Object

Representation ID: 30219

Received: 30/11/2021

Respondent: Mrs Jane Lodge

Legally compliant? Not specified

Sound? No

Not happy with 70 to 50 and ignoring the views of residents.

Object

Representation ID: 30222

Received: 30/11/2021

Respondent: Mrs Brenda Leigh

Legally compliant? Not specified

Sound? No

The proposed developments in Blackmore would fall within a critical drainage area. Run-off from so many new houses with their concrete surrounding, hard surfaces would increase the speed of flooding in the centre of the established village below. May there not be overflowing sewage issues too. We have been told that climate change may cause more frequent storms. Having witnessed the speed of surface water flowing across fields, I have great concerns for our church, a centre of village life, in future years.
I believe that a number of new houses have been erected in recent years, so perhaps a more gradual approach should be adopted in a pastoral area of Green Belt land.

Object

Representation ID: 30242

Received: 01/12/2021

Respondent: Mr Marc Cohen

Legally compliant? Not specified

Sound? No

BBC listened and understood the local issues relating to Blackmore and reduced the number of new dwellings from 70 to 50. The inspectors seem to have ignored this and increased the number back to 70. This is a display or either ignorance or laziness that they refuse to investigate specific sites.

Object

Representation ID: 30246

Received: 01/12/2021

Respondent: Mr Martin Clark

Legally compliant? Not specified

Sound? No

Development in Blackmore is contradicting with:
MM19 – States optimise use of Sustainable Drainage Systems. Fields being built on in an area known to flood risk.
MM27 – States transport impacts should be mitigated. Difficult in a remote village with few public transport links
MM51 – States Conservation areas to be protected. Development in Blackmore will greatly increase the risk of flooding in the Conservation Area.
MM74 – States Protecting and enhancing the natural environment.
MM75 – States ‘so far as possible retain existing trees and hedgerows.
MM78/81 – Flood Risk. R25 and R26 often flood with even average rainfall.

Object

Representation ID: 30248

Received: 01/12/2021

Respondent: Mr Martin Clark

Legally compliant? Not specified

Sound? No

MM107 – Increase R25 from 30 to 40 houses. Why?

Object

Representation ID: 30300

Received: 02/12/2021

Respondent: Mrs Janet Jacob

Legally compliant? Not specified

Sound? No

The houses have been reduced by BBC because of the major concerns of our residents and to raise it back to 70 means that you are just ignoring the response given in respect to the LDP.

Object

Representation ID: 30307

Received: 02/12/2021

Respondent: Mr Steven Jacobs

Legally compliant? Not specified

Sound? No

Houses have reduced from 70 to 50 due to concerns of Blackmore residents. For the Inspector just to change the goal posts back to 70 totally ignores the public opinion in response to the LDP.

Object

Representation ID: 30317

Received: 02/12/2021

Respondent: Ms Annie Jackson

Legally compliant? Not specified

Sound? No

Houses were reduced from 70 to 50 by BBC due to high level of concerns by majority of Blackmore residents. For the Inspector to just increase back to 70 ignores the point of asking for public response to the LDP.

Object

Representation ID: 30334

Received: 02/12/2021

Respondent: Mr Ben Holmes

Legally compliant? Not specified

Sound? No

Houses were reduced from 70 to 50 by BBC due to high level of concerns by majority of Blackmore residents. For the Inspector to just increase back to 70 ignores the point of asking for public response to the LDP.

Object

Representation ID: 30370

Received: 03/12/2021

Respondent: Susan Harris

Legally compliant? Not specified

Sound? No

Houses were reduced by BBC from 70 to 50 due to high level concerns for Inspector to increase back to 70 ignores the point of asking for public response.

Object

Representation ID: 30383

Received: 03/12/2021

Respondent: Mr Michael Juniper

Legally compliant? Not specified

Sound? No

There are areas of brownfield sites in the vicinity surely they should be considered before spoiling, which is at the moment a pleasant attractive village on the outskirts of Brentwood. I would like to point out there has already been a housing estate built at the other end of Fingrith Hall Road, Epping Forest Council, and those residents and their cars are already adding to the dangerous traffic chaos.

