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 plan

Refer to attached submission . Statistical summary of responses of Survey Monkey questionnaire from residents and their families in Blackmore

Remove R25 and R26 from plan

Refer to attached submission . Statistical summary of responses of Survey Monkey questionnaire from residents and their families in Blackmore

Remove R25 and R26 from the Plan. The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i,e, R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Regs 18 and 19 and return us to the correct position as stated in January 2016.

Q2 DATA PROTECTION: All representations and personal information that you provide will be used solely for the purpose of Local Plan Consultation including sharing your personal contact details with the Planning Inspectorate and Programme Officer. Declaration: I hereby consent to share this information as above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to share my representations and personal contact details, as above, from the previous Regulation 19 Consultation in February/March 2019Declaration: I hereby consent to share this information as above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
I agree. The density on this site needs to be increased to NPPF advised levels. As you will note from the number of people who responded in February-March 2019 it seems incongruous that numbers on a Brownfield site should ever have been considered for a reduction.
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure. This is a residential area with appropriate infrastructure that will accommodate at least the original number of 75 allocated to Priests Lane.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
I agree - the site should be removed from the LDP. Blackmore Village is the most "special" of all the villages in Brentwood "Borough of villages". The infrastructure in this historic village was originally built for horse and cart travel, and modern vehicle numbers already mean that the centre of the village is severely congested. Adding an additional approximate 1,000 vehicle movements per day (adding up all proposed development in and around the village) will mean a massive risk to public safety, and the ability for existing residents to get in and out of the village. The flood risk attaching to sites R25 and R26 will be further increased by concreting over greenfield/Green Belt land.
Q8 FOCUSSED CHANGE 4 - PART B. The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. I agree - these sites are developer led and should be removed from the LDP
Q9 FOCUSSED CHANGE 4 - PART C. At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). Brentwood Council has NOT considered all/better development opportunities in and around not only this village but across the wider borough area. The LDP should not have been constructed purely around sites proposed by developers, especially when within Blackmore there is no identified housing need on the scale proposed.
Q12 FOCUSSED CHANGE 5 - PART BR26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area .A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be Reinstated
Q13 FOCUSSED CHANGE 5 -PART C SOUNDNESS and HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i.e. sites R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Reg 18 and 19 and return us the correct position as stated in January 2016.
Q15 CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
Strongly agree

Remove R25 and R26 from the Plan. The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i,e, R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Regs 18 and 19 and return us to the correct position as stated in January 2016.

Q2 DATA PROTECTION: All representations and personal information that you provide will be used solely for the purpose of Local Plan Consultation including sharing your personal contact details with the Planning Inspectorate and Programme Officer. Declaration: I hereby consent to share this information as above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to share my representations and personal contact details, as above, from the previous Regulation 19 Consultation in February/March 2019Declaration: I hereby consent to share this information as above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
I agree. The density on this site needs to be increased to NPPF advised levels. As you will note from the number of people who responded in February-March 2019 it seems incongruous that numbers on a Brownfield site should ever have been considered for a reduction.
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure. This is a residential area with appropriate infrastructure that will accommodate at least the original number of 75 allocated to Priests Lane.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
I agree - the site should be removed from the LDP. Blackmore Village is the most "special" of all the villages in Brentwood "Borough of villages". The infrastructure in this historic village was originally built for horse and cart travel, and modern vehicle numbers already mean that the centre of the village is severely congested. Adding an additional approximate 1,000 vehicle movements per day (adding up all proposed development in and around the village) will mean a massive risk to public safety, and the ability for existing residents to get in and out of the village. The flood risk attaching to sites R25 and R26 will be further increased by concreting over greenfield/Green Belt land.
Q8 FOCUSSED CHANGE 4 - PART B. The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. I agree - these sites are developer led and should be removed from the LDP
Q9 FOCUSSED CHANGE 4 - PART C. At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). Brentwood Council has NOT considered all/better development opportunities in and around not only this village but across the wider borough area. The LDP should not have been constructed purely around sites proposed by developers, especially when within Blackmore there is no identified housing need on the scale proposed.
Q12 FOCUSSED CHANGE 5 - PART BR26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area .A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be Reinstated
Q13 FOCUSSED CHANGE 5 -PART C SOUNDNESS and HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i.e. sites R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Reg 18 and 19 and return us the correct position as stated in January 2016.
Q15 CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
Strongly agree

Remove R25 and R26 from the Plan. The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i,e, R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Regs 18 and 19 and return us to the correct position as stated in January 2016.

