Schedule of Potential Main Modifications
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Schedule of Potential Main Modifications
Strategic Objective SO1: Managing Growth Sustainably
Representation ID: 30554
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
See attached representation
Object
Schedule of Potential Main Modifications
MM5
Representation ID: 30560
Received: 06/12/2021
Respondent: 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 quite distinct and different
- It's size, facilities (centre), resources (notably shopping), roads and connectivity with the rest of the Borough and beyond, underline this point
• The 'Office for National Statistics' definitions are sound, whereas the LDP categories are not positively prepared, rather they are an attempt at a retro-fit to justify the inclusion of R25 and R26.
See attached representation
Object
Schedule of Potential Main Modifications
MM78
Representation ID: 30565
Received: 06/12/2021
Respondent: Blackmore Village Heritage Association
Legally compliant? Not specified
Sound? No
There needs to be more specific engagement with, and a report from, The Environment Agency.
- Essex CC has, to (some extent), reported on surface water run off (Albeit not understood the full implications for Blackmore)
- But on the massively important subject of fluvial flooding, and the regularity with which the River Wid floods Blackmore, there is insufficient due diligence.
- In this respect the LDP is unsound (not positively prepared).
- The River Wid rises just north of Blackmore, and regularly causes flooding along the Chelmsford Road (main route into the village) and along Redrose Lane (rendering the proposed access road to R26 impassable).
-This major area of concern occurs north of the Stondon Hall Brook tributary to which you do refer, in rather more detail.
- The Sustainability Appraisal (2.8.1) seems to gloss over the reality in Blackmore. This flooding is well documented, including albums of photos, some of which are attached.
- We also contest the robustness of and conclusions from. The discussions at the Local Plan Hearing. Referred to in the Sustainability Appraisal (Hearing on 12.02.21).
- So just to underline, the flooding issues in Blackmore (Surface Water and Fluvial) are real and serious.
- The impact of future climate change is another good reason to properly engage with the Environment Agency before this plan is adopted and before moving onto the next plan, in the immediate future. Get it right now.
See attached representation
Object
Schedule of Potential Main Modifications
MM81
Representation ID: 30568
Received: 06/12/2021
Respondent: Blackmore Village Heritage Association
Legally compliant? Not specified
Sound? No
- The 'exceptional circumstances' test This has not been adequately demonstrated, for example: in paragraph 8.81, 'good connectivity' is quoted. Again, Blackmore is remote. no main roads, mainly narrow lanes, inadequate bus services, and a long distance from any of the Borough's main centres and railway stations.
- Has there been a robust, strategic approach to the Green Belt (i.e. as opposed to the so called call for land and then acquiescence to pressure from developers very late in the process Reg 18) The you would be making better decisions in line with your own strategic objectives.
- There are clearly other, much larger settlements surrounded by Green Belt, with better connectivity and services. Doddinhurst for example no housing allocated.
- As proposed by BVHA, on multiple occasions, there ought be a coherent strategy covering all the villages in the north of the Borough, rather than this random approach adopted in this plan.
See attached representation
Object
Schedule of Potential Main Modifications
MM107
Representation ID: 30570
Received: 06/12/2021
Respondent: Blackmore Village Heritage Association
Legally compliant? Not specified
Sound? No
Deletion of (b), the 'minimum 25% reserved for locals etc' clause, is pretty obvious.
- However, what did not come to light in the Hearings, is why this clause is there in the first place. As it certainly did not come from village demand in fact it was deemed ridiculous by BVHA when promoted and voted on at the ECM in November 2018.
- No it was introduced to stifle proper debate, ad as BBCs own Barrister put it on 01.02.21 it was embarrasing.
- Again MM1 and MM2 - The 50's have been ignored.
- The above is the true context behind these sites (previously omission sites) suddenly and unexpectedly being included at Reg 18 and it is something that needs to go on record. It has nothing to do with strategic thinking. In fact it is the polar opposite of a proper strategy.
- Access to R26 and R26. Redrose Lane is wholly inadequate for this purpose, narrow, single track lane, no pavements, frequent flooding and a danger to wildlife and humans (walkers, cyclists, horse riders etc). It might not have received protected land status (Sustainability Appraisal refers), but Redrose Lane is inadequate for existing vehicle usage (including lorry restrictions) and certainly should not be threatened with an additional 700 (plus?) vehicle movements per day.
- It is not a defendable boundary look at the number of houses already to the north of Redrose Lane.
- Orchard Piece as an alternative access road (R26): Presumably that has been added in because the above comments have been taken on board but Orchard Piece is a quiet, residential, cul-de-sac. Again totally unfit for purpose as a new access route.
- Proposed changes to site allocations (back up to around 70 from around 60): the Sustainability Appraisal comments on page 5, 'Community and Wellbeing' is a massive understatement and further evidence of the
lack of understanding of our community. A 20% increase in total dwellings (on top of all the other well documented development going on around Blackmore including EFDC) is not sustainable: (354 + 70 +EFDC housing, plus, plus). In fact, it will destroy the sustainable community that has been built over many decades and it will have a serious detrimental impact on lives, resources, infrastructure etc etc. MM1 and MM2 rules should apply.
See attached representation
Object
Schedule of Potential Main Modifications
MM108
Representation ID: 30571
Received: 06/12/2021
Respondent: Blackmore Village Heritage Association
Legally compliant? Not specified
Sound? No
Deletion of (b), the 'minimum 25% reserved for locals etc' clause, is pretty obvious.
- However, what did not come to light in the Hearings, is why this clause is there in the first place. As it certainly did not come from village demand in fact it was deemed ridiculous by BVHA when promoted and voted on at the ECM in November 2018.
- No it was introduced to stifle proper debate, ad as BBCs own Barrister put it on 01.02.21 it was embarrasing.
- Again MM1 and MM2 - The 50's have been ignored.
- The above is the true context behind these sites (previously omission sites) suddenly and unexpectedly being included at Reg 18 and it is something that needs to go on record. It has nothing to do with strategic thinking. In fact it is the polar opposite of a proper strategy.
- Access to R26 and R26. Redrose Lane is wholly inadequate for this purpose, narrow, single track lane, no pavements, frequent flooding and a danger to wildlife and humans (walkers, cyclists, horse riders etc). It might not have received protected land status (Sustainability Appraisal refers), but Redrose Lane is inadequate for existing vehicle usage (including lorry restrictions) and certainly should not be threatened with an additional 700 (plus?) vehicle movements per day.
- It is not a defendable boundary look at the number of houses already to the north of Redrose Lane.
- Orchard Piece as an alternative access road (R26): Presumably that has been added in because the above comments have been taken on board but Orchard Piece is a quiet, residential, cul-de-sac. Again totally unfit for purpose as a new access route.
- Proposed changes to site allocations (back up to around 70 from around 60): the Sustainability Appraisal comments on page 5, 'Community and Wellbeing' is a massive understatement and further evidence of the
lack of understanding of our community. A 20% increase in total dwellings (on top of all the other well documented development going on around Blackmore including EFDC) is not sustainable: (354 + 70 +EFDC housing, plus, plus). In fact, it will destroy the sustainable community that has been built over many decades and it will have a serious detrimental impact on lives, resources, infrastructure etc etc. MM1 and MM2 rules should apply.
See attached representation