Support

Representation ID: 29533

Received: 04/11/2021

Respondent: Essex County Council

2. Justified
3. Effective

With regards to access and criterion 2.b., ECC as highway and transportation authority previously made representations recommending that BBC needed to demonstrate that suitable access arrangements for all modes of travel could be achieved, including appropriate mitigation/improvements, and demonstrate what discussions had taken place the relevant Highway Authorities, to ensure that access arrangements are deliverable and agreed.

ECC confirms it has agreed in principle that an access to the site from Warley Street (B186) can be achieved.

This modification has addressed ECC’s Reg.19 Reps 22498 and 22501.

Object

Representation ID: 29568

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

2. Not Justified

ECC acknowledges that the provision of Early Years and Childcare (EYCC) facilities on employment sites can be beneficial to the development, increasing the attractiveness for employees. However, the most recent ECC Developers’ Guide to Infrastructure Contributions (updated 2020) no longer specifically requires the delivery of EYCC facilities (and/or contributions) as part of proposals for employment development. Whilst ECC would encourage the provision of a 56 place facility to be delivered on-site to support employees, we cannot insist on this requirement being a prerequisite for the development. Criterion 2.a. of Policy E11 should be deleted.

Object

Representation ID: 29569

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

Given the scale of the allocation, Policy E11 needs to include criteria requiring a range of unit sizes supporting start-ups, as well as those businesses that have outgrown their initial accommodation. The need for such requirements is evidenced in the South Essex Grow-on Space Study (February 2020).

Object

Representation ID: 29604

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 reference to potential risk of flooding, and links to sustainable drainage and flood risk Local Plan policies, provides clarity to applicants/decisions makers of need for consideration of flooding matters at beginning of planning process.

Insert additional wording after para.9.210 to ensure factual representation of current flooding position, in line with NPPF paragraphs 159, 160.

Reflects ECC’s Reg.19 Rep 22499, position in Statement of Common Ground (F17D) between BBC and ECC, Hearing Statement G7AN–paragraph1.42.

Object

Representation ID: 29693

Received: 10/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

It is unclear to ECC as highway and transportation authority why ‘Demand Responsive Travel’ has been included within criterion 2.d., as it is considered to be part of passenger transport. Reference to ‘Demand Responsive Travel' should be deleted and ‘public’ changed to ‘passenger’.

Object

Representation ID: 29695

Received: 10/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3.Not Effective

ECC welcomes the inclusion of criterion 2.e within Policy E11, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.

In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.

Object

Representation ID: 29700

Received: 10/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

In order to ensure that all highway works are identified, including site access from the highway, criterion 4.a. needs to be amended.

Object

Representation ID: 30234

Received: 01/12/2021

Respondent: St Modwen Properties PLC and S&J Padfield and Partners

Agent: Strutt & Parker LLP

Legally compliant? No

Sound? No

Policy E11’s requirement for contribution towards EYCC from development at E11 is not justified. A demand for such a contribution is not considered capable of confirming to national policy or CIL Regulations on planning obligations. No residential development of the site is proposed or supported by proposed policy. Recent pre-application discussions with Essex County Council in respect of the proposed development of site E11 have confirmed that Essex County Council would not require a contribution to EYCC from employment development of the site.

Object

Representation ID: 30235

Received: 01/12/2021

Respondent: St Modwen Properties PLC and S&J Padfield and Partners

Agent: Strutt & Parker LLP

Legally compliant? Not specified

Sound? No

Unclear why the Council has changed its position with regards to the amendments to the site boundary and resultant further Green Belt release. Concerned that future decision makers could consider the areas now not proposed to be removed from the Green Belt not to meet the tests in paragraph 150 of the NPPF and therefore constitute inappropriate development;

Object

Representation ID: 30236

Received: 01/12/2021

Respondent: St Modwen Properties PLC and S&J Padfield and Partners

Agent: Strutt & Parker LLP

Legally compliant? No

Sound? No

- Policy should be clear contributions should only be demanded where necessary to make the development acceptable in planning terms, directly related to the development and fairly and reasonably related in scale and kind to the development;
- The proposed reference to J28 is not necessary to make the Plan sound, and therefore is not compliant with Sections 20(7B) and (7C) of the
Planning and Compulsory Purchase Act 2004. There is no evidence to suggest that development of the site would be unacceptable in planning terms without improvements to J28; or that contribution would be directly related to the development.