Object

Representation ID: 30388

Received: 03/12/2021

Respondent: Mr John Lester

Legally compliant? Not specified

Sound? No

MM107, B1, (a), page 237. Red Rose Lane is a lane with rural bends, access from the site would be a traffic hazard as visibility would be limited. It would therefore be a danger to walkers, runners, cyclists etc. Based n 4 cars per 3 bedroom house that it potentially a total of 160 cars emerging onto a lane. R25 is in a critical drainage area and covering the fields could increase surface water causing further danger. To provide vehicular access to Nine Ashes Road would be just as dangerous as stipulated above.

Object

Representation ID: 30397

Received: 03/12/2021

Respondent: Mrs Danielle Cohen

Legally compliant? Not specified

Sound? No

BBC listened and understood the local issues relating to Blackmore and reduced the number of new dwellings from 70 to 50. The inspectors seem to have ignored this and increased the number back to 70. This is a display or either ignorance or laziness that they refuse to investigate specific sites.

Object

Representation ID: 30413

Received: 03/12/2021

Respondent: Ms Patricia Taylor

Legally compliant? Not specified

Sound? No

Contradicts with MM14C. The sewerage system for Blackmore is over-capacity, this was not considered before R25 and R26 were allocated. Any considerable development within the village, as proposed, would only add to the existing flood risk and drainage problems. The source of the River Wid is just North of Blackmore and regularly floods Red Rose Lane, which has become impassable on 10 occasions over the period Dec-Feb 2021. No mitigation measures could cope and to use this lane as an access point is unsustainable. It is narrow, unlit and without pathways and not a suitable route for emergency vehicles .

Object

Representation ID: 30416

Received: 03/12/2021

Respondent: Miss Laura Harris

Legally compliant? Not specified

Sound? No

Increasing from 50 to 70 is a 40% increase and they were reduced to lower figures as BBC accepted some of residents views about unsuitability of site.

Object

Representation ID: 30418

Received: 03/12/2021

Respondent: Ms Patricia Taylor

Legally compliant? Not specified

Sound? No

An increase in the number of houses proposed to around 70 (and no doubt the developers will press for more)the more the pressure on the village and the flooding and drainage situation increases. NPPF guidelines should not be manipulated the put a village, which is rich in history and is very rural and unique, at risk from all the fall-out from such development. Blackmore has one small Co-op and two public houses, so how it can be classed as a Category 3 Settlement is very questionable. We have no parade of shops (as in Doddinghurst for instance) and we certainly do not have a travel agency!!!

Object

Representation ID: 30423

Received: 03/12/2021

Respondent: Ms Patricia Taylor

Legally compliant? Not specified

Sound? No

Contradicted with SO2 and SO3. Blackmore has very few ‘walkable streets’. Most are narrow dark lanes with no pavements. There are limited bus services. This would add140 cars being used on the badly maintained roads. Sustainable Communities does not automatically come from building houses on green belt. In fact the income of the village could be affected in a negative manner as many people visit the village. A housing needs assessment has not been undertaken. Who will be living in these houses? Not local people, so how this will add to the rural economy is questionable.

Object

Representation ID: 30431

Received: 03/12/2021

Respondent: Mrs Patricia Moulton

Legally compliant? Not specified

Sound? No

The house numbers were reduced from 70 to 50 by Brentwood Borough Council due to high levels of concerns by Blackmore residents. Why ask for the public response to the LDP if we are just going to be ignored and the number of houses is increased back to 70.

Object

Representation ID: 30433

Received: 03/12/2021

Respondent: Mr Kevin Wood

Legally compliant? No

Sound? No

The proposal to increase the proposed number of dwellings on sites R25 and R26, where in both instances the numbers had previously been reduced as the original number was not considered appropriate seems nonsensical. These proposals to build on greenfield sites on what is potentially good quality agricultural land also make no sense. The proposed developments are on the edge of, and on higher ground than, a known flood risk area. Building on the existing greenfield areas is only going to increase the flood risk to the houses within the flood zone.
Red Rose Lane, which is one of the proposed access was flooded and impassable on a number of occasions during the period of the original consultation. The alternative suggestions now added for R26 of access via Fingrith Hall Lane or Orchard Piece are also not viable as the access from Fingrith Hall Lane would require a new road either on or very close to the existing junction between Red Rose Lane and Fingrith Hall Lane, and Orchard Piece is a cul-de-sac and therefore access from there would create an unreasonable amount of disruption for existing residents of that road.

