2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including the references to the specific Critical Drainage Areas (CDAs) that affect the development, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.

Paragraph 9.116 should be replaced to ensure factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Reps 22454, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.4.

2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including the references to the specific Critical Drainage Areas (CDAs) that affect the development, and to the potential risk of flooding, and links back to the sustainable drainage and flood risk policies in the Local Plan, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.

Paragraph 9.121 should be replaced to ensure factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Reps 22455, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.18.

2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including the references to the specific Critical Drainage Areas (CDAs) that affect the development, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.

Paragraph 9.136 should be replaced to ensure factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Rep 22469, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.4.

2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including the references to the specific Critical Drainage Areas (CDAs) that affect the development, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.

Paragraph 9.164 should be replaced to ensure factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Reps 22473 the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.18.

2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including the references to the specific Critical Drainage Areas (CDAs) that affect the development, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.

Paragraph 9.176 should be replaced to ensure factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Reps 22477, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.13.

2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including the references to the specific Critical Drainage Areas (CDAs) that affect the development, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.

Paragraph 9.185 should be replaced to ensure factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Reps 22480, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.25.

2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including the references to the specific Critical Drainage Areas (CDAs) that affect the development, will provide clarity to applicants and decisions makers of the need for consideration of specific CDAs at the beginning of the planning process.

Paragraph 9.190 should be replaced to ensure factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Reps 22482, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in ECC’s Hearing Statement G7AN – paragraph 1.25.

2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including links back to the sustainable drainage and flood risk policies in the Local Plan, will provide clarity to applicants and decisions makers of the need for consideration of flooding matters at the beginning of the planning process.

Clarification in respect of Floods and SuDS should be inserted after paragraph 9.193, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Rep 22483 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

2. Not Justified
3. Not Effective
4. Not Consistent with National Policy

ECC as the Lead Local Flood Authority (LLFA) for BBC consider that the inclusion of site specific text within the supporting text of the site specific policies, in particular, including links back to the sustainable drainage and flood risk policies in the Local Plan, will provide clarity to applicants and decisions makers of the need for consideration of flooding matters at the beginning of the planning process.

Clarification in respect of Floods and SuDS should be inserted after paragraph 9.196, in line with paragraphs 159 and 160 of the NPPF.

This reflects ECC’s Reg.19 Rep 22485 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

2. Not Justified

ECC as the Lead Local Flood Authority advises that this site is not identified as being within a Critical Drainage Area (CDA).

In order to ensure factual representation of the current position in respect of flooding Criterion 2. of Policy R25 should be deleted.