Q2 DATA PROTECTION: All representations and personal information that you provide will be used solely for the purpose of Local Plan Consultation including sharing your personal contact details with the Planning Inspectorate and Programme Officer. Declaration: I hereby consent to share this information as above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to share my representations and personal contact details, as above, from the previous Regulation 19 Consultation in February/March 2019Declaration: I hereby consent to share this information as above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
I agree. The density on this site needs to be increased to NPPF advised levels. As you will note from the number of people who responded in February-March 2019 it seems incongruous that numbers on a Brownfield site should ever have been considered for a reduction.
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure. This is a residential area with appropriate infrastructure that will accommodate at least the original number of 75 allocated to Priests Lane.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
I agree - the site should be removed from the LDP. Blackmore Village is the most "special" of all the villages in Brentwood "Borough of villages". The infrastructure in this historic village was originally built for horse and cart travel, and modern vehicle numbers already mean that the centre of the village is severely congested. Adding an additional approximate 1,000 vehicle movements per day (adding up all proposed development in and around the village) will mean a massive risk to public safety, and the ability for existing residents to get in and out of the village. The flood risk attaching to sites R25 and R26 will be further increased by concreting over greenfield/Green Belt land.
Q8 FOCUSSED CHANGE 4 - PART B. The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. I agree - these sites are developer led and should be removed from the LDP
Q9 FOCUSSED CHANGE 4 - PART C. At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). Brentwood Council has NOT considered all/better development opportunities in and around not only this village but across the wider borough area. The LDP should not have been constructed purely around sites proposed by developers, especially when within Blackmore there is no identified housing need on the scale proposed.
Q12 FOCUSSED CHANGE 5 - PART BR26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area .A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be Reinstated
Q13 FOCUSSED CHANGE 5 -PART C SOUNDNESS and HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i.e. sites R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Reg 18 and 19 and return us the correct position as stated in January 2016.
Q15 CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
Strongly agree

Remove R25 and R26 from the Plan. The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i,e, R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Regs 18 and 19 and return us to the correct position as stated in January 2016.

Q2 DATA PROTECTION: All representations and personal information that you provide will be used solely for the purpose of Local Plan Consultation including sharing your personal contact details with the Planning Inspectorate and Programme Officer. Declaration: I hereby consent to share this information as above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to share my representations and personal contact details, as above, from the previous Regulation 19 Consultation in February/March 2019Declaration: I hereby consent to share this information as above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
I agree. The density on this site needs to be increased to NPPF advised levels. As you will note from the number of people who responded in February-March 2019 it seems incongruous that numbers on a Brownfield site should ever have been considered for a reduction.
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure. This is a residential area with appropriate infrastructure that will accommodate at least the original number of 75 allocated to Priests Lane.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
I agree - the site should be removed from the LDP. Blackmore Village is the most "special" of all the villages in Brentwood "Borough of villages". The infrastructure in this historic village was originally built for horse and cart travel, and modern vehicle numbers already mean that the centre of the village is severely congested. Adding an additional approximate 1,000 vehicle movements per day (adding up all proposed development in and around the village) will mean a massive risk to public safety, and the ability for existing residents to get in and out of the village. The flood risk attaching to sites R25 and R26 will be further increased by concreting over greenfield/Green Belt land.
Q8 FOCUSSED CHANGE 4 - PART B. The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. I agree - these sites are developer led and should be removed from the LDP
Q9 FOCUSSED CHANGE 4 - PART C. At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). Brentwood Council has NOT considered all/better development opportunities in and around not only this village but across the wider borough area. The LDP should not have been constructed purely around sites proposed by developers, especially when within Blackmore there is no identified housing need on the scale proposed.
Q12 FOCUSSED CHANGE 5 - PART BR26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area .A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be Reinstated
Q13 FOCUSSED CHANGE 5 -PART C SOUNDNESS and HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i.e. sites R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Reg 18 and 19 and return us the correct position as stated in January 2016.
Q15 CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
Strongly agree

Remove R25 and R26 from the Plan. The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i,e, R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Regs 18 and 19 and return us to the correct position as stated in January 2016.