Object

Representation ID: 30434

Received: 03/12/2021

Respondent: Mr Malcolm Hurford

Legally compliant? Not specified

Sound? No

The plan for vehicular access via Red Rose Lane is inherently flawed as this is a narrow lane which will not tolerate increased traffic giving rise to risk to life and limb to pedestrians, cyclists and horse riders who regularly use this narrow lane. There are no pathways or street lighting which further increases the risk when introducing more vehicles to the lane. It is acknowledged as a critical drainage area in the document but there is little depth to the mitigation required the developer. Blackmore is in a critical drainage area and sustainable drainage systems will not provide a workable solution, green fields clearly provide a more effective solution.

Object

Representation ID: 30446

Received: 03/12/2021

Respondent: Mr Edward Turner

Legally compliant? Not specified

Sound? No

The reason for selecting Blackmore for 70 new dwellings needs to be reviewed. BBC need to be transparent and advise how this decision was arrived as Blackmore does not meet any of the strategic BBC tests or meet government guidelines. Blackmore does not fit the criteria of class 3 village, needs to be reviewed by BBC or independent body before the plan goes any further. Environment Agency needs to be involved & their recommendations acted upon. There is no evidence that an exceptional circumstances test was carried out to allow the release of Green Belt that fits government guideline.

Object

Representation ID: 30449

Received: 03/12/2021

Respondent: Mr Luke Holmes

Legally compliant? Not specified

Sound? No

Houses were reduced from 70 to 50 by BBC due to high level of concerns by majority of Blackmore residents. For the Inspector to just increase back to 70 ignores the point of asking for public response to the LDP.

Object

Representation ID: 30477

Received: 04/12/2021

Respondent: Mr Ken Holmes

Legally compliant? Not specified

Sound? No

Houses were reduced from 70 to 50 by BBC due to high level of concerns by majority of Blackmore residents. For the Inspector to just increase back to 70 ignores the point of asking for public response to the LDP.

Object

Representation ID: 30479

Received: 04/12/2021

Respondent: Mrs Janice Holbrook

Legally compliant? Not specified

Sound? No

Omission v Commission
The LDP process is open to manipulation at various different stages and in our particular case this has led to a gap existing that purportedly can't be addressed at all.
The normal process for all LDP's is for the Council to
1. Carry out a housing requirement analysis (or use an existing one)
2. Search for sites that could deliver the requirements at 1 above.
3. Carry out a suitability and sustainability analysis to select the most appropriate of those sites to be put into the LOP, and publish a draft plan
4. Carry out a Public Consultation to refine the sites in the plan and other aspects
5. Create a revised Plan incorporating necessary changes
6. If too much opposition still exists or the revised plan has other potential issues a Government inspector is appointed to carry out a further public enquiry and propose amendments
7. The Council has a Public Consultation to collect views on any required amendments.

In this case:
1. No analysis was carried out or available (apart from the BVHA Housing Needs Assessment for Blackmore which was ignored)
2. The list of sites was dictated totally by those Developers who submitted an application
3. No suitability or sustainability assessment was carried out on the developer's site options. Although at Reg 18 stage a large site was removed that was appropriate, and replace by 2 sites that were not.
4. Major issues were identified by the public with the Draft Plan, including over 300 responses relating to Blackmore. Council view was that Reg 19 was not able to consider flaws that were created in Reg 18.
5. The Council refused to consider "Major" changes (such as removing an unsuitable site). That would shine an embarrassing light on their approach to date. They choose to only make "Minor" changes (such as reducing the number of dwellings on inappropriate sites where they were receiving massive public criticism). Even admitting the site choice was down to the previous administration and they would not have included at least 2, as they realised that they were unsuitable and unsustainable.
6. At the Public Enquiry, the Inspectors would not accept any evidence on certain aspects e.g. if sites were appropriate, or conduct of the Council in creating the list of sites
7. The Council has tried to limit public responses to only those items that the government inspectors have changed.

