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