ms joanne woodward our ref: ne/2006/000004/cs- redbridge borough council · cont/d.....

$: Ms Joanne Woodward Our ref: NE/2006/000004/CS- Redbridge Borough Council · Cont/d.. :\Users\agoymer\Desktop\Redbridge Reg 19 - Final Draft.docx 3 Part B - If necessary please use$
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Ms Joanne Woodward Redbridge Borough Council [email protected]

Our ref: NE/2006/000004/CS-05/SB1-L01 Date: 30 September 2016

Dear Ms Woodward Local Plan (Regulation 19): Pre-Submission Draft Thank you for consulting us on the above proposed submission document. We have made representations on the following:

LP21: Water and Flooding

LP21: Pollution

LP27: Tall Buildings

LP32: Sustainable Design and Construction

LP37: Green Infrastructure and Blue Ribbon Network

LP39: Nature Conservation and Biodiversity Please find our representations appended to this letter. I appreciate that it will take some time for you to read and digest all of the comments received in relation to this consultation but feel that it would be useful for us to meet and discuss the issues raised. Please contact me as soon as possible to arrange a suitable date. If you have any questions please call me on 0203 025 5486. Yours sincerely Mr Andy Goymer Planning Advisor Telephone: 0203 025 5486

E-mail: [email protected]

Address: Environment Agency, Ergon House, Horseferry Road, London SW1P 2AL

mailto:[email protected]


Cont/d.. :\Users\agoymer\Desktop\Redbridge Reg 19 - Final Draft.docx

2

Ref:

(for official use only)

Local Plan

Publication stage representation form

(Regulation 19)

This form has two parts: Part A – Personal Details Part B - Your representation (s). Please fill in a separate Part B for each representation you wish to make. Part A

Please return to London Borough of Redbridge by 30th September 2016 5pm

1. Personal Details1 2. Agent’s Details

Title Mr

First Name Andy

Last Name Goymer

Job Title (where relevant

Planning Advisor

Organisation (where relevant)

Environment Agency

Address Line 1 Ergon House

Address Line 2 Horseferry Road

Address Line 3 London

Post Code SW1P 2AL

Telephone Number

0203 025 5486

Mobile

Email address [email protected]

1 If an agent is appointed, please complete only the Personal Details, Title, Name and Organisation boxes, but complete the full contact details for Agent. www.redbridge.gov.uk





3

Part B - If necessary please use a separate sheet for each response Name or Organisation: Environment Agency

Due to the lack of evidence supporting Policy LP21 we find it unsound as it is not ‘justified’ or ‘Consistent with National Policy’. The Local Plan has provided very generic planning policy in relation to flood risk. Ideally, we would like to see this tailored to the local area (using SFRA). Local Plans can help to ensure that new developments are resilient over their lifetime and help improve the sustainability of existing communities. Managing flood risk can also improve the economic prospects of communities and improve the information. Planning for flooding can also help improve water quality, enhance biodiversity, and increase recreation opportunities. It is currently unclear from reading the Local Plan, Pre-Submission Draft, July 2016 and associated Sustainability Appraisal how the Council have used the findings and recommendations of the Strategic Flood Risk Assessment (SFRA) to apply the Sequential Test and influence the proposed areas of growth and opportunity. Although the plan acknowledges the SFRA and Thames River Basin Management Plan (RBMP), there is no evidence to suggest that it has been written in accordance with the recommendations made in either of these reports.

3. To which part of the Local Plan does this relate?

Paragraph Policy LP21 Policies Map

4. Do you consider the Local Plan is (tick):

4. (1) Legally compliant X Yes No

4. (2) Sound Yes X No

4. (2a) If No, then which of the ‘Soundness test’ does it fail?

Positively Prepared

Justified

Effective

Consistent with National Policy

X

X

4. (3) Complies with the Duty to co-operate

X Yes No

5. Please give details of why you consider the Local Plan is not legally

compliant or is unsound or fails to comply with the duty-to-cooperate.

Please be as detailed as possible. If you wish to support the legal

compliance or soundness of the Local Plan or its compliance with the duty

to co-operate, please also use this box to set out your comments.


