Object

Representation ID: 30510

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

NPPF (para 11) says that the titled balance (i.e. in favour of granting development where there is no up-to-date Local Plan) is disapplied where there are clear policies to reject. Footnote 7 to para 11 confirms that not only Green Belt, but also 'areas at risk of flooding' are some exceptions -­ R25 and R26 (currently) fall within both. Taking this further, para 11(b) confirms that objectively assessed needs (for housing and housing supply) do NOT need to be met by strategic policies where protective policies of the NPPF (as identified in footnote 7) provide a strong reason for restricting the overall scale of development, or any adverse impacts of meeting housing needs in full would significantly and demonstrably outweigh the benefits when assessed in the round.
- Turning to the existence (or absence) of 'exceptional circumstances' to justify Green Belt release (Solihull v Gallagher), site suitability for development is not sufficient reason alone to justify Green Belt Release. These sites (R25 and R26) are quality arable land, added to which Brentwood BC chose to ignore the availability/ suitability of the Brownfield site at Redrose Farm. This was flagged by us to BBC in July 2018, i.e. well ahead of Reg 19 decisions. The 12 houses now constructed on the brownfield site (which BVHA supported, and helped tailor to the needs of this Village - see letter from Stonebond, attached), now sharpens the focus on other concerns previously highlighted in our various Reps, e.g. Village infrastructure and resources......issues that should have been taken into account before allocating a further (around) 70 houses. BBC has simply taken the "brownfield 12" as windfall.
- In any event, 'exceptional circumstances' have not been adequately demonstrated, for example: in paragraph 8.81, 'good connectivity' is quoted. Again, Blackmore is remote. no main roads, mainly narrow lanes, inadequate bus services, and a long way from any of the Borough's main centres and railway stations.
- In the absence of BBC having undertaken a robust, strategic approach to the Green Belt and the housing needs I future sustainability of all of the villages, it chose instead to 'call for land' and acquiesce to pressure from developers...a complete volte-face from its stated position in 2016 when, and I quote, 'we have told the developers that R25 and R26 are unsuitable for development'. Had it actually thought strategically, BBC would have made better decisions, in line with the Council's own Strategic Objectives.
- There are clearly other, much larger settlements (with 'parades of shops'), also surrounded by Green Belt, with better connectivity and infrastructure / services. Doddinhurst is the best example....and with zero housing allocated.
- As proposed by BVHA, on multiple occasions, there must be a coherent strategy covering all the villages in the north of the Borough, rather than this random, developer-led approach that has been adopted thus far.

Object

Representation ID: 30516

Received: 04/12/2021

Respondent: Mrs Ann Rigby

Legally compliant? Not specified

Sound? No

No evidence has been provided that an exceptional circumstances test was carried out to allow the release of the Green Belt land for speculative development.

Object

Representation ID: 30521

Received: 04/12/2021

Respondent: Mr Peter Ryan

Legally compliant? Not specified

Sound? No

I do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane and Stondon Massey would have been identified and included in LDP. Houses were reduced from 70 to 50 by BBC due to high level concerns by majority of Blackmore residents. For the Inspector to just increase back to 70 ignores the point of asking the public responses to the LDP.

Object

Representation ID: 30528

Received: 06/12/2021

Respondent: Mrs Margaret Roast

Legally compliant? Not specified

Sound? No

There are not exceptional reasons for removing the two sites [R25 and R26] from green field status. Which is good quality farmland and currently helps to protect the village from some of the effects of water runoff.

Object

Representation ID: 30533

Received: 06/12/2021

Respondent: Ms. Donna Toomey

Legally compliant? Not specified

Sound? No

BBC did not carry our exceptional circumstances test, otherwise they would have identified available brownfield sites, 12 houses were built on such a site in 2020/21 in Red Rose Lane Blackmore

Object

Representation ID: 30538

Received: 06/12/2021

Respondent: Mrs Joanne Ryan

Legally compliant? Not specified

Sound? No

Do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30546

Received: 06/12/2021

Respondent: Mrs Joan Westover

Legally compliant? Not specified

Sound? No

What are the 'exceptional circumstances' that says R25 and R26 should be released from green belt? There are ancient hedgerows that should be preserved.

Object

Representation ID: 30559

Received: 06/12/2021

Respondent: Mr John Richardson

Legally compliant? Not specified

Sound? No

I do not believe releasing the fields R25 and R26 qualify as “exceptional Circumstances”.
Not including the Stonebond development in Redrose Lane and the brownfield site in Stondon Massey in the LDP was a monumental blunder which highlights the incompetence of BBC.
The property in Ingrave Road, Brentwood (old perguet garage) has been boarded up for over 10 years. It is in residential area could have contributed positively to the LDP, there are likely other sites that could have been found and included in the LDP. The Council have selected the ‘soft’ option which is developer led sacrificing Green Belt and opening the flood gates for the area.

Object

Representation ID: 30568

Received: 06/12/2021

Respondent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

- The 'exceptional circumstances' test This has not been adequately demonstrated, for example: in paragraph 8.81, 'good connectivity' is quoted. Again, Blackmore is remote. no main roads, mainly narrow lanes, inadequate bus services, and a long distance from any of the Borough's main centres and railway stations.
- Has there been a robust, strategic approach to the Green Belt (i.e. as opposed to the so called call for land and then acquiescence to pressure from developers very late in the process Reg 18) The you would be making better decisions in line with your own strategic objectives.
- There are clearly other, much larger settlements surrounded by Green Belt, with better connectivity and services. Doddinhurst for example no housing allocated.
- As proposed by BVHA, on multiple occasions, there ought be a coherent strategy covering all the villages in the north of the Borough, rather than this random approach adopted in this plan.

