MM112
Object
Schedule of Potential Main Modifications
Representation ID: 29698
Received: 10/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
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.
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.
Object
Schedule of Potential Main Modifications
Representation ID: 29703
Received: 10/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
2.Not Justified
3.Not Effective
4.Not Consistent with National Policy
ECC as LLFA for BBC consider inclusion of supporting text for site specific policies, including potential risk of flooding references, and links to Local Plan sustainable drainage and flood risk policies, provides clarity to applicants/decisions makers of need for consideration of flooding matters at beginning of planning process.
New paragraph after 9.224 ensures factual representation of current flooding position (NPPF 159, 160). Amend to provide links to Local Plan sustainable drainage and flood risk policies.
Reflects ECC’s Reg.19 Rep 22507, position in BBC/ECC SoCG (F17D), and Hearing Statement G7AN – paragraph1.42.
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.