Object

Representation ID: 30505

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

For the VISION and STRATEGIC OBJECTIVES to be meaningful, sound and effective, they have to be rigorously applied throughout the Plan. The allocations in Blackmore (R25 and R26) fail BBC's own 'tests', in particular:
• Blackmore is the most remote Village in the entire Borough
• Existing (and future) residents are, and will remain, totally dependent on personal motorised means of transport
• An additional 70 homes will likely mean an additional 1,000 plus traffic movements per day (including the increasing frequency of delivery vehicles, for food and other shopping)
• All leading to increased pollution levels
• There will be a significantly negative impact on biodiversity, if two green fields, in the Green Belt, are developed
• MM1 and MM2 are rendered unsound (not effective and not positively prepared), should R25 and R26 remain in the LDP

Object

Representation ID: 30506

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

For the VISION and STRATEGIC OBJECTIVES to be meaningful, sound and effective, they have to be rigorously applied throughout the Plan. The allocations in Blackmore (R25 and R26) fail BBC's own 'tests', in particular:
• Blackmore is the most remote Village in the entire Borough
• Existing (and future) residents are, and will remain, totally dependent on personal motorised means of transport
• An additional 70 homes will likely mean an additional 1,000 plus traffic movements per day (including the increasing frequency of delivery vehicles, for food and other shopping)
• All leading to increased pollution levels
• There will be a significantly negative impact on biodiversity, if two green fields, in the Green Belt, are developed
• MM1 and MM2 are rendered unsound (not effective and not positively prepared), should R25 and R26 remain in the LDP.

Object

Representation ID: 30507

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

For the VISION and STRATEGIC OBJECTIVES to be meaningful, sound and effective, they have to be rigorously applied throughout the Plan. The allocations in Blackmore (R25 and R26) fail BBC's own 'tests', in particular:
• Blackmore is the most remote Village in the entire Borough
• Existing (and future) residents are, and will remain, totally dependent on personal motorised means of transport
• An additional 70 homes will likely mean an additional 1,000 plus traffic movements per day (including the increasing frequency of delivery vehicles, for food and other shopping)
• All leading to increased pollution levels
• There will be a significantly negative impact on biodiversity, if two green fields, in the Green Belt, are developed
• MM1 and MM2 are rendered unsound (not effective and not positively prepared), should R25 and R26 remain in the LDP

Object

Representation ID: 30508

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

- Blackmore, when compared with, e.g: Doddinghurst; Kelvedon Hatch; Herongate & lngrave (which is a single conurbation); and Mountnessing, is distinct and very different
- Blackmore's size, facilities (including inter-alia shopping 'centre'), resources, infrastructure, public transport, roads and connectivity with the rest of the Borough and beyond, underline the above point
• The 'Office for National Statistics' own definitions of settlement types, is totally sound and comprehensible, whereas the LDP categories are not positively prepared or properly thought through. Blackmore is nowhere near 'category 3' status, rather it is attempt to 'retro-fit', and thereby 'justify' the flawed thinking behind the late inclusion of R25 and R26 into the LDP
- By way of example, in the BBC Paper LF59A, dated 19/04/2021, it refers to Blackmore having a Travel Agent. This is not a branch of TUI, rather a semi-retired gentleman of pensionable age, working from an office bedroom. 'Due diligence by Yellow Pages' rather than knowledge of the village.

