brentwood.gov.uk

ECC welcomes the draft HRA screening report and the references to co-operating with other Essex local planning authorities (LPAs) on a strategic mitigation scheme for recreational disturbance (RAMS) to deliver measures to avoid adverse impacts on site integrity on European sites. The emerging RAMS is being co-ordinated by ECC for the 11 Essex LPAs needing to provide mitigation measures.

ECC recommends that references to developer contributions towards the Essex Coastal RAMS need to be clear. These should be sought from developers (not new residents), to avoid impacts from recreational disturbance, in combination with other plans and projects. A reference to the need for project level HRA for developments not proposing to contribute to the RAMS may also be helpful. This could be to secure bespoke mitigation measures in certain cases. Furthermore it is recommended that a reference is also made to project level HRA's, to ensure applicants minimise likely impacts from the developments alone in terms of layout.

ECC welcomes the acknowledgement for the need for a mitigation strategy for Epping Forest Special Area of Conservation (SAC) to deal with increased atmospheric pollution, and looks forward to receiving more details on modelling.

ECC notes that the evidence base for the Local Plan includes a Local Wildlife (LoWS) Review (2012) which enables consideration to be given to minimising impacts of site allocations on these non-statutory designated sites for biodiversity. However ECC advises that BCC should carry out assessments in relation to the preferred site allocations, including DHGV, to establish if they contain Priority habitats and species which could meet the criteria for new LoWS.