3.Not Effective

ECC welcomes the inclusion of criterion 1.b. within Policy E13, 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.

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 supporting text for the site specific policies, in particular, including reference 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 flooding matters at the beginning of the planning process.

ECC therefore welcome the proposed modifications to include the new paragraph after 9.224 as it ensures factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

ECC would recommend that the last sentence is amended to provide the links back to the sustainable drainage and flood risk policies in the Local Plan.

This reflects ECC’s Reg.19 Rep 22507, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in its Hearing Statement G7AN – paragraph 1.42.