Delete a. of paragraph 8.22

3. Effective.

Paragraph 8.22 a. makes reference to the Essex Biodiversity Plan (2011). This is no longer considered 'live' by Government.

Replace Policy NE02 A. & B. wording with the following -

Where appropriate, contributions from developments will be secured towards mitigation measures identified in the Essex Recreational Disturbance Avoidance and Mitigation Strategy (RAMS) which will be completed by the time the Local Plan is adopted. Prior to RAMS completion, the authority will seek contributions, where appropriate, from proposed residential development to deliver all measures identified (including strategic measures) through project level HRAs, or otherwise, to mitigate any recreational disturbance impacts in compliance with the Habitat Regulations and Habitats Directive.

3. Effective

Natural England advice is that ALL residential development within the RAMS Zone of Influence will need to provide mitigation and this will trigger a proportionate financial contribution.

The Essex Rams Steering Group agreed the following action at its 5th February 2019 meeting -
ALL to endeavour to use the policy text in Chelmsford's emerging Local Plan for the RAMS so that there is consistency across all LPAs involved in the Essex Coast RAMS

The wording was agreed in response to issues raised by Natural England (PS2078) in response to Chelmsford Draft Local Plan and was included in their Schedule of Additional Changes - June 2018.

Amend paragraph 8.25 as follows -

Following consultation with Natural England, an Essex-wide Recreational Disturbance Avoidance and Mitigation Strategy (RAMS) is being prepared to include all coastal European sites. The strategy will identify where recreational disturbance is happening and the main recreational uses causing the disturbance. New residential development that is likely to affect the integrity of the European Sites will be required to contribute towards the implementation of the mitigation. At this stage, it is considered that development allocations in this location will be required to pay for the implementation of mitigation measures to protect the interest features of European designated sites along the Essex Coast which include the Crouch and Roach Estuaries Special Protection Area, the Colne and Blackwater Estuaries SPAs and Ramsar sites and Site of Special Scientific Interest, and the Essex Estuaries Special Area of Conservation. The appropriate mechanisms will be identified in the RAMS.

3. Effective.

The Essex Rams Steering Group agreed the following action at its 5th February 2019 meeting -
ALL to endeavour to use the policy text in Chelmsford's emerging Local Plan for the RAMS so that there is consistency across all LPAs involved in the Essex Coast RAMS

The wording was agreed in response to issues raised by Natural England (PS2078) in response to Chelmsford Draft Local Plan and was included in their Schedule of Additional Changes - June 2018.

Change paragraph 8.27 to read as follows:

Any residential development within the Zone of Influence of the Essex Coast RAMS is likely to affect the integrity of these European sites. The developer will be required to either contribute towards mitigation measures identified in the RAMS or, identify and implement bespoke mitigation measures at the Essex coastal Habitats Sites to ensure
compliance with the Habitat Regulations.

3. Effective.

The Essex Rams Steering Group agreed the following action at its 5th February 2019 meeting -
ALL to endeavour to use the policy text in Chelmsford's emerging Local Plan for the RAMS so that there is consistency across all LPAs involved in the Essex Coast RAMS

The wording was agreed in response to issues raised by Natural England (PS2078) in response to Chelmsford Draft Local Plan and was included in their Schedule of Additional Changes - June 2018.

Amend A. to read as follows:

'...including irreplaceable habitats such as trees, ancient woodlands or hedgerows.'

4. Consistent with National Policy.

Additional wording requested to ensure consistency with paragraph 175 of the NPPF.

Insert additional sentence at end of paragraph 8.59 to read as follows -

Updated Critical Drainage Areas were identified in 2018 and should be referenced and considered.

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

Request amendment to paragraph 8.59 to ensure factual representation of the current position, in line with paragraph 156 of the NPPF.

Delete criterion A. b. from Policy NE10.

4. Consistent with National Policy.

Policy NE10 A. b. as currently proposed considers the provision of education and community uses as an exception to inappropriate development in the Green Belt.

It is recommended that criterion A. b. of Policy NE10 is deleted (see earlier comments in relation to Policy PC15 - Education Facilities).

Delete criterion b. from paragraph 8.98.

4. Consistent with National Policy.

Paragraph 8.98 b. refers to new buildings or extension for education and community uses which can demonstrate a requirement for a Green belt location as an exception to inappropriate development, as set out in paragraphs 145 and 146 of the NPPF. The NNPF does not include this exception.

It is recommended that criterion b. of paragraph 8.98 is deleted (see earlier comments in relation to Policy PC15 - Education Facilities).

Amend paragraph 8.99 as follows -

The Council acknowledges that due to the extent of the Green Belt in Brentwood there may be instances where new buildings related to community or educational uses may be proposed e.g. a new village hall, ancillary buildings related to an existing school. In accordance with the NPPF, these types of uses will be considered inappropriate development. However, the locational need for these types of uses will be given appropriate weight when considering whether there are very special circumstances that weigh in favour of the proposals.

4. Consistent with National Policy.

It is recommended that paragraph 8.99 is amended (see earlier comments in relation to Policy PC15 - Education Facilities).

Delete criterion B. from Policy NE11.

4. Consistent with National Policy.

Policy NE11 B. as currently proposed considers the provision of education and community uses as an exception to inappropriate development in the Green Belt. The NPPF does not include this exception.

It is recommended that criterion B. of Policy NE11 is deleted (see earlier comments in relation to Policy PC15 - Education Facilities).