Additional footnote should be added to 5 as follows -

United Kingdom Climate Projections 2018 (UKCP18) has started to consider revised risk associated with sea level change

3. Effective

Request clarification footnote to footnote 5 to provide up to date information.

Amend Policy BE08 A. as follows -

'... adverse impact on water quality. SuDS must be based on the criteria outlined in the Essex County Council SuDS Guide.

3. Effective
4. Consistent with National Policy

In line with paragraph 156 of the NPPF, request additional wording added to end of A. to ensure requirements of Lead Local Flood Authority (LLFA) are met.

Delete paragraph 5.68.

3. Effective

The Water Framework Directive (WFD) is a driver for the need for water quality improvements. However, the inclusion of this paragraph within the section relating to SuDS is confusing because ECC as LLFA do not use the criteria associated with water body status to assess pollution control delivered by SuDS.

BBC need to complete the transport modelling, in order to clearly illustrate the site specific, local and cumulative impacts of the Local Plan growth, and identify any infrastructure and/or mitigation measures which would be required, together with costings and phasing.

BBC (together with ECC) need the confidence, and assurance that it can identify up-front the required developer funded transport mitigation measures, and that such mitigation measures are covered within the Local Plan site allocation policies and accounted for in both viability and IDP work.

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

In line with paragraph 31 of the NPPF, a Local Plan needs to be supported by transport modelling that clearly illustrates the site specific, local and cumulative impacts of the Local Plan growth, and identifies any infrastructure and/or mitigation measures which would be required, together with costings and phasing.

ECC as Highway Authority (including BBC as the Local Planning Authority) need the confidence, and assurance that it can identify up-front the required developer funded transport mitigation measures, and that such mitigation measures are covered within the Local Plan site allocation policies and accounted for in both viability and IDP work.

It should be noted that as BBC have their own highway consultants, rather than ECC. This requires ECC as the Highway Authority to check outputs to confirm its satisfaction, and to ensure the mitigation measures are identified and accounted for.

Following the BBC's 2018 consultation, BBC and ECC have held meetings with BBC's transport consultants (PBA) to help progress the additional work needed to be undertaken to address the full range of issues previously raised.

BBC has published a note from PBA (dated 30th January 2019) as part of their evidence base for this consultation, which sets out the transport work that is still outstanding.

ECC confirms that these matters are being discussed and ECC will continue to work with BBC to address these matters. Once this work is completed and verified by ECC, BBC will need to publish a revised and consolidated transport assessment as part of the Plan's evidence base.

ECC as Highway Authority cannot, at this stage, endorse the transport evidence as it is incomplete, and this is required to inform the IDP which shows mitigation, costs and phasing.

Amend Policy BE11 B. b. as follows -

'The Council will work with all relevant statutory bodies, stakeholders and passenger transport providers to consider .... .'

3. Effective.

Criteria B. b. needs to make it clear who BBC will work with in relation to the matter. This would be consistent with the wording for criteria B. a.

Amend last sentence of paragraph 5.92 as follows -

'... with improved forecourt and pedestrian crossing facilities.

3. Effective.

Request amendment to paragraph 5.92 to reflect current situation. Both stations have existing forecourts, the policy should be seeking to improve these.

Insert additional sentence at end of paragraph 5.96 b. as follows -

Where appropriate contributions will therefore be sought from nearby developments.

3. Effective.

Additional wording requested to the end of paragraph 5.96 b. to ensure the proposed improvements can be appropriately funded.

BBC should seek to clarify the status and progress of the South Brentwood Growth Corridor Masterplan referenced in criterion i in paragraph 5.102. BBC should consider providing further narrative in the paragraph to explain this.

3. Effective.

Clarification is sought with regards to the status and progress with South Brentwood Growth Corridor Masterplan referenced in criterion i in paragraph 5.102. BBC should consider providing further narrative in the paragraph to explain this.

Insert additional point to paragraph 5.102 as follows -

iv. The A127 Task Force has representation from all South Essex authorities including BBC. This Task Force will oversee much of the public affairs interaction between the Councils and Government to ensure that the route is seen as strategic and as a potential candidate for re-trunking in order to bring about the long-term improvement required for an area of South Essex with over 600,000 residents. The planning and design work for any improvement of this scale will of necessity require a short-term, medium and long term phasing. Whilst the A127 is the main focus ECC would be looking to work collaboratively with BBC and other councils in the area on the impact on the A128 and the M25 Junction 28 scheme.

3. Effective.

It is recommended that reference is made to the A127 Task Force. This has representation from all South Essex authorities including BBC. This Task Force will oversee much of the public affairs interaction between the Councils and Government to ensure that the route is seen as strategic and as a potential candidate for re-trunking in order to bring about the long-term improvement required for an area of South Essex with over 600,000 residents. The planning and design work for any improvement of this scale will of necessity require a short-term, medium and long term phasing. Whilst the A127 is the main focus ECC would be looking to work collaboratively with BBC and other councils in the area on the impact on the A128 and the M25 Junction 28 scheme.

It is recommended that the policy wording is amended to address the points raised in order to remove ambiguity and provide clarity for the decision maker in relevant planning applications.

3. Effective
4. Consistent with National Policy

The principle of the policy to consider car limited development in appropriate locations is supported. NPPF, paragraph 102, seeks to promote opportunities for walking, cycling and public transport use, along with ensuring parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.

The policy makes reference to car limited development being considered at Brentwood Town Centre or District Shopping Centres, railway stations or strategic employment sites. As worded it is unclear why locations have been separated into the two alternatives, or in drafting the policy is the intention to refer to all these locations individually when considering car-limited development?

Paragraph 2.34 of the LP defines the 'District Shopping Centres' as being Shenfield Hutton Road, Ingatestone High Street, Warley Hill (Brentwood Station). It is considered reasonable that car limited development could be considered at these locations, as they are in close proximity to walking, cycling and passenger transport modes, including rail stations. However, they would need to consider other policies in the plan.

However, it is unclear how car limited development will be considered at Strategic Employment Allocations, of which only Brentwood Enterprise Park is thus defined. It is unclear how it would be expected that employees will be expected to travel via safe and direct walking and cycling routes given its location at M25, J29, without significant improvements to the sustainable transport network, including the provision of new passenger transport services.

However, criteria b and c, as worded, is repeated through Policy BE13 - Sustainable Means of Travel and Walkable Streets, which prioritises cycle and pedestrian movements and access to public transport.

It is unclear how the methods identified in criteria d. would be implemented.