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Support

Schedule of Potential Main Modifications

Representation ID: 29522

Received: 04/11/2021

Respondent: Essex County Council

Representation Summary:

2. Justified
4. Consistent with National Policy

The proposed modification to criterion 2. of Policy R12 is consistent with the requirements of the NPPF.

Full text:

2. Justified
4. Consistent with National Policy

The proposed modification to criterion 2. of Policy R12 is consistent with the requirements of the NPPF.

Object

Schedule of Potential Main Modifications

Representation ID: 29556

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

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.

Full text:

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: 29669

Received: 09/11/2021

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 highway and transportation authority welcomes inclusion of text within criterion 1.b 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 paragraphs 92.c, 104 c, and 106d of NPPF, 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.

Full text:

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.b 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 paragraphs 92.c, 104 c, and 106d of NPPF, 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: 29685

Received: 09/11/2021

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 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 9.145 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of NPPF.

This reflects ECC’s Reg.19 Rep 22459, position in Statement of Common Ground (F17D) between BBC and ECC, and position in ECC’s Hearing Statement G7AN – paragraph 1.4.

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 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 9.145 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 22459 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.