4

Paragraph 100 of the NPPF requires LPAs to do this at the strategic level. The Sequential Test should not simply be a test for the planning application stage. The Level 2 SFRA will help you to determine if a site/area could pass the exceptions test (in principle) and whether it’s possible a site can mitigate flood risk. We are also concerned that the plan also only appears to acknowledge surface water and fluvial flood risk and not the risk from tidal sources – as identified within the SFRA. Whilst we support the Local Plans desire to reduce flood risk for new development, further emphasis should be given to help existing communities at risk of flooding. The Sustainability Appraisal does not specifically address flood risk management – only in relation to houses. There is no mention of flood defences or reducing flood risk to existing areas. This could be addressed through the creation of flood defence/alleviation schemes or retrofitting SuDS where required. We would like to see a policy included in the Local Plan that ensures new development does not detrimentally impact upon existing / proposed flood defence structures / systems (and in certain areas contributes to establishing / maintaining flood defence structures / systems). We feel that the wording in some areas of the policy and supporting text could be stronger with a commitment to reducing flood risk and improving watercourses. Recommended amendments have been provided below. Although covered within the SFRA, a commitment should also be made within the Local Plan to safeguard Flood Zone 3b, the functional floodplain – land where water has to flow or be stored in times of flood. We strongly support the provision of a minimum 8m ‘buffer zone’ alongside watercourses as and a desire to open up existing culverts where possible. This is in line with the River Basin Management Plan and Water Framework Directive. We would like to see the policy to go further by encouraging developers to make financial contributions to other projects to enhance or deculvert rivers when deculverting on their site is deemed unviable. It was positive to see that the risks of water consumption, distribution and disposal were acknowledged (Paragraph 4.4.1). As identified within an area of water stress, it is recommended that such risks and appropriate mitigation measures be reflected in the corresponding policy LP21, which currently focus on impacts of flooding and resilience measures. This could be done through the planning process where buildings can be developed to ensure less energy is used for water transportation and disposal. It could be an option within LP21, to reference LP32 Sustainable Design and Construction detailing water efficient measures and optimising resource efficiency.

6. Please set out what modification(s) you consider necessary to make the

Local Plan legally compliant or sound, having regard to the test you have

identified at question 5 above where this relates to soundness. (NB) please

note that any non-compliance with the duty to co-operate is incapable of

modification at examination). You will need to say why this modification

will make the Local Plan legally compliant or sound. It will be helpful if you

are able to put forward your suggested wording of any policy or text.

Please be as detailed as possible.


5

To comply with the NPPF, Policy LP21 should be updated to include the areas highlighted above. The Plan will need to demonstrate the Sequential Test has been applied for strategic sites and allocations based on the findings and recommendations of the SFRA. We also recommend the following amendments or corrections to the existing wording. To comply with the NPPF, the London Borough of Redbridge (LBR) will need to demonstrate how they have applied the Sequential Test for strategic sites and allocations based on the findings and recommendations of the SFRA. LP21: Existing: The Council will seek to ensure that development does not increase flood risk and reduces the risk of flooding where possible. Suggested amendment: The Council will seek to ensure that development does not increase flood risk and implement opportunities to reduce the risk of flooding overall. LP21: 1a – Existing text: “Requiring development on land that is at risk of flooding as identified in the Council’s SFRA to comply with the Sequential Test and (where appropriate) the Exception Test, as set out in the NPPF and accompanying Technical Guidance. …” This paragraph creates the impression that the LPA are not taking a strong enough stance on preventing development in flood risk areas. We recommend an additional point be included before this, stating that development in areas of high flood risk will be avoided. LP21: 1b iv - Strategic Flood Risk Assessment. LP21: 1c “Incorporating flood resilient measures…” This is not very detailed. We would prefer to see some guidance or recommendations on what the council consider as appropriate resilient measures. Who will these measures be for? Who will be responsible for them? LP21: 1d - It is encouraging to see a SuDS policy included within the Local Plan but it appears to be restricted to just flood mitigation. SuDS can be useful in slowing down impacts from urban diffuse pollution if designed, used and maintained in the correct manner. This point can also be linked through to Policy LP32: Sustainable Design and Construction. We suggest the following amended wording to ensure a commitment to delivering the greenfield run-off in line with the London Plan. Suggested amendment: Utilising Sustainable Drainage Systems (SuDS) in line with the drainage hierarchy to achieve a greenfield run-off rate where possible. This is supported by paragraph 4.6.3 and the SFRA. The word ‘resisting’ should be removed from paragraphs LP21: 1f and LP21: 1g to provide a stronger commitment to diverting development away from watercourses. LP21: 1f – Suggested amendment - Opposing the further culverting of watercourses and building over culverts. All developments on sites with existing culverts should seek opportunities to de-culvert these streams to reduce flood risk and provide conservation benefits. Where enhancements or deculverting are financially viable but not feasible the Council will seek a financial contribution toward other relevant projects for the enhancement or deculverting of other sections of the waterway. LP21: 1g - Suggested amendment: Development that poses unacceptable risk to the quality of the water catchment, ground water or surface water will not be permitted. Development adjoining water courses or which contains a watercourse within the site boundary should maintain a minimum 8 metre wide (riparian) buffer free of development from the top of the bank of the water course and include measures to enhance the environment of the water course wherever possible.


