Amend paragraph 9.203 as follows -

The development will take its main vehicular access from Orchard Piece and/or Fingrith Hall Lane...'.

3. Effective.

Paragraph 9.203 makes reference to the main vehicular access for the site to be via Redrose Lane.

ECC have previously advised that vehicular access from Redrose Lane may not be able to meet highway standards. It would be more appropriate to take access from Orchard Piece, or after further consideration Fingrith Hall Road.

The paragraph should therefore be amended to reflect this.

Clarity is sought on the deliverability and phasing of employment land allocations in order to meet requirements outlined in the Local Plan.

1. Positively prepared
2. Justified
3. Effective
4. Consistent with National Policy

BBC needs to satisfy itself that the Local Plan has a clear economic strategy, with robust phasing and delivery mechanisms in place to ensure that the full employment requirements can be delivered over the whole Plan period, in line with paragraph 23 of the NPPF. This is important given 55% of BBC's employment land allocation in the Plan is proposed at the BEP. This site still has uncertainty over its access and how and when this will be delivered. Furthermore, BBC's evidence base (Economic Futures 2013-2033 Report 2018 prepared by consultants Litchfields) indicates that there is a need for this site to be delivered early in the Plan period, in order to accommodate local businesses that may be affected by employment land re-allocation proposed in the Plan.

BBC need to demonstrate that suitable access arrangements for all modes of travel can be achieved, including appropriate mitigation/improvements.

1. Positively prepared.
2. Justified.
3. Effective.
4. Consistent with National Policy.

Currently it is unclear how access to the site can be achieved directly from J29 of the M25 as a consequence of the Lower Thames Crossing improvements to this junction, which includes a segregated left turn slip road from the A127 to M25 southbound. BBC therefore need to demonstrate that suitable access arrangements for all modes of travel can be achieved, including appropriate mitigation/improvements. BBC should also demonstrate what discussions have taken place with Highways England, ECC as Highway Authority, and the site promoter to ensure that access arrangements are deliverable and agreed.

Insert following wording as additional paragraph after 9.210 -

The proposed development area is at potential risk of flooding from surface water as show on the EAs Risk of Flooding from Surface Water Maps. Any development within this area should be directed away from areas of existing flooding and where possible should try to have a positive impact on existing areas of flood risk downstream of the development. It should however be ensured that any development within this area complies with flood risk mitigation measures outlined in the Essex SuDS guide.

2. Justified.
3. Effective.
4. Consistent with National Policy.

Request additional paragraph after paragraph 9.210 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.

BBC need to demonstrate that suitable access arrangements for all modes of travel can be achieved, including appropriate mitigation/improvements.

BBC should also demonstrate what discussions have taken place with Highways England, ECC as Highway Authority, and the site promoter to ensure that access arrangements are deliverable and agreed.

2. Justified.
3. Effective.

Criterion D. b. of Policy E11 refers to potential access points via M25 Junction 29 and Warley Street (B186) and associated slip roads.

Currently it is unclear how access to the site can be achieved directly from J29 of the M25 as a consequence of the Lower Thames Crossing improvements to this junction, which includes a segregated left turn slip road from the A127 to M25 southbound. BBC therefore need to demonstrate that suitable access arrangements for all modes of travel can be achieved, including appropriate mitigation/improvements. BBC should also demonstrate what discussions have taken place with Highways England, ECC as Highway Authority, and the site promoter to ensure that access arrangements are deliverable and agreed.

Paragraph 9.208 needs to be amended to demonstrate the latest position in respect of access to the site, and what discussions have taken place with Highways England, ECC, and the site promoter to ensure that access arrangements are deliverable and agreed.

2. Justified.
3. Effective.

Criterion D. b. of Policy E11 refers to potential access points via M25 Junction 29 and Warley Street (B186) and associated slip roads.

Currently it is unclear how access to the site can be achieved directly from J29 of the M25 as a consequence of the Lower Thames Crossing improvements to this junction, which includes a segregated left turn slip road from the A127 to M25 southbound. BBC therefore need to demonstrate that suitable access arrangements for all modes of travel can be achieved, including appropriate mitigation/improvements. BBC should also demonstrate what discussions have taken place with Highways England, ECC as Highway Authority, and the site promoter to ensure that access arrangements are deliverable and agreed.

The detailed information for access to this site should be set out in the Policy, consistent with the other site allocation policies. This should be informed by the outputs of the transport modelling for the Local Plan, which is currently on-going.

3. Effective.

Criterion B. c. of Policy E12 makes reference to development having consideration of improvements to A127 junction.

The detailed information for access to this site should be set out in the Policy, consistent with the other site allocation policies. This should be informed by the outputs of the transport modelling for the Local Plan, which is currently on-going.

Insert following wording as additional paragraph after paragraphs 9.214, 9.219, and 9.224 -

The proposed development area is at potential risk of flooding from surface water as show on the EAs Risk of Flooding from Surface Water Maps. Any development within this area should be directed away from areas of existing flooding and where possible should try to have a positive impact on existing areas of flood risk downstream of the development. It should however be ensured that any development within this area complies with flood risk mitigation measures outlined in the Essex SuDS guide.

2. Justified.
3. Effective.
4. Consistent with National Policy.

Request additional paragraph after paragraphs 9.214, 9.219, and 9.224 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.

Insert following wording as additional paragraph after paragraphs 9.214, 9.219, and 9.224 -

The proposed development area is at potential risk of flooding from surface water as show on the EAs Risk of Flooding from Surface Water Maps. Any development within this area should be directed away from areas of existing flooding and where possible should try to have a positive impact on existing areas of flood risk downstream of the development. It should however be ensured that any development within this area complies with flood risk mitigation measures outlined in the Essex SuDS guide.

2. Justified.
3. Effective.
4. Consistent with National Policy.

Request additional paragraph after paragraphs 9.214, 9.219, and 9.224 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.

Insert following wording as additional paragraph after paragraphs 9.214, 9.219, and 9.224 -

The proposed development area is at potential risk of flooding from surface water as show on the EAs Risk of Flooding from Surface Water Maps. Any development within this area should be directed away from areas of existing flooding and where possible should try to have a positive impact on existing areas of flood risk downstream of the development. It should however be ensured that any development within this area complies with flood risk mitigation measures outlined in the Essex SuDS guide.

2. Justified.
3. Effective.
4. Consistent with National Policy.

Request additional paragraph after paragraphs 9.214, 9.219, and 9.224 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.