MM87
Support
Schedule of Potential Main Modifications
Representation ID: 29461
Received: 19/10/2021
Respondent: Sport England
The proposed modification to section 2(k) of Policy R03 directly respond to representations made by Sport England on the pre-submission version of the plan and the modification was subsequently agreed as part of the completed Statement of Common Ground with the Council. The modified policy is therefore supported as it would be considered to accord with Government policy in paragraph 99 of the NPPF (2021).
The proposed modification to section 2(k) of Policy R03 directly respond to representations made by Sport England on the pre-submission version of the plan and the modification was subsequently agreed as part of the completed Statement of Common Ground with the Council. The modified policy is therefore supported as it would be considered to accord with Government policy in paragraph 99 of the NPPF (2021).
Support
Schedule of Potential Main Modifications
Representation ID: 29514
Received: 04/11/2021
Respondent: Essex County Council
2. Justified
4. Consistent with National Policy
The proposed modification to criterion 3.c. of Policy R03 is consistent with the requirements of the NPPF.
2. Justified
4. Consistent with National Policy
The proposed modification to criterion 3.c. of Policy R03 is consistent with the requirements of the NPPF.
Support
Schedule of Potential Main Modifications
Representation ID: 29530
Received: 04/11/2021
Respondent: Essex County Council
3. Effective
ECC as highway and transportation authority has engaged with developers’ transport consultants and is satisfied with access wording proposed in criterion 2.c. of Policy R03.
Furthermore, it's understood that a scheme could be designed to allow for partial vehicular access and partial pedestrian and cyclist access along Alexander Lane as part of any wider masterplanning of the site. ECC is satisfied with wording proposed in criterion 2.d. of Policy R03.
These modifications address ECC’s Reg.19 Rep 22446 and reaffirms ECC’s position in Statement of Common Ground (F17D) between BBC and ECC, and paragraph 1.9 of Hearing Statement G7AN.
3. Effective
ECC as highway and transportation authority has engaged with developers’ transport consultants and is satisfied with access wording proposed in criterion 2.c. of Policy R03.
Furthermore, it's understood that a scheme could be designed to allow for partial vehicular access and partial pedestrian and cyclist access along Alexander Lane as part of any wider masterplanning of the site. ECC is satisfied with wording proposed in criterion 2.d. of Policy R03.
These modifications address ECC’s Reg.19 Rep 22446 and reaffirms ECC’s position in Statement of Common Ground (F17D) between BBC and ECC, and paragraph 1.9 of Hearing Statement G7AN.
Support
Schedule of Potential Main Modifications
Representation ID: 29531
Received: 04/11/2021
Respondent: Essex County Council
3. Effective
The proposed deletion of the wording at the end of paragraph 9.100 ensures consistency with Policy BE13 Sustainable Means of Travel and Walkable Streets.
This modification addresses ECC’s Reg.19 Rep 22448 and the position in the Statement of Common Ground (F17D) between BBC and ECC.
3. Effective
The proposed deletion of the wording at the end of paragraph 9.100 ensures consistency with Policy BE13 Sustainable Means of Travel and Walkable Streets.
This modification addresses ECC’s Reg.19 Rep 22448 and the position in the Statement of Common Ground (F17D) between BBC and ECC.
Object
Schedule of Potential Main Modifications
Representation ID: 29549
Received: 04/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
Clarity is required for both applicants and decision makers in relation to the policy requirement criterion 4.b for ‘quietway’ cycle routes connecting transfer hubs.
As currently drafted the policy provides limited detail and the supporting text provides no guidance on what a ‘quietway’ cycle route is and their locations, or what a transfer hub is and their locations.
BBC should include appropriate wording within the supporting text to address this.
3. Not Effective
Clarity is required for both applicants and decision makers in relation to the policy requirement criterion 4.b for ‘quietway’ cycle routes connecting transfer hubs.
As currently drafted the policy provides limited detail and the supporting text provides no guidance on what a ‘quietway’ cycle route is and their locations, or what a transfer hub is and their locations.
BBC should include appropriate wording within the supporting text to address this.
Object
Schedule of Potential Main Modifications
Representation ID: 29585
Received: 04/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
2. Not Justified
4. Not Consistent with National Policy
ECC as the appropriate authority with responsibilities for education covering Brentwood Borough Council (BBC) has provided BBC with the education and childcare requirements (land size in hectares, use class allocation, and type of facility – Primary, Secondary, Early Years and Childcare) for this site allocation.
As currently drafted ECC is not satisfied that the wording proposed within criterion 1.b. will ensure that land for education purposes will be secured.
This reaffirms ECC’s position in paragraph 1.5 of its Hearing Statement F127B.
2. Not Justified
4. Not Consistent with National Policy
ECC as the appropriate authority with responsibilities for education covering Brentwood Borough Council (BBC) has provided BBC with the education and childcare requirements (land size in hectares, use class allocation, and type of facility – Primary, Secondary, Early Years and Childcare) for this site allocation.
As currently drafted ECC is not satisfied that the wording proposed within criterion 1.b. will ensure that land for education purposes will be secured.
This reaffirms ECC’s position in paragraph 1.5 of its Hearing Statement F127B.
Object
Schedule of Potential Main Modifications
Representation ID: 29664
Received: 09/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
ECC as highway and transportation authority welcomes the modification to criterion 2.e. which ensures consistency with paragraphs 106 and 107 of the NPPF.
A further modification is required to ensure the infrastructure to support the sustainable links are also considered and can be secured.
3. Not Effective
ECC as highway and transportation authority welcomes the modification to criterion 2.e. which ensures consistency with paragraphs 106 and 107 of the NPPF.
A further modification is required to ensure the infrastructure to support the sustainable links are also considered and can be secured.
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.
Object
Schedule of Potential Main Modifications
Representation ID: 29833
Received: 25/11/2021
Respondent: Countryside Properties
Agent: Strutt & Parker LLP
Legally compliant? Not specified
Sound? No
Concerns regarding the provision of land for employment purposes within the allocation. The restriction of Uses identified at R03, 1(d) is not justified. The restriction to “light industrial, research and development (within Class E) or other sui generis employment uses which are compatible with the residential development”, could limit
opportunities for other employment-generating uses suitable for this location. Further, it would be illogical to suggest that sui generis employment generating uses are acceptable, but that employment-generating uses that fall into other categories are inherently unacceptable and should be restricted.
See attached
Object
Schedule of Potential Main Modifications
Representation ID: 29873
Received: 25/11/2021
Respondent: Land North of Shenfield Developer Group
Number of people: 4
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
In regard to self build, Policy HP01 now includes a caveat regarding the need for the provision to be demonstrated. This provision is absent from Policy R03, and should be included for consistency.
See attached
Object
Schedule of Potential Main Modifications
Representation ID: 29877
Received: 26/11/2021
Respondent: Stonebond Properties Ltd
Agent: Phase 2 Planning and Development Ltd
Legally compliant? Yes
Sound? No
The provision of self and custom build should be amended to be consistent with the wording of Policy HP01. This refinement will prevent any ambiguity during the determination of planning applications on land at Policy R03. This approach has already been reflected in Policy R01, which requires ‘self-build and custom build plots in line accordance with Policy HP01’.
See attached
Object
Schedule of Potential Main Modifications
Representation ID: 29878
Received: 26/11/2021
Respondent: Stonebond Properties Ltd
Agent: Phase 2 Planning and Development Ltd
Legally compliant? Yes
Sound? No
Modifications would benefit from refinement to accord with policy MG05 (Developer Contributions) which relates requirements back to national policy and legal tests.
See attached