Object

Addendum of Focussed Changes to the Pre-Submission Local Plan (Regulation 19)

Representation ID: 26727

Received: 26/11/2019

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

NPPF para 31 requires planning policies to be underpinned by relevant and up to date evidence.

BBC need to be satisfied increase in dwelling numbers is supported by appropriate evidence base,including:
- demonstrating site is where need is (para 59)
- all other reasonable options have been fully examined, including making as much use as possible of suitable brownfield sites and underutilised land,and optimising density (para 137)
- updated transport evidence base fully assesses
transport implications.

Proposed policy change does not address ECC's Pre-Submission Reg.19 consultation representations to this policy (March 2019).

ECC's position has not changed on this matter.

Change suggested by respondent:

As a result of the increase in dwelling numbers for this site allocation BBC should include, within the Plan evidence and supporting text for this Policy, details to demonstrate that the reallocation of dwellings to this site is where the need is (paragraph 59 of the NPPF), and that all other reasonable options for reallocating the dwellings have been fully examined, including making as much use as possible of suitable brownfield sites and underutilised land, and optimising density.

BBC should also update its transport evidence base for the Local Plan to fully assess the transport implications of the change in dwellings numbers on this site allocation.

The policy needs to be further changed to address ECC's representations to this policy made to the Pre-Submission Regulation 19 Local Plan consultation in March 2019.

Full text:

2. Justified
3. Effective
4. Consistent with National Policy

Paragraph 31 of the NPPF requires planning policies to be underpinned by relevant and up to date evidence.

BBC will need to be satisfied that the increase in dwelling numbers on this site is supported by the appropriate evidence base, including demonstrating that the reallocation of dwellings to this site is where the need is (paragraph 59 of the NPPF), and that all other reasonable options for reallocating the dwellings have been fully examined, including making as much use as possible of suitable brownfield sites and underutilised land, and optimising density (paragraph 137).

BBC will need to be satisfied that the transport implications of the change in dwelling numbers on this site allocation are fully assessed through an updated transport evidence base for the Local Plan.

The proposed change to this policy does not address ECC's representations to this policy made to the Pre-Submission Regulation 19 Local Plan consultation in March 2019.
See
ECC 67 / BBC 22434
ECC 68 / BBC 22435
ECC 69 / BBC 22436
ECC 70 / BBC 22437
ECC 71 / BBC 22438
ECC 72 / BBC 22439
ECC 73 / BBC 22440
ECC 74 / BBC 22441
ECC 75 / BBC 22442
ECC 76 / BBC 22443

ECC's position has not changed on this matter.