Schedule of Potential Main Modifications

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Object

Schedule of Potential Main Modifications

MM70

Representation ID: 29576

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

2. Not Justified

The supporting text to Policy PC 15 needs to include reference to Post 16 education and skills to ensure the full range of education provision is considered.

This reflects ECC’s Reg.19 Rep 22414 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Object

Schedule of Potential Main Modifications

MM70

Representation ID: 29577

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

2. Not Justified

Additional paragraphs should be inserted at the end of this section relating to Special Education Needs (SEN) to ensure that the full range of education provision is identified and considered.

This reflects ECC’s Reg.19 Rep 22275 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Object

Schedule of Potential Main Modifications

MM84

Representation ID: 29578

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

2. Not Justified
4. Not Consistent with National Policy

ECC as appropriate authority with responsibilities for education provided BBC with education and childcare requirements for DHGV at Reg.19 and agreed position in Statement of Common Ground (F17D).

ECC is not satisfied that wording in criteria 7 a, b, c and d of Policy R01 (i) will ensure education and childcare requirements are provided for on-site.

Criterion 7. a. is misleading. 7.9ha of land allows sufficient space for secondary school only. Additional 2.1ha required to co-locate with primary school/EYCC.

This reflects ECC’s position in Statement of Common Ground with BBC (F17D).

Object

Schedule of Potential Main Modifications

MM85

Representation ID: 29579

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Not Effective
4. Not Consistent with National Policy

Criteria A.2.g and A.2.i need to be combined to ensure that all sustainable travel links are identified, in line with paragraph 110 of the NPPF.

Object

Schedule of Potential Main Modifications

MM85

Representation ID: 29580

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Not Effective

In order to ensure the consistency with other parts of the policy and to ensure the criteria under A.3. are secured the word ‘should’ needs to be replaced with ‘shall’.

Object

Schedule of Potential Main Modifications

MM85

Representation ID: 29581

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

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 reference to potential risk of flooding, and links to sustainable drainage and flood risk Local Plan policies, provides clarity to applicants/decisions makers of need for consideration of flooding matters at beginning of planning process.

Insert additional wording after para.9.40 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of NPPF.

Reflects ECC’s Reg.19 Rep 22434 and Statement of Common Ground (F17D) position between BBC and ECC.

Object

Schedule of Potential Main Modifications

MM85

Representation ID: 29582

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

3. Not Effective

In order to strengthen the supporting text in paragraph 9.82, in relation to employment and skills, reference to the adoption of Employment and Skills Plans should be referenced.

This reflects ECC’s Reg.19 Rep 22443 and the position in the Statement of Common Ground (F17D) between BBC and ECC.

Object

Schedule of Potential Main Modifications

MM86

Representation ID: 29583

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

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 9.97 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of the NPPF.

Reflects ECC’s Reg.19 Rep 22445, position in Statement of Common Ground (F17D) between BBC and ECC, and position in ECC’s Hearing Statement G7AN – paragraph 1.25.

Object

Schedule of Potential Main Modifications

MM87

Representation ID: 29585

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

2. Not Justified
4. Not Consistent with National Policy

ECC as the appropriate authority with responsibilities for education covering Brentwood Borough Council (BBC) has provided BBC with the education and childcare requirements (land size in hectares, use class allocation, and type of facility – Primary, Secondary, Early Years and Childcare) for this site allocation.

As currently drafted ECC is not satisfied that the wording proposed within criterion 1.b. will ensure that land for education purposes will be secured.

This reaffirms ECC’s position in paragraph 1.5 of its Hearing Statement F127B.

Object

Schedule of Potential Main Modifications

MM88

Representation ID: 29586

Received: 04/11/2021

Respondent: Essex County Council

Legally compliant? Yes

Sound? No

Representation Summary:

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 9.112 to ensure factual representation of current flooding position, in line with paragraphs 159 and 160 of the NPPF.

Reflects ECC’s Reg.19 Rep 22453, position in Statement of Common Ground (F17D) between BBC and ECC, and position in ECC’s Hearing Statement G7AN – paragraph 1.18.

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