Schedule of Potential Main Modifications
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Schedule of Potential Main Modifications
MM70
Representation ID: 29576
Received: 04/11/2021
Respondent: Essex County Council
Legally compliant? Yes
Sound? No
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.
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
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.
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
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).
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 the DHGV site allocation as part of its Regulation 19 consultation responses and has agreed this position with BBC in the Statement of Common Ground (F17D).
As currently drafted ECC is not satisfied that the wording proposed within criteria 7 a, b, c and d of Policy R01 (i) will ensure the education and childcare requirements are provided for on-site.
It is considered that criterion 7. a. as currently drafted is misleading. 7.9ha of land allows sufficient space for a secondary school only. To co-locate a primary school and EYCC facility with the secondary school requires an additional 2.1ha of land.
This reflects ECC’s position as set out in the 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
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.
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
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’.
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
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.
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.
Insert additional wording after paragraph 9.40 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 22434 and the position in the Statement of Common Ground (F17D) 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
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.
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
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.
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 9.97 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 22445, the position in the Statement of Common Ground (F17D) between BBC and ECC, and the 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
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.
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
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.
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, and 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 specific CDAs at the beginning of the planning process.
Paragraph 9.112 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.
