Schedule of Potential Main Modifications
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Schedule of Potential Main Modifications
MM117
Representation ID: 29618
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
Policy BE14 – Sustainable Passenger Transport
3. Not Effective
ECC as highway and transportation authority recommends that this is included in Local Plan Monitoring Framework in order to ensure that full sustainable modes of travel can be monitored. Considered particularly important given strong reliance on sustainable travel as transport mitigation measure in Local Plan, Transport Assessment, and IDP.
For example, it is unclear how success of criterion B of Policy BE14 could be measured and achieved without regular monitoring of capacity and frequency of bus services.
Reaffirms ECC’s position set out in Examination Statement F125A - paragraphs 1.2 and 1.3.
Policy BE14 – Sustainable Passenger Transport
3. Not Effective
ECC as highway and transportation authority recommends that this is included in Local Plan Monitoring Framework in order to ensure that full sustainable modes of travel can be monitored. Considered particularly important given strong reliance on sustainable travel as transport mitigation measure in Local Plan, Transport Assessment, and IDP.
For example, it is unclear how success of criterion B of Policy BE14 could be measured and achieved without regular monitoring of capacity and frequency of bus services.
Reaffirms ECC’s position set out in Examination Statement F125A - paragraphs 1.2 and 1.3.
Object
Schedule of Potential Main Modifications
MM117
Representation ID: 29619
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
BE15 (now BE11) - Electric and Low-Emission Vehicles
3. Not Effective
Delivery of electric charging points is key to other sustainability and climate change policies in the Local Plan. It is recommended that setting minimum standards should be considered rather than simply reviewing the policy. The target and action should be amended to reflect this.
This would ensure consistency with paragraph 112 of the NPPF, and ECC’s proposed amendments to Policy BE15 – MM26.
BE15 (now BE11) - Electric and Low-Emission Vehicles
3. Not Effective
Delivery of electric charging points is key to other sustainability and climate change policies in the Local Plan. It is recommended that setting minimum standards should be considered rather than simply reviewing the policy. The target and action should be amended to reflect this.
This would ensure consistency with paragraph 112 of the NPPF, and ECC’s proposed amendments to Policy BE15 – MM26.
Object
Schedule of Potential Main Modifications
MM117
Representation ID: 29620
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
BE16 (now BE12) - Mitigating the Transport Impacts of Development
3. Not Effective
ECC as highway and transportation authority recommends that Policy BE16 – Mitigating the transport impacts of development, is included in the Local Plan Monitoring Framework in order to ensure that developments are fully mitigated. The monitoring of transport impacts such as traffic generation from developments can determine if / when additional sustainable modes of transport are required, and/or certain physical highway and transportation infrastructure is required.
This reaffirms ECC’s position as set out in its Examination Statement F125A - paragraphs 1.4.
BE16 (now BE12) - Mitigating the Transport Impacts of Development
3. Not Effective
ECC as highway and transportation authority recommends that Policy BE16 – Mitigating the transport impacts of development, is included in the Local Plan Monitoring Framework in order to ensure that developments are fully mitigated. The monitoring of transport impacts such as traffic generation from developments can determine if / when additional sustainable modes of transport are required, and/or certain physical highway and transportation infrastructure is required.
This reaffirms ECC’s position as set out in its Examination Statement F125A - paragraphs 1.4.
Object
Schedule of Potential Main Modifications
MM117
Representation ID: 29621
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
BE17 (now BE13) - Parking Standards
3. Not Effective
The word ‘minimum’ in the first Trigger for Action should be deleted as it does not allow for flexibility such as changes to parking policy in the future.
The Town centre is a sustainable location and the Local Plan should not be encouraging car use by provision of high level of parking. The second monitoring requirement under BE17 (now BE13) should be deleted.
BE17 (now BE13) - Parking Standards
3. Not Effective
The word ‘minimum’ in the first Trigger for Action should be deleted as it does not allow for flexibility such as changes to parking policy in the future.
The Town centre is a sustainable location and the Local Plan should not be encouraging car use by provision of high level of parking. The second monitoring requirement under BE17 (now BE13) should be deleted.
Object
Schedule of Potential Main Modifications
MM10
Representation ID: 29622
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
2.Not Justified
3.Not Effective
4.Not Consistent with National Policy
ECC as the highway and transportation authority considers that the review policy MG06 gives Brentwood Borough Council the opportunity to address not only the highways and transportation matters raised by National Highways, but also those matters raised by ECC, as set out in Hearing Statement F76A (its response to F65 the latest published Transport Assessment) and reiterated at the EIP. In particular the summaries set out in Paragraphs 1.8 and 1.9 of F76A.
