Comment

Representation ID: 16088

Received: 11/05/2016

Respondent: Essex County Council

Paragraph 3 - Reference to residential travel plans should be amended to refer to `travel plans'
Paragraph 6 - Recommend the deletion of `where appropriate' as cycle improvements will be necessary in the majority of new development.
Paragraph 7 - The paragraph refers to new development close to schools/early years facilitating a public realm. In addition, the development of new schools/early years facilities also need to consider walking and cycling connectivity. Reference to `school run traffic' should be deleted.

Support

Representation ID: 16089

Received: 11/05/2016

Respondent: Essex County Council

Paragraph 10.40 - Welcome the definition of `infrastructure' and reference to utilities and waste; transport; social and community; and green infrastructure.

Comment

Representation ID: 16091

Received: 11/05/2016

Respondent: Essex County Council

Paragraph 1 - Reference to Internal Drainage Boards should be removed as there are none in Essex.
Paragraph - `Where development is permitted within.......' - Recommend that in addition to the categorization of developments into different flood risk zones as outlined in the Brentwood SFRA, development proposals should also be viewed in terms of the location of the proposed development within a Flooding Hotspot as identified in the Brentwood SWMP.

Comment

Representation ID: 16092

Received: 11/05/2016

Respondent: Essex County Council

Paragraph 10.70 - Where a flood risk assessment is required for development within flood zone 1, specifically looking at surface water and ground water flood risk, the Flood Risk Assessment should be approved by the Lead Local flood Authority(LLFA), namely ECC, as part of our role as a statutory consultee to the planning process. Furthermore, a drainage strategy should be approved for all major development within the borough to ensure that development will not increase flood risk to the site or surrounding areas.

Comment

Representation ID: 16093

Received: 11/05/2016

Respondent: Essex County Council

Criterion a) - allowable brownfield discharge rates are confusing. Reference to discharge at current brownfield rates should be deleted.
Criterion b) - a drainage strategy should be submitted for any site over 0.1 ha
Criterion c) - current best practice now requires developers to use an index based approach when managing water quality rather than requiring a specific number of treatment. This section of the policy should be updated and should refer developers to chapter 26 of the updated CIRIA SuDS Manual for more information about this approach.

In addition, ECC would expect only the first 4-5mm of any storm event to be managed within the site. A requirement of 10mm may be considered too onerous for many developers to achieve especially onsite where infiltration potential is very low.

Comment

Representation ID: 16095

Received: 11/05/2016

Respondent: Essex County Council

Paragraph 10.74 - a drainage strategy should be submitted for any site over 0.1 ha.
Paragraph 10.76 - updates to the legislation mean that schedule 3 of the Flood and Water Management Act (FWMA) was not implemented, and therefore the LLFA did not become the SuDS approval body. Instead the LLFA was made a statutory consultee to the planning process and will provide advice to the local planning authority about the suitability of proposed drainage schemes.

Comment

Representation ID: 16096

Received: 11/05/2016

Respondent: Essex County Council

The policy refers to `no unacceptable adverse impacts' effect on water quality or flooding, watercourses, biodiversity or important wildlife habitats. However it is not clear what would be considered unacceptable. ECC recommends the policy refers to the SuDs Design Guide with regards appropriate standards.

Support

Representation ID: 16097

Received: 11/05/2016

Respondent: Essex County Council

Paragraph 10.16 - Supports reference to providing institutional uses close to where people live and work.

Comment

Representation ID: 16098

Received: 11/05/2016

Respondent: Essex County Council

Should include reference to ensuring that children and young people can walk or cycle to school safely on designated safe routes through new developments. Such routes should be planned from the outset of development and not retrofitted into a scheme's design;`regard should be given as to how residents will access the nearest primary and secondary school provision by foot, ensuring that the route is safe and convenient.'

Comment

Representation ID: 16099

Received: 11/05/2016

Respondent: Essex County Council

The policy does not make explicit reference to traffic congestion, which is often the leading contributor to local air pollution. ECC supports the recommendation of the Interim SA (para 10.1.6) that reference is made to Policy 10.1: Sustainable Transport, to encourage this link.