3.Not Effective

ECC welcomes the inclusion of criterion 1.b. within Policy E13, 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.b. within Policy E08, 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

In order to ensure that all highway works are identified, including site access from the highway, criterion 4.a. needs to be amended.

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 supporting text for the site specific policies, in particular, including reference 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 flooding matters at the beginning of the planning process.

ECC therefore welcome the proposed modifications to include the new paragraph after 9.214 as it ensures factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

ECC would recommend that the last sentence is amended to provide the links back to the sustainable drainage and flood risk policies in the Local Plan.

This reflects ECC’s Reg.19 Rep 22504, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in its Hearing Statement G7AN – paragraph 1.42.

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 supporting text for the site specific policies, in particular, including reference 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 flooding matters at the beginning of the planning process.

ECC therefore welcome the proposed modifications to include the new paragraph after 9.219 as it ensures factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

ECC would recommend that the last sentence is amended to provide the links back to the sustainable drainage and flood risk policies in the Local Plan.

This reflects ECC’s Reg.19 Rep 22506, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in its Hearing Statement G7AN – paragraph 1.42.

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 supporting text for the site specific policies, in particular, including reference 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 flooding matters at the beginning of the planning process.

ECC therefore welcome the proposed modifications to include the new paragraph after 9.224 as it ensures factual representation of the current position in respect of flooding, in line with paragraphs 159 and 160 of the NPPF.

ECC would recommend that the last sentence is amended to provide the links back to the sustainable drainage and flood risk policies in the Local Plan.

This reflects ECC’s Reg.19 Rep 22507, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the position in its Hearing Statement G7AN – paragraph 1.42.

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

The inclusion of a requirement for Health Impact Assessments (HIA) to be undertaken for hot food takeaways in the Policy is strongly supported by ECC given its responsibilities for Public Health.

However, to ensure borough wide consideration of such matters this requirement should be required both within, and outside, designated town, district or local centres. This is not the case as currently proposed in criterion A of the Policy.

The level of detailed required for an HIA and work required for applicants to undertake is proportionate depending on the type and nature of development, as well as its location. The HIA stepped process allows for consideration of the type of HIA required on a case by case basis, with the level of detail required varying from a desktop based short review to a full comprehensive assessment. This approach is outlined on page 9 of the Essex Planning Officers’ Association (EPOA) HIA Guidance Note – Essex Healthy Places – Advice Notes for Planners, Developers and Designers.