptional circumstances which can possibly justify this development in this location.

There are no exceptional circumstances that apply to change the status of the green belt land of sites R25 and R26:
The proposed number of houses is substantial encroachment onto the countryside; one of the purposes of the green belt is to safeguard against that.
The proposed number of houses and the use of narrow rural Red Rose Lane for access will substantially change the setting and character of the small rural village of Blackmore. One of the purposes of the green belt is to preserve that.

Blackmore does not align with being an 'exceptional circumstance', especially regarding having good connectivity. There are no main roads, all roads out are country lanes and the only transport is a very limited bus service. It is not within an easy commute to a train station apart from by car which is not an environmentally safe option. No strategic approach has been applied and I believe there is greenbelt land in places much better suited with better infrastructure and transport.

Blackmore does not align with being an 'exceptional circumstance', especially regarding having good connectivity. There are no main roads, all roads out are country lanes and the only transport is a very limited bus service. It is not within an easy commute to a train station apart from by car which is not an environmentally safe option. No strategic approach has been applied and I believe there is greenbelt land in places much better suited with better infrastructure and transport.

Blackmore does not align with being an 'exceptional circumstance', especially regarding having good connectivity. There are no main roads, all roads out are country lanes and the only transport is a very limited bus service. It is not within an easy commute to a train station apart from by car which is not an environmentally safe option. No strategic approach has been applied and I believe there is greenbelt land in places much better suited with better infrastructure and transport.

Whilst consolidating the Pre-Submission Plan's Green Belt policies into a single strategic policy (MG02) gives these policies greater prominence in the plan, the fine detail encapsulated in Policies NE10-NE15 of the Pre-Submission Plan has been lost. To delete these policies on the basis that they are "Covered by other policies in the Plan" leaves the Council's position unclear on the exceptions allowed by paragraph 149 of the NPPF, and is unhelpful given that the matters dealt with in Policies NE10-NE15 are not covered by other policies in the plan.

MM5 states that "The vitality of rural communities to ensure villages grow and thrive, in line with paragraph 78 of the NPPF, was a key consideration in defining the spatial strategy", but this aspiration is not borne out by the proposed modifications to the Plan. For the record, paragraph 78 of the NPPF states:

"In rural areas, planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs. Local planning authorities should support opportunities to bring forward rural exception sites that will provide affordable housing to meet identified local needs, and consider whether allowing some market housing on these sites would help to facilitate this."

The government's position is clear: local planning authorities should support opportunities to bring forward rural exception sites to meet identified local needs (with no distinction drawn between Green Belt and non-Green Belt locations). Yet the proposed modifications remove the only route open to communities and landowners to bring forward affordable housing for local community needs i.e. schemes which accord with paragraph 149 of the NPPF (the paragraph 72 route being ruled out by note 36 which excludes Green Belts).

In the Pre-Submission Plan, Policy NE10 specifically allowed for limited affordable housing for local community needs in accordance with other policies set out in this Plan, reflecting the approach set out in paragraph 149 of the NPPF. As modified, the Plan contains no support for exception sites (whether in the Green Belt or not), in conflict with paragraph 78 of the NPPF. This is a particular concern given that the Pre-Submission Plan identifies at paragraph 8.79 that 89% of the borough is designated as Green Belt, giving Brentwood the sixth highest Green Belt area in England, meaning the only realistic option for exception sites in the Borough is the Green Belt.

Although the Plan insets the 11 largest villages from the Green Belt, there are numerous smaller villages in the borough, with MM5 identifying that "Brentwood borough is characterised by a central urban core and a number of scattered villages north and south of this main urban core. This has given rise to its principal character as a 'Borough of Villages'." It is therefore very disappointing that the Plan as modified offers no support for schemes aimed at meeting the housing needs of the smaller villages in the borough.

One possible interpretation of Policy MG02 is that, despite making no reference to Paragraph 149 of the NPPF, it offers implicit support for rural exception sites with the words: "All development proposals within the Green Belt will be considered and assessed in accordance with the provisions of national planning policy". However, paragraph 9(f) of the NPPF offers support only for "limited affordable housing for local community needs UNDER POLICIES SET OUT IN THE DEVELOPMENT PLAN [my emphasis] (including policies for rural exception sites)".