Object

Representation ID: 30480

Received: 04/12/2021

Respondent: Mr Colin Holbrook

Legally compliant? Not specified

Sound? No

The Plan is unsound as not consistent with NPPF in various aspects
Sustainable Development
Under NPPF para 16(a) a plan must be prepared with the objective of contributing to the achievement of sustainable development. The plan fails this objective when it contains sites (i.e. R25 & R26) that will be subject to, or exacerbate, flooding. This is confirmed in Para 159 which requires developments to be made safe for its lifetime without increasing flood risk elsewhere. There is no evidence to support that this policy requirement can be met as no site assessment has been carried out on any sites in the LDP and certainly not for R25 & R26. This has been specifically pointed out at every stage of the LDP flawed process. To seek to make corrections and after the event condition is poor planning, as such should have been considered and dealt with prior to allocation (i.e. there should be no allocation if there is an issue unless clear evidence that it is a nonissue or can be overcome by a specified method).
Government Inspectors in other locations have required a higher level of sustainability to release Green Belt land where the sites were considered unsustainable, due to "lack of access to sustainable modes of transport" and/ or "reducing private car usage and establishing better public transport". These issues are a very significant problem for R25 & R26 even before any additional development takes place, but has not been addressed by the LOP nor the Inspectors (unlike their counterparts elsewhere in the country).
Green Belt
Altering the boundaries of the existing green belt must be done through new or updated local plans and "exceptional circumstances" are required to justify this. Before green belt boundaries are redrawn, an
authority must demonstrate that it has "examined all other reasonable options for meeting its identified need for development", including making use of brownfield land, and exploring whether neighbouring authorities can help meet its needs. This can't be demonstrated as BBC has failed to examine other options e.g. : It did not consider including a brownfield site in Blackmore which has subsequently been successfully developed after support from BVHA; it did not explore potential for large development in Epping Forest which sits on the borough borders and directly negatively impacts Blackmore
infrastructure, facilities and services without compromising anything for Epping Forest.
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 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 (i.e.
for housing/ housing supply) do not need to be met by strategic policies where protective policies of the NPPF (i.e. as identified in footnote 7) provide a strong reason for restricting the overall scale etc of development or any adverse impacts of meeting housing need in full would significantly and demonstrably outweigh the benefits when assessed in the round.
Sites require" exceptional circumstances" to justify Green Belt release. Whilst site unsuitability is not sufficient reason alone to keep it in Green Belt, it is equally true that site suitability for development (housing) is not sufficient reason alone to justify Green Belt release. More is needed. This all comes back to, are there areas where release of the Green Belt is more apt? - eg poorer quality Green Belt land exists, or there is brownfield land within the Green Belt that should be released first etc.

Object

Representation ID: 30484

Received: 04/12/2021

Respondent: Mrs Sara Harris

Legally compliant? Not specified

Sound? No

BBC recognised the error of including R25 & R26 and went as far as partially mitigating the situation by reducing the number of houses. The Inspectors showing total ignorance of local problems and refusing to look at, or judge any individual sites blindly propose increasing the numbers back to an arbitrary National standard and increased the total number to 70 houses on these sites.
This makes the a bad situation worse and renders the sites (and therefore the Plan whilst they remain) unsustainable.

Object

Representation ID: 30490

Received: 04/12/2021

Respondent: Mr James Harris

Legally compliant? Not specified

Sound? No

Also Chris Hossack visited Blackmore advised that over 50% of entire objections to development in LDP were from Blackmore. He advised no point asking for residents views if you are going to ignore. So he reduced number of houses from 70 to 50. The Inspector who has no local knowledge increased back to 70 which defeats whole point of consultations.
Blackmore has 354 dwellings, BBC is proposing additional 70 plus 12 already built in 2021, in Red Rose Lane total 82, which is a 23% increase no village can take such as increase without serious detrimental effects on its infrastructure.

