Schedule of Potential Main Modifications
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Schedule of Potential Main Modifications
MM94
Representation ID: 29684
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.
Replace Paragraph 9.141 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of NPPF.
This reflects ECC’s Reg.19 Rep 22458, position in Statement of Common Ground (F17D) between BBC and ECC, and 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 9.141 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 22458 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.
Object
Schedule of Potential Main Modifications
MM95
Representation ID: 29685
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.
Replace Paragraph 9.145 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of NPPF.
This reflects ECC’s Reg.19 Rep 22459, position in Statement of Common Ground (F17D) between BBC and ECC, and 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 9.145 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 22459 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.
Object
Schedule of Potential Main Modifications
MM96
Representation ID: 29686
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.
Replace Paragraph 9.149 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of NPPF.
This reflects ECC’s Reg.19 Rep 22461, position in Statement of Common Ground (F17D) between BBC and ECC, and 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 9.149 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 22461 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.
Object
Schedule of Potential Main Modifications
MM97
Representation ID: 29687
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.
Replace Paragraph 9.153 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of NPPF.
This reflects ECC’s Reg.19 Rep 22462, position in Statement of Common Ground (F17D) between BBC and ECC, and 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 9.153 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 22462, 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.
Object
Schedule of Potential Main Modifications
MM98
Representation ID: 29688
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.
Replace Paragraph 9.159 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of NPPF.
This reflects ECC’s Reg.19 Rep 22463, position in Statement of Common Ground (F17D) between BBC and ECC, and 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 9.159 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 22463, 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.
Object
Schedule of Potential Main Modifications
MM109
Representation ID: 29693
Received: 10/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
It is unclear to ECC as highway and transportation authority why ‘Demand Responsive Travel’ has been included within criterion 2.d., as it is considered to be part of passenger transport. Reference to ‘Demand Responsive Travel' should be deleted and ‘public’ changed to ‘passenger’.
3. Not Effective
It is unclear to ECC as highway and transportation authority why ‘Demand Responsive Travel’ has been included within criterion 2.d., as it is considered to be part of passenger transport. Reference to ‘Demand Responsive Travel' should be deleted and ‘public’ changed to ‘passenger’.
Object
Schedule of Potential Main Modifications
MM110
Representation ID: 29694
Received: 10/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3. Not Effective
It is unclear to ECC as highway and transportation authority why ‘Demand Responsive Travel’ has been included within criterion 1.d, as it is considered to be part of passenger transport. Reference to ‘Demand Responsive Travel’ should be deleted and ‘public’ changed to ‘passenger’.
3. Not Effective
It is unclear to ECC as highway and transportation authority why ‘Demand Responsive Travel’ has been included within criterion 1.d, as it is considered to be part of passenger transport. Reference to ‘Demand Responsive Travel’ should be deleted and ‘public’ changed to ‘passenger’.
Object
Schedule of Potential Main Modifications
MM109
Representation ID: 29695
Received: 10/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3.Not Effective
ECC welcomes the inclusion of criterion 2.e within Policy E11, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.
In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.
3.Not Effective
ECC welcomes the inclusion of criterion 2.e within Policy E11, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.
In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.
Object
Schedule of Potential Main Modifications
MM110
Representation ID: 29696
Received: 10/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3.Not Effective
ECC welcomes the inclusion of criterion 1.c. within Policy E12, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.
In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.
3.Not Effective
ECC welcomes the inclusion of criterion 1.c. within Policy E12, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.
In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.
Object
Schedule of Potential Main Modifications
MM111
Representation ID: 29697
Received: 10/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
3.Not Effective
ECC welcomes the inclusion of criterion 1.d. within Policy E10, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.
In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.
3.Not Effective
ECC welcomes the inclusion of criterion 1.d. within Policy E10, however it should be amended to be consistent with criteria in other Local Plan site allocation policies.
In order to futureproof the policy and ensure that development provides the appropriate walking and cycling provision in the future, in line with NPPF 92.c, 104 c, 106d, the supporting text needs to provide clarity on the types of other ‘relevant evidence’ which is referenced in the Policy. It needs to be made clear that such evidence should include details on future key destinations and attractors for walking and cycling connections.