In other words, the Local Plan must contain a positively-worded policy on rural exception sites for a scheme to qualify as an exception. The deletion of policy NE10(f) from the Pre-Submission Plan removes the required positively-worded policy, implying that this exception no longer applies in Brentwood's Green Belt.

This change in emphasis is reinforced by discussions with officers, who have confirmed that it is the Plan's intention, as modified, to preclude rural exception sites in the Green Belt, on the basis that the housing allocations in the Plan will meet the Borough's affordable housing needs in full over the plan period, through the mechanism of each site contributing a proportion of affordable housing. Such an approach is fundamentally flawed, for two reasons:

* house prices in Brentwood are high and rising, pricing many local people out of the housing market, as Strategic Housing Market Assessment Part 2 demonstrates. It is therefore unwise to assume that housing need can be met in full over the plan period, without the fallback option of rural exception sites, in the event that unmet housing need arises over the plan period.

* the allocated housing sites are located predominantly in and around the town of Brentwood, with smaller allocations in the larger villages. By contrast, the smaller villages are spread throughout the borough, in many cases some distance away from allocated housing sites. The aim of the NPPF is to meet local housing needs where they arise, in order to bolster smaller settlements and ensure that local residents can remain in their village rather than being forced to move elsewhere. It runs completely contrary to government advice to plan to meet rural housing need only in the largest settlements in the borough.

As drafted, therefore, the main modifications are in conflict with paragraph 78 of the NPPF, and the Plan is unsound.

In light of covid we need to consider if green belt for building is really necessary. People are moving further afield, and We are edging further to London with the removal of green belt. It’s there for a reason. if we continue to keep giving up land because of meeting housing numbers there will be no village feel left.

R25 and R26 are Greenbelt. The exceptional circumstances tests for building on Greenbelt have not been satisfied. Blackmore is remote, does not have adequate local public transport (buses), is a distance from the nearest train stations, and the roads that serve the village are narrow (often single) lanes. This modification is unsound on the basis that it unjustifiably releases Greenbelt, and is not positively prepared.

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MM107 - The proposed amendment to allocate 40 homes to this site (R25) represents an arbitrary number not supported by any objectively assessed housing needs investigation. Further, being within a Critical Drainage Area, and Blackmore already experiencing regular instances of flooding on its highways and (less) regular flooding of the village centre, no increase in surface run-off should be allowed; the only way to prevent this is to retain this green field site in its current undeveloped state. Vehicular access to the site via either Redrose Lane or Nine Ashes Road is inappropriate: Redrose Lane due to its limited width and popularity with walkers and horse-riders; Nine Ashes Road due to the proximity of any entry point to the village Primary School entrance. The village of Blackmore has been incorrectly categorised as a Category 3 settlement. Being a small rural village with poor public transport, limited shops (it has no local shopping parade), limited job and amenity facilities, where residents rely on nearby settlements for services (e.g. it has no health facilities), it should be classified as a Category 4 settlement and development of this green field site should not be permitted. No new homes should be allocated to site R25.

MM108 - The proposed amendment to allocate 30 homes to this site (R26) represents an arbitrary number not supported by any objectively assessed housing needs investigation. Further, being within a Critical Drainage Area, and Blackmore already experiencing regular instances of flooding on its highways and (less) regular flooding of the village centre, no increase in surface run-off should be allowed; the only way to prevent this is to retain this green field site in its current undeveloped state. Vehicular access to the site via either Orchard Piece, Fingrith Hall Lane, or Redress Lane is inappropriate: Orchard Piece due to dangers arising from the volume of additional traffic through an already established housing estate; Fingrith Hall Lane due to the proximity of any entry point to existing roads joining Fingrith Hall Lane; and Redrose Lane due to its limited width and popularity with walkers and horse-riders. The village of Blackmore has been incorrectly categorised as a Category 3 settlement. Being a small rural village with poor public transport, limited shops (it has no local shopping parade), limited job and amenity facilities, where residents rely on nearby settlements for services (e.g. it has no health facilities), it should be classified as a Category 4 settlement and development of this green field site should not be permitted. No new homes should be allocated to site R26.