6

This is in line with the aims of the Water Framework Directive and River Basin Management Plan not to cause a further deterioration in water quality. 4.4.1 – We are pleased to see that the risks of water consumption, distribution and disposal have been acknowledged in paragraph 4.4.1. As Redbridge is within an area of water stress, it is recommended that such risks and appropriate mitigation measures are reflected within policy LP21. It could be an option within LP21, to reference LP32 Sustainable Design and Construction detailing water efficient measures and optimising resource efficiency. 4.4.2 acknowledges the Thames River Basin Management Plan (RBMP). However, we recommend that the Local Plan use the recommendations of the RBMP within policy LP21. The RBMP advises that the Environment Agency and local authorities will ensure that all relevant actions are identified, prioritised, resourced and implemented. The Water Framework Directive (WFD) is also briefly mentioned within the plan however, it fails to identify any measures required to improve the surrounding water bodies and how the Local Authority will aid the Agency in completing WFD actions. 4.4.4 highlights the impact climate change can have on ‘the quantity and quality of our water supply’, referring to policy LP19 (Climate Change Mitigation). Although we support this observation, there is no suggestion of climate change impacting on the quantity and quality of water within LP19. Additionally, there is no reference to water supply or resources within LP21. It is recommended that LBR considers an approach to mitigate the impacts of climate change on water supply, particularly important considering it’s already in an area under ‘water stress’. This can be, in part, done through the planning process and building design (see comments below on LP32 for further information), and referenced made to LP32 Sustainable Design and Construction. We would recommend working closely with water supply organisations who monitor the current water usage, as information of household water consumption can give clear trends and targets for reduction. The use of unit ‘litres per person per day’ is recommended as it corresponds with the Building Regulations 2000. 4.5.1 – This sentence requires rewording. Suggested - The largest river to flow through the borough is the River Roding. Other main rivers include the largely culverted Cran Brook and Seven Kings Water/LoxfordWater. The River Roding (Lower) is affected by the tide from Ilford. 4.5.2 – Amendment required. Current text: “…..to minimise the likelihood of such events being repeated.” It is unclear what ‘events’ this paragraph is referring to. 4.6.1 – Amendment required. The paragraph needs rewording. It would also be an opportunity to include a sentence here about the importance of not taking up areas of natural flood storage – nowhere else in the Plan acknowledges the need to provide flood storage compensation. Suggested - Developing in areas at risk of flooding can increase the risk on and off site. In addition to the increased footprint, replacing naturally vegetated land with impermeable surfaces can increase the burden on surface watercourses, culverts and drainage systems which can increase flood risk. Developments should aim to maximise floodplain and attenuation storage through use of green infrastructure and sustainable drainage measures. There should be no net loss in floodplain storage, or in exceptional circumstances, providing adequate off site compensatory storage on a level for level basis. Overland flow routes should not be obstructed. 4.6.2 – Amendment Required. Although this section mentions different SuDS available for use and their benefits, there is no mention that the use of SuDS is encouraged/recommended by the Local Plan.


7

We recommend that the wording is amended to strengthen the policy LP21: 1d (see comments above). 4.6.3 – We support this paragraph.

We hope to work with the Council to address our comments prior to the examination, however it may be necessary to attend the examination to clarify our position or if the Inspector has specific questions on our representations.

Please note the inspector will determine the most appropriate procedure to adopt to hear who have indicated that they wish to participate in the oral examination.

7. If your representation is seeking a modification, do you consider it necessary

to participate at the oral part of the examination?

No, I do not wish to participate at the oral examination

Yes, I wish to participate at the oral examination

X

8. If you wish to participate at the oral part of the examination, please outline

why you consider this to be necessary

Please note your representation should cover concisely all the information, evidence, and supporting information necessary to support/justify the representation and the suggested d modification, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submission will only be at the request of the Inspector, based on the matters

and issues he/she identifies for the examination.


