Object

Representation ID: 29650

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

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

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

ECC welcome new paragraph after 9.229 - ensures factual representation of current flooding position - in line with NPPF 159 and 160.

Recommend CDA reference number ‘NBTW_IN002’ included - consistency with other supporting text.

Reflects ECC’s Reg.19 Rep 22508 and position in Hearing Statement G7AN – paragraph.1.25.

Object

Representation ID: 29651

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3.Not Effective
4.Not consistent with National Policy

Replace criterion 9 wording ‘sustainable transport hub’ with ‘Mobility Hub’ to ensure consistency of wording with remainder of Policy R01 (i) and Policy R01 (ii).

Policy and supporting text are silent on what constitutes ‘Mobility Hub’. Provide clarity in supporting text.

Replace ‘that should relate well to’ with ‘within’ to provide clarity on intended location.

Insert additional wording at end of sentence to reference subsidiary hubs within local centres on site to ensure all residents and businesses within site allocation have reasonable access to mobility hubs - in line with NPPF 112.

Object

Representation ID: 29652

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

Criterion A.1. needs to be amended to make it clear what is required of the applicant.

Object

Representation ID: 29653

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective
4. Not Consistent with National Policy

As currently drafted, criterion A.2.d. indicates that highway and other sustainable modes of travel should be identified separately. Reference needs to be made to ‘movement corridors’ rather than ‘internal highway links’ to ensure that the design of DHGV minimises the scope for conflict between pedestrians, cyclists and vehicles, as set out in paragraphs 110 and 112 of the NPPF.

Object

Representation ID: 29654

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective
4. Not Consistent with National Policy

Identifying the locations of infrastructure for sustainable transport within criterion A.2.j. will assist applicants and decision makers in assessing whether the full range of measures are catered for, in line with paragraph 110 of the NPPF.

Object

Representation ID: 29655

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective
4. Not consistent with National Policy

The wording in criterion A.2.l.iii. needs to be amended in order to ensure that all residents and businesses within the site allocation have access to a range of sustainable travel options within the site and beyond, in line with paragraphs 106, 110 and 112 of the NPPF.

Object

Representation ID: 29656

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

As currently worded it is not clear to an applicant or decision maker what criterion A.3.d. is seeking to achieve, particularly with references to ‘fine-grain’ and street-based’.

The wording needs be amended to make it clear that the layout should prioritise movement by sustainable modes of transport. This would be in line with paragraph 110 of the NPPF.

Object

Representation ID: 29657

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

Reference to walking and cycling should be included in criterion A.3.e. as these forms of movement can utilise multi-functional green infrastructure. This would be in line with paragraph 110 of the NPPF.

Object

Representation ID: 29658

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

Criterion A.3.i. needs to be amended to ensure that it applies to the full public rights of way (PRoW) network on site. This would be in line with paragraph 100 of the NPPF.

Object

Representation ID: 29659

Received: 09/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

3. Not Effective

Criterion B.1. needs to be amended to reflect other parts of the DHGV policies, ensuring that the phasing and implementation plan is not just submitted but obtains approval.