Insert the following paragraph after paragraph 9.40 -

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 9.40 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.

Amend DH01f as follows -

DH01f: Active and Sustainable Travel

3. Effective.

To be consistent with the wording associated with DH01f the title should include the word 'Active'.

Amend DH02b as follows -

DH02b: ALL THROUGH LEARNING. Development that delivers exemplar education facilities that meet the needs of all types of learners through life, from nursery to adult learning opportunities.

2. Justified
4. Consistent with National Policy.

The type or types of school that will best serve Dunton have yet to be properly considered and cannot be determined at this stage. The important consideration at this stage is ensuring appropriate opportunities for all learners of all ages. The DfE regulations for establishing a new school include appropriate consultation requirements that would be prejudiced by an assumption that any new school must be 'all through'.

DH02b should be amended to reflect this.

Amend Policy R01 (I) D. e. & f. as follows -

e. land (circa 2.1 hectares each) for three co-located primary school and early years and childcare nurseries (Use Class D1)
f. land (circa 0.13 hectares each) for one stand-alone early years and childcare nursery (Use Class D1)

2. Justified
4. Consistent with National Policy.

The DHGV allocation is now based on an overall 4,000 homes rather than the 3,500 ECC have previously tested. BBC has previously been advised that the higher number would require a further 2.1ha site for a primary school. This amendment needs to be made to point D(e) & (f).

Amend Policy R01 (I) C. a. as follows -

The masterplan to be underpinned by Garden City Principles and qualities;

4. Consistent with National Policy.

Reference to garden communities should be consistent with the guidance referred to in paragraph 9.14, and in paragraph 72 of the NPPF.

Recommend amending criterion C. a. of Policy R01 (I) to reflect this.

BBC need to include within the Plan evidence, particularly in respect of transport, the site specific, local and cumulative impact on the local and strategic transport network, to demonstrate that the spatial strategy is the most appropriate.

3. Effective.

In respect of DHGV, ECC strongly support the masterplan approach and the reference to Garden City Principles, together with the integration of the provision of education, employment space and community facilities within the site allocation. However due to its location the site will need to reply upon and embed sustainable transport measures, as required in the DHGV policies, to mitigate impacts on the highway network. Such measures will be informed by the outputs of the transport evidence, which is still to be completed.

Delete reference to 'A127' in Policy R01 (II) J. a.

2. Justified
3. Effective.

Policy R01 (II) J. b. makes reference to the A127 as an access to the site. The remainder of the DHGV policies do not define access to the site, which is inconsistent with all other site allocation policies. Appendix 2 does refer to access from A128 Tilbury Road. ECC do not support access to the site from the A127, and reference to the A127 should be deleted from this policy.

Change paragraph 9.43 to read as follows -

Proposals will need to retain irreplaceable habitats such as ancient woodlands, veteran trees and fens ....'

4. Consistent with National Policy.

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

Amend paragraph 9.72 as follows -

Strategic Objective DH02b (all through learning) will deliver exemplar education facilities that meet the needs of all types of learners through life, from nursery to adult learning opportunities.

2. Justified
3. Effective.

The type or types of school that will best serve Dunton have yet to be properly considered and cannot be determined at this stage. The important consideration at this stage is ensuring appropriate opportunities for all learners of all ages. The DfE regulations for establishing a new school include appropriate consultation requirements that would be prejudiced by an assumption that any new school must be 'all through'.

Paragraph 9.72 should be amended to reflect this.

Insert additional sentence after the first sentence of paragraph 9.82 as follows -

This could be achieved by adopting Employment and Skills Plans, through the planning process, which will require local developments, subject to meeting relevant thresholds, to obligate for activities such as apprenticeship opportunities, work experience placements as well as school and college outreach, particularly in construction but also at end-use. It will also factor contributions to support skills and employability for those hard to reach and furthest away from the job market.

3. Effective.

In order to strengthen the supporting text in paragraph 9.82 in relation to employment and skills reference to the adoption of Employment and Skills Plans should be referenced.