1.22
Object
Brentwood Local Plan 2016 - 2033 (Pre-Submission, Regulation 19)
Representation ID: 22267
Received: 18/03/2019
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
3. Effective
4. Consistent with National Policy
The RAMS is not needed to assess the in-combination impacts - this is the role of HRA prepared by the LPA.
Mitigation is needed because these impacts cannot be ruled out and a strategic approach was advised by Natural England. This has now been produced (Jan 2019) and a SPD is in draft to secure per dwelling developer contributions.
Paragraph 1.22 should be amended to reflect this.
Amend paragraph 1.22 as follows -
'...(RAMS) has been identified for the internationally important designated wildlife sites on the Coast. A RAMS has been prepared (January 2019) to deliver strategic mitigation to avoid impacts on these sites from residential development within the evidenced Zone of Influence, with a view to subsequent adoption of a Supplementary Planning Document (SPD) by the Council to secure per dwelling developer contributions. Residential development that is likely to adversely affect the integrity of Habitats (European) Sites, is required to either contribute towards mitigation measures identified in the RAMS or, in exceptional circumstances, identify and deliver bespoke mitigation measures (in perpetuity) to ensure compliance with the Habitat Regulations. Mitigation is needed because these impacts, in combination with other plans and projects, cannot be ruled out and a strategic approach was advised by Natural England.
3. Effective
4. Consistent with National Policy
The RAMS is not needed to assess the in-combination impacts - this is the role of HRA prepared by the LPA.
Mitigation is needed because these impacts cannot be ruled out and a strategic approach was advised by Natural England. This has now been produced (Jan 2019) and a SPD is in draft to secure per dwelling developer contributions.
Paragraph 1.22 should be amended to reflect this.