8


We find policy LP24 unsound as it has failed to demonstrate that it has been influenced by all available evidence in line with paragraphs 158 and 165 of the NPPF. The Local Plan has identified a current lack of information regarding the sewage and drainage infrastructure and network capacity. It is recommended that the Local Plan therefore lists proposals on how to mitigate against current known issues and how the London Borough of Redbridge (LBR) plans to identify and improve infrastructure where required. Policy LP24, and the supporting text should further consider the impact to the natural environment. This includes the impact of diffuse urban pollution on the water catchment. This would support the objectives of the WFD and RBMP which are currently not referred to. The plan is being produced from 2016 to 2030 and should account for population growth within the area.


Paragraph

Policy LP24 Policies Map





Positively Prepared

Justified

Effective


X

X


X Yes No


compliant or is unsound or fails to comply with the duty-to-cooperate.

Please be as detailed as possible. If you wish to support the legal

compliance or soundness of the Local Plan or its compliance with the duty

to co-operate, please also use this box to set out your comments.

10. Please set out what modification(s) you consider necessary to make the

Local Plan legally compliant or sound, having regard to the test you have

identified at question 5 above where this relates to soundness. (NB) please

note that any non-compliance with the duty to co-operate is incapable of

modification at examination). You will need to say why this modification will

make the Local Plan legally compliant or sound. It will be helpful if you are

able to put forward your suggested wording of any policy or text. Please be

as detailed as possible.


9

Policy LP24 should be amended to address the issues highlighted above. We have also made some suggested amendments and corrections below. LP24: 1 Parts (c) and (d) - To improve air quality, and to safeguard against waste fires, we recommend that the Local Plan considers, where appropriate, the full enclosure of waste operations. Suggested wording: All waste storage and treatment activities may only be carried out inside a covered building, enclosed on all sides with access and egress points covered by fast acting doors which default closed. LP24: 1 Parts (e) and (f) should be expanded to include the issues of misconnections. The Local Plan should ensure that all drainage is correctly connected within any new buildings proposed in the growth areas. This would further help reduce water pollution in the Redbridge area and coincide with WFD actions. Furthermore, the wording should be strengthened (replacing ‘resisting’) to ensure that risks of pollution are eliminated. Suggested amendment (LP24 1(e)): development that poses an unacceptable risk to the quality of the water catchment, groundwater or surface water will be refused. LP24 1(f): it is currently unclear how the Local Plan proposes to aid in ‘reducing the runoff of particulates and other forms of biological and chemical pollution to waterways.’ Suggested amendment: reducing the runoff of particulates and other forms of biological and chemical pollution to waterways through sustainable drainage and pollution prevention methods. This should be supported within the supporting text and linked to policy LP32. LP24 1(g): We support this statement. LP24 1(j): Suggested amendment to include the risk of light pollution to watercourses. Resisting development involving floodlights or other external forms lighting (including flashing lights) that would unacceptably impact on the amenity of nearby occupiers at unsocial hours, be likely to distract drivers on the public highway or be likely to disrupt the ecology of watercourses. 4.17.1: Increased lighting levels can affect the natural habitat of rivers and riverbanks. A sentence should be added to 4.17.1 to acknowledge these concerns.





X






10




11


We find LP27 sound. However, we recommend an amendment to acknowledge the potential adverse impact that tall buildings can have on the ecology and amenity of a watercourse. Developers may also be required to set buildings back further than 8m (LP21: 1g) to counteract potential impacts. This issue can be rectified with minor changes to policy wording.


Paragraph




4. (2) Sound X Yes No


Positively Prepared

Justified

Effective



X Yes No


compliant or is unsound or fails to comply with the duty-to-cooperate. Please

be as detailed as possible. If you wish to support the legal compliance or

soundness of the Local Plan or its compliance with the duty to co-operate,

please also use this box to set out your comments.

14. Please set out what modification(s) you consider necessary to make the Local

Plan legally compliant or sound, having regard to the test you have identified

at question 5 above where this relates to soundness. (NB) please note that any

non-compliance with the duty to co-operate is incapable of modification at

examination). You will need to say why this modification will make the Local

Plan legally compliant or sound. It will be helpful if you are able to put forward

your suggested wording of any policy or text. Please be as detailed as

possible.