Object

Representation ID: 30497

Received: 04/12/2021

Respondent: Mrs Lucille Foreman

Legally compliant? Not specified

Sound? No

Both sites are located in a critical drainage area, there is
significant water run of and frequent flooding from the River Wid. The increase in housing numbers from around 50 to around 70 means that with the greater the number the more the risk factors increase: flooding, drainage capacity, infrastructure issues (roads, schools, health services). Brentwood Borough Council understood this, hence the Focussed Consultation of November 2019. The NPPF guidelines should be forced to retrofit a flawed strategy in a historic, unique, remote, rural village,
Category 3 Settlement - there is no parade of shops, there is no travel agency.
There is one small Co-Op store for day-to-day needs, together with a hairdressers, two pubs, and a teashop (What village in England does not have a tea shop or a
pub).
MM116 Appendix 2
SO2 Sustainable Means of Travel and Walkable Streets - 70 extra homes means more cars, more journeys, more congestion in the village centre and more pollution. Many of the lanes in Blackmore are not safely "walkable" as they are too narrow with no pavements.
SO3 - Deliver Sustainable Communities - building extra homes will not create any employment opportunities, support the rural economy or enhance community facilities. However, other "zombie" villages nearby do need this regeneration.
Strategic thought needs to be given to the sustainability of villages in the north of the Borough. In Policy MG06 it is stated that a Housing Needs Assessment needs to be
undertaken before the next LDP is constructed in the short term, begs the question "why is this not done first" before Blackmore is selected.
With regard to other reference points in the MM paper.
Page 3 - promoting sustainable mobility - this cannot be ticked by building in Blackmore
Page 4 creating environmental net gain - building on Green Belt in Blackmore will destroy the significant wildlife that current inhabits the R25 and R26 green fields.
Page 54/56 promoting improved choices in modes of transport - this underlines the paradox of Brentwood Borough Council's strategy versus its developer led decision to promote building in Blackmore.
Sustainability Appraisal September 2021
Page 5 - community and wellbeing - the comments in this paragraph underline that Brentwood Borough Council has zero understanding of the community that has been
created by villagers of Blackmore over the decades, and it is appalling that and not acceptable that BBC think that concerns are not significant. The work done with
Stonebond on a brownfield site in Blackmore shows that we are not just "Nimbys".
Page 8 Reasonable Alternatives - in July 2018 Redrose Farm was presented as a reasonable alternative a brownfield site, which was subsequently ignored and then
used as a "windfall" site, and pressed ahead with developer led destruction of the Green Belt.
Page 9 - Omission Sites - Honeypot Lane (a long-standing "included" site) was voted out of the LDP due to site access issues and being on Green Belt and Blackmore was voted in , despite even more difficult access issues and being Green Belt - where is the consistency and strategy.
In a village of c.350 dwellings to add c.70 (an c.20% increase) it is quite clear that the decision to build in Blackmore is developer led and opportunistic and does not "tick the boxes in Brentwood Borough Council's own limited strategic thinking.
In conclusion, it would appear that the decision to use Green Belt in Blackmore is developer led and the only consideration being given to the amount of profitability
there is to be made. No consideration, has been given to the concerns of the residents or the findings of professionals concerning drainage, flooding, etc.