Criterion D of Policy MG06 should be modified to explicitly reflect this position.
2. Not Justified
3. Not Effective
4. Not Consistent with National Policy
ECC as the highway and transportation authority considers that the review policy MG06 gives Brentwood Borough Council the opportunity to address not only the highways and transportation matters raised by National Highways, but also those matters raised by ECC, as set out in Hearing Statement F76A (its response to F65 the latest published Transport Assessment) and reiterated at the EIP. In particular the summaries set out in Paragraphs 1.8 and 1.9 of F76A (set out below).
ECC is generally satisfied with regard to the assumptions underpinning the modelling approach, its outputs in terms of reasonable traffic flows, and the infrastructure and junction mitigation measures identified as necessary. However, there are some junctions where traffic flows appear to have been underestimated and therefore the impacts of Local Plan growth may also be understated. This includes the junctions along Brook Street between the M25 and Brentwood Town Centre. More robust analysis will therefore be required through the planning application process for relevant sites, which in turn could necessitate additional infrastructure improvements.
It is noted that a comprehensive and deliverable package of sustainable transportation interventions is likely to be required to reduce Local Plan impacts where a physical infrastructure improvement is not possible or viable. BBC are seeking to develop a sustainable transport strategy which will provide greater detail. ECC as the local highway and transportation authority would be involved with this process.
Criterion D of Policy MG06 should be modified to explicitly reflect this position.
Object
Schedule of Potential Main Modifications
MM19
Representation ID: 29623
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
4. Not Consistent with National Policy
ECC as Lead Local Flood Authority (LLFA) for BBC are satisfied in principle with the amended policy for BE08 Sustainable Drainage.
However, criterion D needs to include reference to Flood Risk Assessment to ensure the link to the Flood Risk Policy in the Local Plan is clear to applicants and decision makers.
3. Not Effective
4. Not Consistent with National Policy
ECC as Lead Local Flood Authority (LLFA) for BBC are satisfied in principle with the amended policy for BE08 Sustainable Drainage.
However, criterion D needs to include reference to Flood Risk Assessment to ensure the link to the Flood Risk Policy in the Local Plan is clear to applicants and decision makers.
Object
Schedule of Potential Main Modifications
MM22
Representation ID: 29624
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
Strategic transport infrastructure is required to be delivered to support the Local Plan growth. It is not considered that the word “critical” is necessary in this context. It is therefore recommended that paragraph 5.90 is modified to reflect this.
3. Not Effective
Strategic transport infrastructure is required to be delivered to support the Local Plan growth. It is not considered that the word “critical” is necessary in this context. It is therefore recommended that paragraph 5.90 is modified to reflect this.
Object
Schedule of Potential Main Modifications
MM25
Representation ID: 29625
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
The inclusion of the additional wording after paragraph 5.119 in relation to passenger transport having consideration of the ECC’s Development Management Policies is welcomed. This addresses ECC’s Reg.19 Rep 22378 and the position in the Statement of Common Ground (F17D) between BBC and ECC.
A further addition needs to be made to the paragraph in order to reflect Government policy on passenger transport and buses and where ECC’s position on this is detailed.
3. Not Effective
The inclusion of the additional wording after paragraph 5.119 in relation to passenger transport having consideration of the ECC’s Development Management Policies is welcomed. This addresses ECC’s Reg.19 Rep 22378 and the position in the Statement of Common Ground (F17D) between BBC and ECC.
A further addition needs to be made to the paragraph in order to reflect Government policy on passenger transport and buses and where ECC’s position on this is detailed.
Object
Schedule of Potential Main Modifications
MM26
Representation ID: 29626
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
4. Not Consistent with National Policy
As currently worded the policy is not considered to be consistent with paragraph 112 of the NPPF.
This reflects ECC’s Reg.19 Rep 22380.
4. Not Consistent with National Policy
As currently worded the policy is not considered to be consistent with paragraph 112 of the NPPF.
This reflects ECC’s Reg.19 Rep 22380.
Object
Schedule of Potential Main Modifications
MM27
Representation ID: 29627
Received: 08/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
4. Not Consistent with National Policy
The wording in criterion A needs to be amended to ensure that the policy is positively prepared, and is consistent with paragraph 110 of the NPPF, particularly 101 d.
This reflects ECC’s Reg.19 Rep 22386 and the position in the Statement of Common Ground (F17D) between BBC and ECC.
4. Not Consistent with National Policy
The wording in criterion A needs to be amended to ensure that the policy is positively prepared, and is consistent with paragraph 110 of the NPPF, particularly 101 d.
This reflects ECC’s Reg.19 Rep 22386 and the position in the Statement of Common Ground (F17D) between BBC and ECC.
