Object
Schedule of Potential Main Modifications
Representation ID: 29665
Received: 09/11/2021
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.
ECC welcome modifications to paragraph 9.105 - ensures factual representation of current flooding position - in line with NPPF 159 and 160.
Recommend CDA reference number ‘NBTW_002’ included - consistency with other supporting text.
Reflects ECC’s Reg.19 Rep 22449 and position in Hearing Statement G7AN – paragraph.1.13.
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 modifications to paragraph 9.105 as it ensures factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.
ECC as LLFA would recommend that the CDA reference number ‘NBTW_002’ is included in the paragraph to be consistent with other supporting text.
This reflects ECC’s Reg.19 Rep 22449, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.13.