Object

Representation ID: 30576

Received: 06/12/2021

Respondent: Mrs Alison Ratcliffe

Legally compliant? No

Sound? No

I cannot see any ‘exceptional circumstances’ in the case of Blackmore.
I was in attendance at the BBC public meeting in 2016, when the following statement was made by the project team ‘we have told the developers that these sites (known now as R25 and R26) are not suitable’. That was the correct decision. At Reg 18 and 19 the wrong decision was made.

Object

Representation ID: 30580

Received: 06/12/2021

Respondent: Mr Stuart Townsend

Legally compliant? Not specified

Sound? No

Justification of the release of two green belt land sites R25 and R26 for housing development

Object

Representation ID: 30600

Received: 06/12/2021

Respondent: Mr Gary Durdant-Pead

Legally compliant? Not specified

Sound? No

Do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30606

Received: 06/12/2021

Respondent: Mrs Carol Poulton

Legally compliant? Not specified

Sound? No

There are clear reasons why the release of green field sites R25 and R26 should not be allowed. The areas (including the village centre) surrounding these sites currently experiences regular flooding and overflow of sewage into the local waterways. The addition of 70 houses would exacerbate this situation. The fields currently act as a soak away and help (not totally) the influx of run-off into the village. The fields are of grazing and arable quality, recently used to graze cattle and surrounding fields are farmed. The fields are not poor quality land. Other than to meet a numbers of dwellings needed for the borough there is not exceptional circumstances to warrant the release.

Object

Representation ID: 30613

Received: 06/12/2021

Respondent: Mrs Louise Roast

Legally compliant? Not specified

Sound? No

Don't believe the exceptional circumstances test was carried out with conviction. If it had been brownfield sites in Red Rose Lane Blackmore and Stondon Massey would have been identified in LDP.

Object

Representation ID: 30623

Received: 06/12/2021

Respondent: Mrs Natalie Walters

Legally compliant? Not specified

Sound? No

There were many more suitable sites other than Blackmore but BBC did not do the research

Object

Representation ID: 30628

Received: 06/12/2021

Respondent: Mr Nicholas Wilkinson

Legally compliant? Not specified

Sound? No

I doubt the exceptional circumstance test was carried out rigorously and fairly. This would have surely shown brownfield sites more suitable for development e.g. at Stondon Massey.

Support

Representation ID: 30632

Received: 06/12/2021

Respondent: Mr Callum Togwell

I don't believe that the exceptional circumstances test was carried out properly. Had it been completed to standard the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30638

Received: 06/12/2021

Respondent: Mr Derek Tillet

Legally compliant? Not specified

Sound? No

Do not believe that exceptional circumstances test were carried out with any conviction. If it has been brownfield sites at Red Rose Lane, Blackmore and at Stondon Massey would have been included in the LDP.

Object

Representation ID: 30653

Received: 06/12/2021

Respondent: Mrs Christine Tabor

Legally compliant? Not specified

Sound? No

Do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30659

Received: 06/12/2021

Respondent: Mr John Sears

Legally compliant? Not specified

Sound? No

The exceptional circumstances test cold not have been conducted correctly, or with any accuracy. If it had been brown field sites on Red Rose Lane Blackmore and Stondon Massey would have been identified and included in the LDP.

Object

Representation ID: 30660

Received: 06/12/2021

Respondent: Mr Frank Tabor

Legally compliant? Not specified

Sound? No

Do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30667

Received: 06/12/2021

Respondent: Mr Stephen Poulton

Legally compliant? Not specified

Sound? No

The identification of exceptional circumstances to justify the building on these two green field sites does not exist and therefore is contra to Government NPPF guidelines and the Environmental Agency advice of building on land which will exacerbate flooding in neighbouring areas. In this instance historic village of Blackmore.

Object

Representation ID: 30676

Received: 06/12/2021

Respondent: Mr Kyle Pounds

Legally compliant? Not specified

Sound? No

Do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30687

Received: 06/12/2021

Respondent: Mrs Julie Pounds

Legally compliant? Not specified

Sound? No

Do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30690

Received: 06/12/2021

Respondent: Mr Charles Snape

Legally compliant? Not specified

Sound? No

There are not exceptional reasons for removing sites R25 and R26 from Green Belt. Exceptional Circumstances Test has not been carried out by BBC.
Housing need does not need to be met where protective NPPF policies exist (like Blackmore) development should be restricted, don't increase housing density if it will cause adverse impacts (it does).
There has been no assessment of the negative impact and no seeking alternatives.

Object

Representation ID: 30711

Received: 09/12/2021

Respondent: Mrs Debbie Spencer

Legally compliant? Not specified

Sound? No

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.

Object

Representation ID: 30717

Received: 09/12/2021

Respondent: Mr Lloyd Piper

Legally compliant? Not specified

Sound? No

Do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30741

Received: 09/12/2021

Respondent: Mr Darryl Pounds

Legally compliant? Not specified

Sound? No

Do not believe the exceptional circumstances test was carried out with any conviction. If it had been the brownfield sites in Red Rose Lane, Blackmore and at Stondon Massey would have been identified and included in LDP.

Object

Representation ID: 30748

Received: 09/12/2021

Respondent: Mrs Faye Osborne

Legally compliant? Not specified

Sound? No

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.

Object

Representation ID: 30761

Received: 09/12/2021

Respondent: Mr Ronald Sanders

Legally compliant? Not specified

Sound? No

Exceptional circumstances test has not been carried out.