Q2 DATA PROTECTION: All representations and personal information that you provide will be used solely for the purpose of Local Plan Consultation including sharing your personal contact details with the Planning Inspectorate and Programme Officer. Declaration: I hereby consent to share this information as above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to share my representations and personal contact details, as above, from the previous Regulation 19 Consultation in February/March 2019Declaration: I hereby consent to share this information as above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden Village Strategic Allocation The allocation should be further increased and the delivery programme accelerated in order to remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent Drive, Shenfield. Brownfield. (Less than 1% of total responses, March 2019)Brownfield sites should be prioritised over Greenfield, and Green Belt should not be released at all unless all other alternatives have been used to fulfil the target housing allocations. The number of homes should be increased back to a minimum of 55 and R25 & R26 should be removed entirely.
I agree. The density on this site needs to be increased to NPPF advised levels. As you will note from the number of people who responded in February-March 2019 it seems incongruous that numbers on a Brownfield site should ever have been considered for a reduction.
Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane, Shenfield.(11% of total responses, March 2019)Defined as: Greenfield Land within Brentwood urban area / Settlement boundary. This is a site surrounded by existing housing, on a main road, and next to a railway line. This site is more suitable for residential development than more remote locations (EG Policies R25 and R26) and therefore should be built on before remote locations.
I agree - we should prioritise building on sites with, or close to, existing infrastructure. This is a residential area with appropriate infrastructure that will accommodate at least the original number of 75 allocated to Priests Lane.
Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of total responses, March 2019)To be read in conjunction with Focussed Change 5 - All comments apply to both sites. Greenfield/Green Belt land in a remote village location with inadequate infrastructure. The number of houses has been reduced by 10. For all the reasons stated in March 2019, this site should be withdrawn completely from the LDP. A reduction of 10 houses does not change fundamental problems - in particular the infrastructure and services of the historically significant Blackmore Village will not support this scale of development.
I agree - the site should be removed from the LDP. Blackmore Village is the most "special" of all the villages in Brentwood "Borough of villages". The infrastructure in this historic village was originally built for horse and cart travel, and modern vehicle numbers already mean that the centre of the village is severely congested. Adding an additional approximate 1,000 vehicle movements per day (adding up all proposed development in and around the village) will mean a massive risk to public safety, and the ability for existing residents to get in and out of the village. The flood risk attaching to sites R25 and R26 will be further increased by concreting over greenfield/Green Belt land.
Q8 FOCUSSED CHANGE 4 - PART B. The sites proposed are developer led and still have not been properly assessed against local housing needs. These sites should be removed. I agree - these sites are developer led and should be removed from the LDP
Q9 FOCUSSED CHANGE 4 - PART C. At the time of the Addendum, a large number of developments (not included within the LDP) are in various stages of progress. These will further degrade the infrastructure of Blackmore. In particular, there has been inadequate consultation and strategic planning between Brentwood and Epping Forest Councils, with EFDC considering/consenting to; 30 houses are currently under construction in Fingrith Hall Lane (1km from the Village) An additional 5 houses are going through planning in Fingrith Hall Lane There are other EFDC 'infill sites' in Nine Ashes (1km away) Within metres of the village there will be at least 10 large dwellings at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25 and R26 should be removed completely from the LDP
Q10 FOCUSSED CHANGE 4 - PART D Also within Brentwood running through the normal planning process is: Redrose Farm (12 dwellings) on a Brownfield site (see R26 comments) 5 starter units in Spriggs Lane - Approved; PP being sought/appealed in Spriggs Lane/Chelmsford Road, (9 dwellings) and any number of other Greenfield sites/opportunistic PPs sought by farmers and land owners. R25 and R26 should be completely removed from the LDP, as the pre-existing and future normal infill (and windfall) in the Blackmore area means this Village has more than shouldered the appropriate housing burden, which will already overwhelm our very limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the LDP
Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of total responses, March 2019 - ie grand total 73% across R25 and R26)To be read in conjunction with Focussed Change 4 (above). All comments apply to both sites. Redrose Farm is a Brownfield redevelopment opportunity (opposite R26) for 12 homes, and it will deliver part of our own Village plan as opposed to digging up Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield should be prioritised (eg Redrose Farm). Brentwood Council has NOT considered all/better development opportunities in and around not only this village but across the wider borough area. The LDP should not have been constructed purely around sites proposed by developers, especially when within Blackmore there is no identified housing need on the scale proposed.
Q12 FOCUSSED CHANGE 5 - PART BR26 is also Greenfield/Green Belt, and development is undesirable in the context of better/alternative sites, both within the Village/Parish and the wider Brentwood Council area .A site that was in the LDP (from Jan 2015 - November 2018, when it was withdrawn) is Honeypot Lane (Ref was 022). Identified as 'Green Belt land - edge of Brentwood Urban Area' - an eminently better near town centre site surrounded by existing housing and would provide c200 units. It should be reinstated as this would allow R18, R19, R25 and R26 to be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be Reinstated
Q13 FOCUSSED CHANGE 5 -PART C SOUNDNESS and HOUSING NEED: In the Addendum, sites R25 and R26 (c50 dwellings) equate to 49% of Green Belt release in 'larger villages'. Brentwood and Shenfield urban areas are identified as having the highest housing need, yet two sites (R18 and R19) have now had their allocations reduced. Blackmore remains classified as a 'Category 3' settlement ('larger village'). Our population numbers are much lower than many other villages in this category - which have sufficient infrastructure and resources that Blackmore lacks. Blackmore is Green Belt and there is no identified need for additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
The LDP, in so far as the 2 Blackmore sites are concerned, was never written strategically and indeed prior to Reg 18 the BBC position was the correct position i.e. sites R25 and R26 are wholly inappropriate for development. We therefore need to reverse out of Reg 18 and 19 and return us the correct position as stated in January 2016.
Q15 CONCLUSION: Taking all the above factors into account, I am opposed to building on the Green Belt, and that sites R25 and R26 should be withdrawn from the LDP.
Strongly agree

