MM88
Support
Schedule of Potential Main Modifications
Representation ID: 29515
Received: 04/11/2021
Respondent: Essex County Council
2. Justified
4. Consistent with National Policy
The proposed modification to criterion 3. of Policy R04 & R05 is consistent with the requirements of the NPPF.
2. Justified
4. Consistent with National Policy
The proposed modification to criterion 3. of Policy R04 & R05 is consistent with the requirements of the NPPF.
Object
Schedule of Potential Main Modifications
Representation ID: 29550
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: 29586
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 9.112 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of the NPPF.
Reflects ECC’s Reg.19 Rep 22453, 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 9.112 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.