MM113

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Support

Schedule of Potential Main Modifications

Representation ID: 29536

Received: 04/11/2021

Respondent: Essex County Council

Representation Summary:

3. Effective

ECC previously advised vehicular access via Roman Road may not be able to meet highway standards. Needed evidence to demonstrate safe and suitable access(es), for all highway users, including pedestrians and cyclists.

Following discussions, ECC as highway and transportation authority is in principle satisfied suitable access could be achieved from Roman Road, subject to highway improvements.

Recommendations of LP TA (j.24 - need to signalise A12 off slip junction with Roman Road) justifies deletion of ‘potential’.

ECC satisfied with criterion 1.a. modification, which addresses ECC’s Reg.19 Rep 22510 and reaffirms position in Hearing Statement F121A (paragraphs 1.2-1.4).

Full text:

3. Effective

ECC as highway and transportation authority has previously advised that vehicular access via Roman Road may not be able to meet highway standards, and that BBC needed to provide the evidence to demonstrate that safe and suitable access(es), for all highway users, including pedestrians and cyclists could be achieved.

Further discussions have since taken place and ECC as highway and transportation authority is in principle satisfied that a suitable access could be achieved from Roman Road, subject to highway improvements.

The recommendations of the Local Plan Transport Assessment (TA) which identifies the need to signalise the A12 off slip junction with Roman Road (junction 24 in the TA), also justifies the proposed deletion of the word ‘potential’ from this criterion.

As a result, ECC is satisfied with the proposed modified wording for criterion 1.a. of Policy E08.

This modification addresses ECC’s Reg.19 Rep 22510 and reaffirms ECC’s position as set out in its Hearing Statement F121A (paragraphs 1.2-1.4).

Support

Schedule of Potential Main Modifications

Representation ID: 29537

Received: 04/11/2021

Respondent: Essex County Council

Representation Summary:

3. Effective

ECC as highway and transportation authority has previously advised that vehicular access via Roman Road may not be able to meet highway standards, and BBC needed to provide evidence to demonstrate safe and suitable access(es), for all highway users, including pedestrians and cyclists could be achieved.

Following further discussions, ECC as highway and transportation authority is in principle satisfied that a suitable access could be achieved from Roman Road, subject to highway improvements.

ECC is satisfied with paragraph 9.227 modified wording.

This modification addresses ECC’s Reg.19 Rep 22511 and reaffirms ECC’s position in Hearing Statement F121A (paragraphs 1.2-1.4).

Full text:

3. Effective

ECC as highway and transportation authority has previously advised that vehicular access via Roman Road may not be able to meet highway standards, and BBC needed to provide evidence to demonstrate safe and suitable access(es), for all highway users, including pedestrians and cyclists could be achieved.

Following further discussions, ECC as highway and transportation authority is in principle satisfied that a suitable access could be achieved from Roman Road, subject to highway improvements.

ECC is satisfied with paragraph 9.227 modified wording.

This modification addresses ECC’s Reg.19 Rep 22511 and reaffirms ECC’s position in Hearing Statement F121A (paragraphs 1.2-1.4).

Object

Schedule of Potential Main Modifications

Representation ID: 29605

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority has identified this site as being within a Critical Drainage Area (CDA).

In order to ensure consistency, with the other policies for site allocations located in CDA’s, an additional criterion needs to be inserted into Policy E08 to reflect this position.

Full text:

3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority has identified this site as being within a Critical Drainage Area (CDA).

In order to ensure consistency, with the other policies for site allocations located in CDA’s, an additional criterion needs to be inserted into Policy E08 to reflect this position.

Object

Schedule of Potential Main Modifications

Representation ID: 29650

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

2.Not Justified
3.Not Effective
4.Not Consistent with National Policy

ECC as Lead Local Flood Authority for BBC consider inclusion of supporting text for site specific policies, including references to specific Critical Drainage Areas (CDAs) that affect development, provides clarity to applicants/decisions makers of need for consideration of CDAs at beginning of planning process.

ECC welcome new paragraph after 9.229 - ensures factual representation of current flooding position - in line with NPPF 159 and 160.

Recommend CDA reference number ‘NBTW_IN002’ included - consistency with other supporting text.

Reflects ECC’s Reg.19 Rep 22508 and position in Hearing Statement G7AN – paragraph.1.25.

Full text:

2. Not Justified
3. Not Effective
4.Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including the references to the specific Critical Drainage Areas (CDAs) that affect the development, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.

ECC therefore welcome the proposed new paragraph after 9.229 as it ensures factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

ECC would recommend that the CDA reference number ‘NBTW_IN002’ is included in the paragraph to be consistent with other supporting text.

This reflects ECC’s Reg.19 Rep 22508 and the position in its Hearing Statement G7AN – paragraph 1.25.

Object

Schedule of Potential Main Modifications

Representation ID: 29699

Received: 10/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3.Not Effective

ECC welcomes the inclusion of criterion 1.b. within Policy E08, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.

In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.

Full text:

3.Not Effective

ECC welcomes the inclusion of criterion 1.b. within Policy E08, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.

In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.

Object

Schedule of Potential Main Modifications

Representation ID: 29882

Received: 26/11/2021

Respondent: Hallmark Care Homes

Agent: Freeths LLP

Legally compliant? Yes

Sound? No

Representation Summary:

Proposed wording is a significant departure from the Statement of Common Ground (SoCG) agreed with the local planning authority and dated 2 February 2021.
Whilst the revised drafting is an improvement on the Pre-Submission draft it is a retrograde step from that proposed in the SoCG. The use of the word “ancillary” fetters the interpretation and application of the policy to the detriment of the broader objectives of the plan. This word should be deleted from the policy.

Full text:

See attached