Object

Representation ID: 29628

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

2. Not Justified
3. Not Effective

There are some junctions where traffic flows appear to have been underestimated in the Transport Assessment 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.

Paragraph 5.128 needs to be amended to provide this flexibility.

This reaffirms ECC's position as set out in its Hearing Statement F76A.

Object

Representation ID: 29629

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

2. Not Justified
3. Not Effective

ECC as highway and transportation authority notes that a comprehensive and deliverable package of sustainable transportation interventions is required to reduce Local Plan impacts and a number of options are set out in the Transport Assessment (2021). Further consideration of the most effective measures can be achieved as part of a sustainable transport strategy, developed in consultation with ECC as Highway Authority for BBC and other relevant statutory consultees and stakeholders.

Paragraph 5.131 needs to be amended to reflect this position.

This reaffirms ECC position as set out its Hearing Statement F76A.

Object

Representation ID: 29630

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3.Not Effective

ECC as highway and transportation authority welcomes the modification to criteria A and C of the policy, as well as the deletion of original criterion B. The modifications provide clarity in relation to the current position in respect of parking policy.

A further amendment is sought to criterion A to ensure the policy is effectively worded. This would be consistent with recently adopted policy on parking in the Chelmsford City Council Local Plan.

This reflects ECC’s Reg.19 Rep 22387, position in Statement of Common Ground (F17D) between BBC and ECC, and reaffirms ECC’s position as expressed at EIP.

Object

Representation ID: 29631

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

4. Not Consistent with National Policy

ECC objects to the removal of the word “significant”. Criterion A.a. should be strengthened to ensure that there is efficient use of employment land, and to avoid the provision of a “token” amount of employment land to allow release of large amounts of employment land.

Object

Representation ID: 29632

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

ECC as Education Authority notes that community use of playing fields and sports facilities of educational establishments can place operational and / or financial burdens on such establishments if not appropriately planned for and funded.

Criterion D of Policy PC15 needs to be amended to make it clear to applicants and decision makers that such use should be paid for and the financial burden does not fall on the educational establishment.

This reflects ECC’s position as set out in paragraph 1.3 of its Hearing Statement F128A.

Object

Representation ID: 29633

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

ECC as Lead Local Flood Authority recommends that paragraph 8.57 is amended to provide the correct technical term for the assessment in relation to infiltration.

Object

Representation ID: 29634

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

To be consistent with the wording associated with DH01f the title needs to include the word ‘Active’.

This reflects ECC’s Reg.19 Rep 22435 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Object

Representation ID: 29635

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

2. Not Justified
3. Not Effective

DH02b in paragraph 9.21 needs to be amended to allow for the appropriate opportunities for all learners of all ages to be considered, and to be consistent with the proposed modification to paragraph 9.72 (MM85).

This reflects ECC’s Reg.19 Rep 22436 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Object

Representation ID: 29636

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

4. Not Consistent with National Policy

The proposed modification to remove reference to Garden City Principles in criterion 3. is inconsistent with Paragraph 73.c of the NPPF, which includes the use of Garden City Principles to set clear expectations for the quality and maintenance of places.

Reference to Garden City Principles needs to be reinstated to reflect this.

This reflects ECC’s Reg.19 Rep 22438 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Object

Representation ID: 29637

Received: 08/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

4.Not Consistent with National Policy

Refer NPPF Paragraph 73 b -sufficient access to services and employment opportunities within development (without unrealistic level of self-containment), or in larger towns (good access).

Given scale of population growth proposed, constrained access to employment opportunities at nearby economic centres, and mixed-use nature of Village / local centres, criterion 5 should state “at least 5.5 hectares of employment development” instead of “around 5.5 hectares”.

To ensure demand and values are sufficient to induce development, criterion 5 needs to state “distributed across the Employment Hub and Village / local centres” instead of “distributed across the village”.