Object
Schedule of Potential Main Modifications
Representation ID: 29588
Received: 04/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
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.
Replace paragraph 9.121 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of the NPPF.
Reflects ECC’s Reg.19 Rep 22455, position in Statement of Common Ground (F17D) between BBC and ECC, and position in ECC’s Hearing Statement G7AN – paragraph 1.18.
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, and to the potential risk of flooding, and links back to the sustainable drainage and flood risk policies in the Local Plan, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.
Paragraph 9.121 should be replaced to ensure factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.
This reflects ECC’s Reg.19 Reps 22455, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.18.