12

LP27: 1(d) - Recommended amendment: the overshadowing effect the building has on other buildings, public spaces, open spaces and watercourses. This matter should also be clarified within the supporting text.





X Yes, I wish to participate at the oral examination






13


Policy LP32 fails to demonstrate that it has been prepared using all available evidence bases when committing to sustainable design. It was positive to see that the Local Plan identifies the use of property development to reduce the demand on natural resources and help address climate change. We additionally support the proposals to “promote zero carbon development” (LP32, Part 2). Further consideration and commitment however should be given to meeting the requirements for water efficiency in such a highly stressed area. Part 2(b) states that the London Plan has targets to reduce carbon emissions. However, the London Plan is also relevant for water efficiency during design and construction but this has not been addressed. The London Plan states that “The highest standards of sustainable design and construction should be achieved” requiring:

the “efficient use of natural resources (including water)” (Policy 5.3, Page 183 of

The London Plan March 2016) and;

a reduction in the environmental impact of existing urban areas through policies and

programmes to bring them up to standards on sustainable design and construction

(Policy 5.4 Page 185 of The London Plan 2016).


Paragraph






Positively Prepared

Justified

Effective


X


X Yes No

17. Please give details of why you consider the Local Plan is not legally compliant

or is unsound or fails to comply with the duty-to-cooperate. Please be as

detailed as possible. If you wish to support the legal compliance or soundness

of the Local Plan or its compliance with the duty to co-operate, please also

use this box to set out your comments.


14

The London Plan Policy 5.3 states that “The Mayor’s supplementary planning guidance on Sustainable Design and Construction...reflect key sustainable design principals and outline the standards that are applicable to all developments” (Page 184). These, in conjunction with the London Plan, can be used as key guidance to implement “optimis[ing] resource efficiency (Part 2(f)). Additionally, in 2008 the Environment Agency conducted a study regarding the greenhouse gas implications of a number of water resource options (available here). Relevant outcomes of the study were:

89% of emissions in the water system can be attributed to ‘water in the home’. This

includes energy for heating water, but excludes space/central heating.

The remaining 11% of emissions originate from abstracting, treating and supplying

water, and the subsequent waste water treatment.

Demand management measures, particularly those that reduce hot water use, have

significant potential to save water and energy, and reduce the carbon footprint

throughout the water system. This could result in a reduction of greenhouse gas

emissions, and household utility bills.

As a result of the above, the Local Plan is strongly encouraged to specifically prioritise water efficiency. It’s understood that new residential buildings will follow building regulations, although this will only be 14% of the total stock dwellings in 2030 (Section 5.6.5). We recommend LBR require that new residential developments to meet the higher water efficiency standard of 110 litres/person/day, as per Requirement G2 in Part G of the Building Regulations 2010 or the London Plan target of 105 litres/person/day when designing residential development. We would suggest developers submit a water efficiency calculator report to demonstrate compliance. Increased water efficiency would contribute towards meeting the 2 (a) (i), 2 (a) (ii), 2 (d) and 2 (f) aspects of LP32 relating to energy efficiencies, Part 3 relating to adapting to climate change and LP19 Climate Change Mitigation. It is recommended that Part 3 is expanded to include small scale projects for domestic dwellings such as rainwater harvesting, water meter installation and incorporating water saving devices and equipment (such as water efficient plumbing fixtures). Additionally, water efficiencies will benefit the householder by reducing water bill charges. In Part 4, the Plan confirms to promote sustainable design and construction for pre-existing developments. We welcome LBR’s use of the BREEAM assessments to achieve an ‘excellent’ rating for water efficiency for pre-existing developments.








possible.

https://www.gov.uk/government/publications/greenhouse-gas-emissions-of-water-supply-and-demand-management-options

https://www.london.gov.uk/what-we-do/planning/london-plan/current-london-plan/london-plan-chapter-five-londons-response/policy-515-water-use-and#_ftn1

https://www.london.gov.uk/what-we-do/planning/london-plan/current-london-plan/london-plan-chapter-five-londons-response/policy-515-water-use-and#_ftn1

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/504207/BR_PDF_AD_G_2015_with_2016_amendments.pdf


15

However the Plan only “supports” the assessment for existing sites over 1,000 sqm in floor space and with an extension equal to/greater than 50% of the existing area (Part 4 (b)). Older properties are often the least water efficient and introducing such measures will reduce overall water consumption within the district. Therefore, we encourage the Council to strengthen their position regarding retro-fitting existing developments, including an ‘excellent’ BREEAM rating for water efficiency as an expectation of all developments equal to or greater than 1,000 sqm or where the extension is equal to or greater than 50% of the current floor space. We recommend segregating these two criteria, creating two points for ease. Additionally, we would recommend the council supports the retro-fitting of developments underneath these size thresholds, unless it is deemed non-cost beneficial. Finally, we recommend that it is extended to include new commercial developments.