Remove R25 and R26 from plan

Q2 DATA PROTECTION: All representations and personal
information that you provide will be used solely for the purpose of
Local Plan Consultation including sharing your personal contact
details with the Planning Inspectorate and Programme
Officer.Declaration: I hereby consent to share this information as
above.
Yes
Q3 DATA PROTECTION (CONT.):I also confirm that I consent to
share my representations and personal contact details, as above,
from the previous Regulation 19 Consultation in February/March
2019Declaration: I hereby consent to share this information as
above.
Yes
Q4 FOCUSSED CHANGE 1: POLICY R01 - Dunton Hills Garden
Village Strategic Allocation. The allocation should be further
increased and the delivery programme accelerated in order to
remove policies R25 and R26 from the LDP
I agree - Dunton Hills can accommodate the houses planned for
Blackmore
Q5 FOCUSSED CHANGE 2: POLICY R18 - Land off Crescent
Drive, Shenfield. Brownfield. (Less than 1% of total responses,
March 2019)Brownfield sites should be prioritised over Greenfield,
and Green Belt should not be released at all unless all other
alternatives have been used to fulfil the target housing allocations.
The number of homes should be increased back to a minimum of
55 and R25 & R26 should be removed entirely.
I agree.
Comment: The density on this, Brownfield, site should be increased, not
decreased


Q6 FOCUSSED CHANGE 3: POLICY R19 - Land at Priests Lane,
Shenfield.(11% of total responses, March 2019) Defined as:
Greenfield Land within Brentwood urban area / Settlement
boundary. This is a site surrounded by existing housing, on a main
road, and next to a railway line. This site is more suitable for
residential development than more remote locations (EG Policies
R25 and R26) and therefore should be built on before remote
locations.
I agree - we should prioritise building on sites with, or close to,
existing infrastructure,
Comment: The density on this site can also be increased, over and above the
original number proposed.

Q7 FOCUSSED CHANGE 4 - PART APOLICY R25 - Land North
of Woollard Way, Blackmore. Greenfield and Green Belt. (36% of
total responses, March 2019)To be read in conjunction with
Focussed Change 5 - All comments apply to both
sites. Greenfield/Green Belt land in a remote village location with
inadequate infrastructure. The number of houses has been
reduced by 10. For all the reasons stated in March 2019, this site
should be withdrawn completely from the LDP. A reduction of 10
houses does not change fundamental problems - in particular the
infrastructure and services of the historically significant Blackmore
Village will not support this scale of development.
I agree - the site should be removed from the
LDP.
Comment: Blackmore is a tiny, remote, village, nowhere near main roads, and the
existing population is almost totally dependant on cars. We cannot cope
with more traffic movements, especially bearing in mind the nearby
developments within EFDC which are right on our doorstep.