Object

Representation ID: 30503

Received: 04/12/2021

Respondent: Mr Colin Foreman

Legally compliant? Not specified

Sound? No

Both sites are located in a critical drainage area, there is
significant water run of and frequent flooding from the River Wid. The increase in housing numbers from around 50 to around 70 means that with the greater the number the more the risk factors increase: flooding, drainage capacity, infrastructure issues (roads, schools, health services). Brentwood Borough Council understood this, hence the Focussed Consultation of November 2019. The NPPF guidelines should be forced to retrofit a flawed strategy in a historic, unique, remote, rural village,
Category 3 Settlement - there is no parade of shops, there is no travel agency.
There is one small Co-Op store for day-to-day needs, together with a hairdressers, two pubs, and a teashop (What village in England does not have a tea shop or a
pub).
MM116 Appendix 2
SO2 Sustainable Means of Travel and Walkable Streets - 70 extra homes means more cars, more journeys, more congestion in the village centre and more pollution. Many of the lanes in Blackmore are not safely "walkable" as they are too narrow with no pavements.
SO3 - Deliver Sustainable Communities - building extra homes will not create any employment opportunities, support the rural economy or enhance community facilities. However, other "zombie" villages nearby do need this regeneration.
Strategic thought needs to be given to the sustainability of villages in the north of the Borough. In Policy MG06 it is stated that a Housing Needs Assessment needs to be
undertaken before the next LDP is constructed in the short term, begs the question "why is this not done first" before Blackmore is selected.
With regard to other reference points in the MM paper.
Page 3 - promoting sustainable mobility - this cannot be ticked by building in Blackmore
Page 4 creating environmental net gain - building on Green Belt in Blackmore will destroy the significant wildlife that current inhabits the R25 and R26 green fields.
Page 54/56 promoting improved choices in modes of transport - this underlines the paradox of Brentwood Borough Council's strategy versus its developer led decision to promote building in Blackmore.
Sustainability Appraisal September 2021
Page 5 - community and wellbeing - the comments in this paragraph underline that Brentwood Borough Council has zero understanding of the community that has been
created by villagers of Blackmore over the decades, and it is appalling that and not acceptable that BBC think that concerns are not significant. The work done with
Stonebond on a brownfield site in Blackmore shows that we are not just "Nimbys".
Page 8 Reasonable Alternatives - in July 2018 Redrose Farm was presented as a reasonable alternative a brownfield site, which was subsequently ignored and then
used as a "windfall" site, and pressed ahead with developer led destruction of the Green Belt.
Page 9 - Omission Sites - Honeypot Lane (a long-standing "included" site) was voted out of the LDP due to site access issues and being on Green Belt and Blackmore was voted in , despite even more difficult access issues and being Green Belt - where is the consistency and strategy.
In a village of c.350 dwellings to add c.70 (an c.20% increase) it is quite clear that the decision to build in Blackmore is developer led and opportunistic and does not "tick the boxes in Brentwood Borough Council's own limited strategic thinking.
In conclusion, it would appear that the decision to use Green Belt in Blackmore is developer led and the only consideration being given to the amount of profitability
there is to be made. No consideration, has been given to the concerns of the residents or the findings of professionals concerning drainage, flooding, etc.

Object

Representation ID: 30511

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

Deletion of (b), the ridiculous 'minimum 25% reserved for locals etc' clause, was inevitable to all bar the Councillors who voted in favour of it.
- What did not become clear during the Hearings, in spite of the very good questions posed by Mrs Wright, is how this clause came to be there in the first place. It certainly did not come from anything akin to a 'Village housing
need', it was simply proposed as a means of stifling any proper debate about the late inclusion of R25 and R26 into the Plan, at the ECM in November 2018. As BBC's own Barrister summed it up nicely at the Hearing on 03.02.2021, it was 'embarrassing'.
- This is mentioned, as it is about time the true context as to why these (previously long-standing omission) sites suddenly and unexpectedly became 'included'....and at the same time other previously 'included' sites became 'omission' sites, and could not therefore be discussed at the Hearings. Where is / was the strategic thinking?
- Access to R26 and R26. Various issues to flag up, including: Redrose Lane is wholly inadequate for this purpose, and ECC Highways need to look into this matter again. It is a narrow, single track lane, with no pavements and no accessible grass verge. Quite apart from the frequent flooding, there is a real danger to walkers; cyclists; horse-riders; and wildlife, that frequent the lanes. Red rose Lane is inadequate for existing vehicle users, including lorry access restrictions, let alone what will happen if another (around) 70 houses are built.
- Orchard Piece as an alternative access road (R26): Presumably that has been added due to the realisation of the flooding and other drawbacks identified along Redrose Lane? Orchard Piece is a quiet, residential, cul­
de-sac, and will be totally unsuitable for an additional several hundred traffic movements per day, especially given the number of young children who live and play in the Close.
- 'A defendable Boundary'? Not really, in fact there are already around 100 houses and mobile homes to the north of this Lane, plus the (currently illegal) Travellers' camp.
- Proposed changes to site allocations (back up to around 70 from around 60): the Sustainability Appraisal comments on page 5, 'Community and Wellbeing' are a massive understatement and further evidence of the
lack of knowledge and understanding of our community. There are currently 354 homes in Blackmore, add 70 equals a 20% increase, plus all the housing that EFDC has had built on the Village borders. It comes back to the points raised earlier about Village resources and infrastructure - it is not sustainable development. In fact, it would destroy the sustainable community that already exists, and which has been built over many decades. It would have a serious detrimental impact on: lives; resources; infrastructure etc. MM1 and MM2 'rules' need to be applied here.