MM81 – Neither the “exceptional circumstances” nor “very special circumstances” have been demonstrated with regards to sites R25 and R26. Without an objectively assessed housing needs investigation, it cannot be proven that the development of sites R25 and R26 are not inappropriate.

MM78 – The continued inclusion of sites R25 and R26 in the document is in contravention to the stated requirement for new developments “to avoid areas of flood risk”. Recent and historical events prove that Blackmore’s highways and village centre are susceptible to flooding – a situation which would not be improved by the allocation of houses to these sites. Indeed the development of sites R25 and R26 would remove significant areas of natural drainage and increase surface run-off, thus increasing the "flood risk elsewhere", as they are uphill of the village centre.

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MM1/MM2
Blackmore village is very remote. It is a long way from towns and railway stations, the bus service is almost non-existent and the lanes are too narrow and dangerous to walk. It is unsuitable for commuting and the car is the only way to travel if you live in Blackmore. More houses would therefore result in more vehicles, congestion and pollution (70 houses would result in approximately 140 more vehicles in the village). This goes against BBC’s objectives and the Government’s aim for reducing unnecessary car journeys.
The loss of 2 large green belt fields to houses would result in the loss of homes for foxes, hedgehogs, voles and badgers, amongst others.

MM5
Blackmore is not a class 3 village like Doddinghurst, it should be recognised as a class 4 village. Blackmore has 1 teashop, 1 small shop and a part time hair salon so cannot be classified the same as larger villages such as Kelvedon Hatch and Doddinghurst who have a parade of shops, a lot more houses, are closer to towns and stations, and have far better and safer road links.

MM78
Blackmore has always had a problem with flooding, and concreting over 2 large fields will just compound the situation. The idea of digging 2 ponds on each field is pointless; when there is heavy rain the water table is at ground surface level. With extreme weather becoming more frequent, the flooding situation will only get worse.

MM81
I do not think the Exceptional Circumstances Test was carried out with any thoroughness. If it had been it would have identified, and included in the LDP, the brown field sites in Stondon Massey and Red Road Lane, Blackmore.

MM107/108
Due to the exceptionally high level of concerns by most of Blackmore’s residents, BBC reduced the number of houses to be built from 70 to 50. For the inspector to increase the number back to 70 begs the question why ask the public for a response to the LDP if you are then going to ignore that response?

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!

MM1/MM2
The village of Blackmore does not have the capacity to copy with so many more houses. Public transport is very minimal, with only an infrequent bus service that goes to other nearby villages. There is no train station and the roads are narrow with many blind bends which makes them dangerous to walk. The roads them selves are in desperate need of repair, and will only get worse with the increase in traffic that 70 more houses will make. It is reasonable to assume each house will have at least two cars, which means around 140 more cars will be travelling the roads everyday, increasing congestion and pollution. This goes against BBC’s objectives and the Government’s aim for reducing unnecessary car journeys. That is not to mention the loss of the two greenbelt fields, which would mean a loss of homes for the local wildlife.

MM5
Blackmore only has a small local shop, a tea shop and a part time hair dressers so should be recognized as a class 4 village. It is nothing like the nearby villages of Kelvedon Hatch and Doddinghust, which are class 3. Aside from having many more shops and amenities, their roads are in much better condition and are much safer.

MM78
Flooding is always an issue in Blackmore, with very little (if anything at all) being done to prevent it. The floods have become more frequent in recent years, occurring multiple times during the year, and with the worsening climate crisis and extreme weather conditions, this situation will only worsen. This development would see two fields concreted over which will make the situation even worse. I understand there are plans to add two ponds on each field, which just seems bizarre, as this will not help in any way. The water table is at ground level so heavy rainfall would be a big problem.

MM81
I do not think the Exceptional Circumstances Test was carried out thouroughly, overwise it would have identified, and included in the LDP, the brown field sites in Stondon Massey and Red Rose Lane, Blackmore.

MM107/108

After an outcry from the residents of Blackmore, the BBC decreased the planned number of homes from 70 to 50. However this has since been put back to 70 again. I don’t know why we were asked for a public response for it to then be ignored. It feels like a very sneaky and underhanded tactic used to ignore the valid and real concerns put forward by the people of Blackmore, who will be the ones to suffer should this proposed plan go ahead.

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