Object

Schedule of Potential Main Modifications

Representation ID: 29701

Received: 10/11/2021

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 LLFA for BBC consider inclusion of supporting text for site specific policies, including potential risk of flooding references, and links to Local Plan sustainable drainage and flood risk policies, provides clarity to applicants/decisions makers of need for consideration of flooding matters at beginning of planning process.

New paragraph after 9.214 ensures factual representation of current flooding position (NPPF 159, 160). Amend to provide links to Local Plan sustainable drainage and flood risk policies.

Reflects ECC’s Reg.19 Rep 22504, position in BBC/ECC SoCG (F17D), and Hearing Statement G7AN – paragraph1.42.

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 supporting text for the site specific policies, in particular, including reference 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 flooding matters at the beginning of the planning process.

ECC therefore welcome the proposed modifications to include the new paragraph after 9.214 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 last sentence is amended to provide the links back to the sustainable drainage and flood risk policies in the Local Plan.

This reflects ECC’s Reg.19 Rep 22504, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in its Hearing Statement G7AN – paragraph 1.42.