X



Please note your representation should cover concisely all the information, evidence, and supporting information necessary to support/justify the representation and the suggested d modification, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submission will only be at the request of the Inspector, based on the matters and issues he/she identifies for the examination.


16


We support the principles of Policy LP37 but feel that further clarification needs to be demonstrated directly within the policy that it has been informed by the available evidence base, the Thames River Basin Management Plan (RBMP). In this regard we feel the policy and the supporting text does not yet comply with paragraph 165 of the National Planning Policy Framework where it states “Planning policies and decisions should be based on up-

to‑date information about the natural environment and other characteristics of the area

including drawing, for example, from River Basin Management Plans.” The Local Plan needs to demonstrate an overall picture of how the watercourses in borough perform under the Water Framework Directive (WFD). The status of the watercourses should be identified together with any reasons for failure. It is not clear how the Local Plan intends to help improve the status and help deliver the aims and objectives of the RBMP and WFD. The policy needs to make a direct reference to the Thames RBMP because the Water Framework Directive is a key designation of waterbodies and the Thames RBMP is the document that drives the action to improve. The aim should be for developers to consider how they can achieve improvements in line with the Thames RBMP, and as a minimum should not cause further deterioration or prevent future improvement measures from taking place. The plan can summarise the WFD evidence for local watercourses within the


Paragraph






Positively Prepared

Justified

Effective


X

X


X Yes No







17

supporting text. This is not just about Blue Ribbon Network (as defined in London Plan) but also the wider river network. Through the Duty to Cooperate, some actions can be agreed jointly with neighbouring boroughs who share sections of a watercourse or where the watercourse forms a local authority boundary.

Policy LP37 should be directed by the recommendations of the Thames River Basin Management Plan and the requirements of the Water Framework Directive. Evidence to support the policy should be added to the supporting text. We request the following amended wording to the policy to help developments in Redbridge acknowledge the objectives set out in the Thames River Basin Management Plan and contribute to achieving the measures: c) Protecting and enhancing the boroughs’ Blue Ribbon network, particularly supporting projects which improve water quality and biodiversity and restore the River Roding and other watercourses, in accordance with the Thames River Basin Management Plan. Paragraph 6.4.6 should include the following wording to explain the context: The River Roding is currently classified as having poor ecological potential and Seven Kings Water is classified as ‘moderate.’ Both watercourse need to achieve good ecological potential by 2027 under the Water Framework Directive. The watercourses are heavily modified by concrete channels and banks (culverting in places) and domestic plumbing misconnections, urban runoff and non-native species all contribute to poor water quality and ecology. It is important developments in the borough do not cause further deterioration and they make a positive contribution to improve and restore the watercourses. In addition, The Council will promote the improvement of water quality in the Blue Ribbon Network in accordance with the Thames River Basin Management Plan, by working in partnership with the Environment Agency and other partners such as the Roding, Beam and Ingrebourne Catchment Partnership.








possible.





X



Please note your representation should cover concisely all the information, evidence, and supporting information necessary to support/justify the representation and the suggested d modification, as there will not normally be a subsequent opportunity to make further representations based on the original representation at publication stage. After this stage, further submission will only be at the request of the Inspector, based on the matters and issues he/she identifies for the examination.


18




19


We find policy LP39: Nature Conservation and Biodiversity, sound.


Paragraph




4. (2) Sound X Yes No


Positively Prepared

Justified

Effective


4. (3) Complies with the Duty to co-operate X Yes No













possible.



End :\Users\agoymer\Desktop\Redbridge Reg 19 - Final Draft.docx

20


Yes No




X Yes, I wish to participate at the oral examination



9. Please let us know if you wish to be notified when the Local Plan is submitted.

X

10. Signature Date

Andy Goymer Planning Advisor

30 September

2016

ms joanne woodward our ref: ne/2006/000004/cs- redbridge borough council · cont/d.....

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