Object

Representation ID: 30509

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

NPPF Para 16(a) requires Plans to be prepared with the objective of contributing to the achievement of sustainable development. Both R25 and, especially, R26 cannot be considered 'sustainable developments'. They will both be subject to, and also exacerbate, the significant flooding that regularly occurs in the Blackmore Village envelope, as well as the very narrow lanes leading into the Village. Para 159 underlines that development should be directed away from areas at risk of flooding, yet it's clear to everyone with knowledge of the Village (and the frequency / extent of flooding here) that development on R25 and R26 will also increase this flood risk to existing dwellings within the existing Village. There is absolutely no evidence presented to remotely suggest that this policy requirement can be met.
Indeed, Mr Shadarevian QC correctly made the point, at the Hearing on 12/02/2021, that 'there are very few rivers in the Brentwood Council area'. Why, then, would BBC belatedly (Reg 18 stage) include sites R25 and R26 within the LDP, when the two sites are within a Village through which flows the largest of all the Brentwood rivers? It is the River Wid, which floods Blackmore with great regularity, and floods in numerous other places en­ route to Chelmsford, where it becomes a major tributary of the River Chelmer.
BVHA, the Parish Council, our Lawyers (Holmes & Hills), and numerous Members/ Residents have flagged this significant issue throughout the entire LDP Process (Reg 18, Reg 19, the Focussed Consultation, in numerous Representations and, in person at the Examination in Public Hearings). It is surprising that these sites were allocated in the first place, and even more incredulous that they remain in the Plan, especially in the absence of any clear evidence that this inherently dangerous issue can be overcome. There needs to be more specific engagement with, including a detailed fluvial flooding risk assessment from, The Environment Agency.
- Essex CC has, to some extent, reported on the other significant flood risk issue, that of surface water run off (Blackmore sits in a bowl, in terms of topography). However, we do not feel that they have understood the full implications for this Village, especially when surface water AND fluvial flooding meet at e.g Red rose Lane, and the heart of the Village (the Conservation area around The Green, where the Ponds (fed by the River Wid) regularly overflow and effectively cut off the eastern side of the Village.
- To be clear, the River Wid rises just north of Blackmore Village, flows (in theory) under Redrose Lane (but the flooding is that deep when it occurs that it renders this lane totally impassable), continues down the eastern side of the Village, into the ponds, exits the ponds, and continues towards Mountnessing. When it floods, as it does with unerring regularity, not only does Redrose Lane get cut off, so too does the entrance to the Village from the Chelmsford Road. Picture Emergency Vehicles trying to access R26 from Chelmsford..... the potential dangers are enormous.
- There is reference made to 'Stondon Brook', which is a tributary of the Wid, flowing into it well south of Blackmore Village. Why is this referenced, and not Blackmore Village, where the proposed developments sit?
- So, insufficient due-diligence again, and therefore the Plan is unsound (not positively prepared)
- Furthermore, the Sustainability Appraisal (2.8.1) appears to 'gloss over' the reality of what occurs in Blackmore. This (i.e. the reality) is really well documented, including several albums full of photos, some of which are included at the end of this Representation.
- We also feel that the discussion at the Hearing on 12.02.2021 was not sufficiently robust, and the real and serious flood risk issues were not probed deeply enough. To suggest that the flood risk issue should be left for consideration at individual site Planning Application stage massively underplays the seriousness of the matter. In short, the River Wid actually exists, and actually floods Blackmore with great regularity and severity.
- Finally, on this matter, the impact of Climate Change is another very good reason to properly engage with The Environment Agency BEFORE this Plan is adopted and BEFORE moving on to the next Plan in a couple of years' time. BVHA is also taking up this matter with other parties who should be made aware of the seriousness of the flood risk issue in Blackmore. We are therefore attaching, as part of these Reps, an open letter to other bodies, including the Secretary of State, and the Environment Agency, in addition to BBC and the Planning Inspectorate, and we stand ready to engage further, in a constructive way.

Object

Representation ID: 30510

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

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

Object

Representation ID: 30511

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

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

Object

Representation ID: 30512

Received: 04/12/2021

Respondent: Blackmore Village Heritage Association

Agent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

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

Object

Representation ID: 30552

Received: 06/12/2021

Respondent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

For the VISION and STRATEGIC OBJECTIVES to be meaningful, sound and effective, they have to be rigorously applied. The allocations in Blackmore (R25 and R26) fail your tests:
• Blackmore is the remotest village in the entire Borough
• Existing (and future) residents are over-dependent on motor vehicles
• More houses equals more cars, more deliveries, more vehicle movements generally and significantly increased pollution
• There will be a significant negative impact on biodiversity, if two green fields, in the Green Belt, are lost
• MM1 and MM2 are rendered unsound (not effective and not positively prepared), should R25 and R26 remain in the plan

Object

Representation ID: 30553

Received: 06/12/2021

Respondent: Blackmore Village Heritage Association

Legally compliant? Not specified

Sound? No

For the VISION and STRATEGIC OBJECTIVES to be meaningful, sound and effective, they have to be rigorously applied. The allocations in Blackmore (R25 and R26) fail your tests:
• Blackmore is the remotest village in the entire Borough
• Existing (and future) residents are over-dependent on motor vehicles
• More houses equals more cars, more deliveries, more vehicle movements generally and significantly increased pollution
• There will be a significant negative impact on biodiversity, if two green fields, in the Green Belt, are lost
• MM1 and MM2 are rendered unsound (not effective and not positively prepared), should R25 and R26 remain in the plan