Q8 FOCUSSED CHANGE 4 - PART B. The sites proposed are
developer led and still have not been properly assessed against
local housing needs. These sites should be removed.
I agree - these sites are developer led and should be removed from
the LDP

Q9 FOCUSSED CHANGE 4 - PART C. At the time of the
Addendum, a large number of developments (not included within
the LDP) are in various stages of progress. These will further
degrade the infrastructure of Blackmore. In particular, there has
been inadequate consultation and strategic planning between
Brentwood and Epping Forest Councils, with EFDC
considering/consenting to; 30 houses are currently under
construction in Fingrith Hall Lane (1km from the Village) An
additional 5 houses are going through planning in Fingrith Hall
Lane There are other EFDC 'infill sites' in Nine Ashes (1km away)
Within metres of the village there will be at least 10 large dwellings
at Ashlings Farm (the entrance development within Blackmore
Parish).
I agree - There has been inadequate consultation and sites R25
and R26 should be removed completely from the LDP

Q10 FOCUSSED CHANGE 4 - PART D. Also within Brentwood
running through the normal planning process is: Redrose Farm (12
dwellings) on a Brownfield site (see R26 comments) 5 starter units
in Spriggs Lane - Approved; PP being sought/appealed in Spriggs
Lane/Chelmsford Road, (9 dwellings) and any number of other
Greenfield sites/opportunistic PPs sought by farmers and land
owners. R25 and R26 should be completely removed from the
LDP, as the pre-existing and future normal infill (and windfall) in the
Blackmore area means this Village has more than shouldered the
appropriate housing burden, which will already overwhelm our very
limited resources and wholly inadequate infrastructure.
I agree - Sites R25 and R26 should be removed completely from the
LDP

Q11 FOCUSSED CHANGE 5: PART APOLICY R26 - Land North
of Orchard Piece, Blackmore. Greenfield and Green Belt. (37% of
total responses, March 2019 - ie grand total 73% across R25 and
R26)To be read in conjunction with Focussed Change 4 (above).
All comments apply to both sites. Redrose Farm is a Brownfield
redevelopment opportunity (opposite R26) for 12 homes, and it will
deliver part of our own Village plan as opposed to digging up
Green Belt land. It should therefore replace R26 in its entirety.
I agree - Green Belt land should not be built upon and Brownfield
should be prioritised (eg Redrose Farm). COMMENT:Redrose Lane is so narrow at the proposed entry point to this site as to make it wholly inadequate. Flood risk remains a major concern.

Q12 FOCUSSED CHANGE 5 - PART BR26 is also
Greenfield/Green Belt, and development is undesirable in the
context of better/alternative sites, both within the Village/Parish and
the wider Brentwood Council area. A site that was in the LDP (from
Jan 2015 - November 2018, when it was withdrawn) is Honeypot
Lane (Ref was 022). Identified as 'Green Belt land - edge of
Brentwood Urban Area' - an eminently better near town centre site
surrounded by existing housing and would provide c200 units. It
should be reinstated as this would allow R18, R19, R25 and R26 to
be completely removed whilst not adding to the burden on R01
I agree - the Honeypot Lane site should be reinstated.

Q13 FOCUSSED CHANGE 5 - PART CSOUNDNESS AND
HOUSING NEED: In the Addendum, sites R25 and R26 (c50
dwellings) equate to 49% of Green Belt release in 'larger
villages'. Brentwood and Shenfield urban areas are identified as
having the highest housing need, yet two sites (R18 and R19) have
now had their allocations reduced. Blackmore remains classified as
a 'Category 3' settlement ('larger village'). Our population numbers
are much lower than many other villages in this category - which
have sufficient infrastructure and resources that Blackmore
lacks.Blackmore is Green Belt and there is no identified need for
additional housing on the scale proposed.
I agree - the allocation in Blackmore is disproportionate and
unsound
Q14 ADDITIONAL COMMENTS: Please use this space for any further comments you wish to record.
We support the properly considered, strategic, elements to the LDP, notably Dunton Hills Garden Village. The proposed sites in Blackmore, however, do not
constitute "strategic thinking", indeed for all the reasons why Blackmore was excluded from the LDP prior to January 2018, the old strategy was the correct
strategy, ie sites R25 and R26 should now be removed. Furthermore, the Honeypot Lane site, which had been included in the LDP prior to Reg 19, needs to be
reinstated. It's withdrawal, for largely "political reasons" was also not professional strategic thinking.

Q15 CONCLUSION: Taking all the above factors into account, I am
opposed to building on the Green Belt, and that sites R25 and R26
should be withdrawn from the LDP. Strongly agree