MM94
Support
Schedule of Potential Main Modifications
Representation ID: 29521
Received: 04/11/2021
Respondent: Essex County Council
2. Justified
4. Consistent with National Policy
The proposed modification to criterion 2. of Policy R11 is consistent with the requirements of the NPPF.
2. Justified
4. Consistent with National Policy
The proposed modification to criterion 2. of Policy R11 is consistent with the requirements of the NPPF.
Object
Schedule of Potential Main Modifications
Representation ID: 29555
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 3.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 3.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: 29563
Received: 04/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
Criterion 1.f. of Policy R11 seeks to ensure retention of public parking spaces sufficient to meet overall town centre public parking needs. BCC should be satisfied that this can be achieved and does not conflict with other polices in the Local Plan, such as BE13 Sustainable Means of Travel and Walkable Streets and BE17 Parking Standards.
This reflects ECC’s Reg.19 Rep 22466.
3. Not Effective
Criterion 1.f. of Policy R11 seeks to ensure retention of public parking spaces sufficient to meet overall town centre public parking needs. BCC should be satisfied that this can be achieved and does not conflict with other polices in the Local Plan, such as BE13 Sustainable Means of Travel and Walkable Streets and BE17 Parking Standards.
This reflects ECC’s Reg.19 Rep 22466.
Object
Schedule of Potential Main Modifications
Representation ID: 29672
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 highway and transportation authority welcomes inclusion of text within criterion 1.c. identifying the Brentwood Cycle Action Plan.
In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF paragraphs 92.c, 104 c and 106 d, the supporting text should provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It should be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.
2.Not Justified
3.Not Effective
4.Not Consistent with National Policy
ECC as highway and transportation authority welcomes inclusion of text within criterion 1.c. identifying the Brentwood Cycle Action Plan.
In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF paragraphs 92.c, 104 c and 106 d, the supporting text should provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It should be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.
Object
Schedule of Potential Main Modifications
Representation ID: 29684
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.
Replace Paragraph 9.141 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of NPPF.
This reflects ECC’s Reg.19 Rep 22458, position in Statement of Common Ground (F17D) between BBC and ECC, and position in ECC’s Hearing Statement G7AN – paragraph 1.4.
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.
Paragraph 9.141 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.
This reflects ECC’s Reg.19 Rep 22458 the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.4.
Object
Schedule of Potential Main Modifications
Representation ID: 30250
Received: 01/12/2021
Respondent: Mr Philip Mynott
Legally compliant? Not specified
Sound? No
The changes a) contradicted with the commitment in the Plan as originally submitted to retain the existing level of public parking spaces. b) presented a commitment to deliver a currently unknown level of parking on-site. This could not possibly allay prior concerns about deliverability, and cannot be proven sound by any means. And this is all despite the fact that the level of Town Centre parking needs is a crucial factor in
the viability of the borough's main shopping centre, and its economy. BBC policies should be
aligning the economic needs of Brentwood businesses and the Council’s finances and policy.
See attached