Amend Policy R02 B. e. as follows -

provide well-connected internal road layouts which allow for good accessibility including for passenger transport;

3. Effective
4. Consistent with National Policy.

ECC welcome that BBC has recognised the importance of ensuring that this site allocation should provide well-connected road layouts which allow for good accessibility. However, such a size of development should also be seeking to ensure that such layouts can accommodate passenger transport. This would be consistent with other policies contained within the Local plan including Policy BE14, and in line with paragraph 102 of the NPPF.

Criterion B. e. of Policy R02 should therefore include reference to passenger transport.

Replace paragraph 9.97 with the following wording:

The site falls within 2 Critical Drainage Areas (CDA) Hor2 and Hor3 and 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. Early Engagement with the Lead Local Flood Authority (LLFA) in this area is critical to ensure that existing and potential flood risk is properly managed.

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

Request replacement of paragraph 9.97 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.

Clarity is sought on how to resolve any conflict between criteria B. c and B. d. in order to ensure the site can provide the required and appropriate accesses.

3. Effective.

Criterion B. d. of Policy R03 seeks a potential diversion of Alexander Lane to create a quiet lane for pedestrians and cyclists. This would appear to be contradictory to criterion B. c. which proposes vehicular from Chelmsford Road and Alexander Lane. A development of this scale requires more than one access, and whilst Chelmsford Road would be the main access, Alexander road would need to provide vehicular access.

Clarification is sought on how this conflict can be resolved, and that the site is provide with the required and appropriate accesses.

Amend Policy R03 B. f. as follows -

provide well-connected internal road layouts which allow for good accessibility including for passenger transport;

3. Effective.
4. Consistent with National Policy.

Criterion B. f. of Policy R03 should include reference to passenger transport (see comments to Policy R02 - Land at West Horndon Industrial Estate).

Delete the following words from the end of paragraph 9.100 -

'to the majority of residents in the development.'

3. Effective.

The second sentence in paragraph 9.100 refers to community services and facilities being accessible 'to the majority of residents in the development'. Policy BE13 requires sustainable modes of transport to be facilitated through new developments to promote accessibility and integration into the wider community and existing networks. It is considered that the wording in paragraph 9.100 contradicts this and should be deleted.

Replace second sentence of paragraph 9.105 and the full paragraph 9.170 with the following wording -

The site falls within the Shenfield CDA and 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. Early Engagement with the LLFA in this area is critical to ensure that existing and potential flood risk is properly managed.

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

Request amendment to second sentence of paragraph 9.105 and full paragraph of 9.170 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.

Replace second sentence of paragraph 9.105 and the full paragraph 9.170 with the following wording -

The site falls within the Shenfield CDA and 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. Early Engagement with the LLFA in this area is critical to ensure that existing and potential flood risk is properly managed.

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

Request amendment to second sentence of paragraph 9.105 and full paragraph of 9.170 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.

Amend Policy R04 and R05 B. c. as follows -

provide well-connected internal road layouts which allow for good accessibility including for passenger transport;

3. Effective.
4. Consistent with National Policy.

Criterion B. c. of Policy R04 and R05 should therefore include reference to passenger transport (see comments to Policy R02 - Land at West Horndon Industrial Estate).

Amend Policy R04 and R05 as follows to separate into two criteria -

d. integrate existing community facilities within new development;

e. provision for new multi-functional green infrastructure including public open space;

3. Effective.

Policy R04 and R05 B. d. covers 2 separate matters (community facilities and open space) and should be split into two criteria.

Replace paragraph 9.112 with the following wording:

The northern part of the site (R05) falls within the Thrift Green CDA. Any development within this area should where possible try to have a positive impact on existing areas of flood risk downstream of the development. Early Engagement with the LLFA in this area is critical to ensure that existing and potential flood risk is properly managed.

The southern part of the proposed development area (R04) is not within areas identified at risk of flooding. 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 replacement of paragraph 9.112 to ensure factual representation of the current position in respect of flooding, in line with paragraphs 155 and 156 of the NPPF.