Draft Integrated Impact Assessment (IIA) of the Spatial Options Document

Support

Representation ID: 37998

Received: 18/08/2021

Respondent: Mr Martyn Clarke

It is a good assessment of the complex document

Object

Representation ID: 39429

Received: 21/09/2021

Respondent: Miss Tracey Richards

I strongly disagree with any building on green belt land. Every opportunity must given to use use brown belt land wherever possible.

I have seen the affects of building on green belt in my childhood town in South Wales. The affects have been devastating both environmentally and socially. Roads, schools, services are not able to support the extra population that new builds bring, Wakering medical centre is impossible to access at the moment. I am sure it is the same all of the area.Once this land has been built on its gone forever. the loss of wild life is devastating.

Support

Representation ID: 39579

Received: 22/09/2021

Respondent: Amherst Homes Ltd

We generally support the idea of an integrated approach towards policy and development. However, the AII provided does not analyse in enough depth for stakeholders to make an informed decision on strategies and options, when nearly 50% of the options produce "uncertain" factors. This analysis should have been more in depth and decisive to allow stakeholders to make better decisions on the options provided.

Comment

Representation ID: 39619

Received: 22/09/2021

Respondent: Walden Land and Property Ltd

Agent: mr ian beatwell

Whilst generally in favour of an integrated approach towards planning policy, the document fails to fully analyse and comment on all issues and options that would contribute to development scenarios into 2050, making it challenging for stakeholders to comment.

Comment

Representation ID: 40699

Received: 22/09/2021

Respondent: Bloor Homes

Agent: Barton Willmore LLP

The IIA is understood to be ‘a mechanism for considering and communicating the impacts of an emerging plan, and potential alternatives in terms of key sustainability issues’, as a document which aims to inform the plan-making process and maximise positive impacts, while minimising negative impacts and addressing risks.In considering the approach to plan-making and development across the district, the NPPF 2021 paragraph 11 presumption in favour of sustainable development should be adhered to, which for plan making means that:
• All plans should promote sustainable growth that aligns growth and infrastructure
• Provide for objectively assessed needs as a minimum as well as any needs that cannot be met within neighbouring areas.;
It is also noted that the IIA is informed by the Issues and Options document and spatial options consultation paper cited. References to these supporting evidence base
documents are included within these representations where relevant in expressing our views on the IIA.
Growth Scenarios
Of the three growth scenarios presented – lower, medium and higher growth – we consider that the higher growth option should be that which is preferred and taken
through the new local plan.
As cited above in paragraph 11 of the NPPF, the objectively assessed housing needs for the district should be seen as a minimum. Therefore to ensure sufficient delivery of homes across the plan, it is prudent to plan for a higher level of growth, thus minimising the risks of unplanned development while proactively addressing current and future needs.
Based on the assessment of growth options in Appendix I of the IIA, the following positive outcomes are the strongest in the higher growth option compared with the medium and lower growth options:
• Meeting the needs of the district and wider area, and improving cross-boundary links;
• Delivery of health and wellbeing infrastructure;
Integration and interaction of cross-boundary communities through the delivery of large-scale developments;
• Delivery of green and blue infrastructure and positive effects on the tourism economy;
• The delivery of sustainable transport connections and the realisation of crossboundary infrastructure projects;
• Delivery of new and accessible landscapes;
• Increased opportunities to focus development away from historic centres;
• Attracting government investment in significant infrastructure improvements to address climate change and environmental/air quality;
• Delivery of strategic green infrastructure in the interests of ecological and biodiversity net gains; and
• Increased co-ordination across boundaries with regard to consumption and use of natural resources.
The summary assessment of the growth options expresses the view that the lower growth options “performs better in comparison to the medium and higher growth options in relation to the landscape, historic environment, environmental quality and natural
resource themes”. This in addition to citing increasing risk of from a transport and climate change perspective.
However such a statement is counterbalanced by the fact that if a higher level of development is planned in the right areas – even if on greenfield or green belt land –
then there is a greater opportunity to not only avoid or mitigate negative effects across IIA themes, but would also constitute a more positive approach to delivery of
enhancements across the themes assessed.
In this sense, planning for a higher level of growth would represent greater consistency with the NPPF. Section 3 – Plan-making, states in paragraphs 16 and 16 that:
“Succinct and up-to-date plans should provide a positive
vision for the future of each area; a framework for
addressing housing needs and other economic, social and environmental priorities; and a platform for local people to shape their surroundings.
Plans should… be prepared positively, in a way that is
aspirational but deliverable.
Early engagement and planning for a higher level of growth would allow stakeholders and decision makers to collaboratively not enhance the district and its surroundings through increased investment opportunities for key infrastructure to be delivered, increasing the
scope and potential for higher quality of design, therefore in turn being more consistent with the recent increased national level focus on design.
Sites such as Land North of Hawkwell Road also demonstrate that some of the evidence base upon which the IIA is made is flawed in that it underestimates the opportunities for the release green belt land that could be released while still retaining and enhancing the purposes of the green belt. This is examined in greater detail within section 4 below and the landscape and visual appraisal included within appendix 3.
Therefore we recommend that the higher growth option is taken forward and that the spatial options Green Belt Study and Landscape Character, Sensitivity and Capacity study papers be immediately reviewed.
Spatial Strategy Options
Of the Spatial Strategy Options presented, we consider that option 4 presents the best combination of outcomes that will enable the authority the greatest flexibility to tailor fit a broad selection of sites spread holistically across the district and would in turn therefore function best with a higher level of growth.
Other options where growth is targeted and focused on one or a smaller selection of settlements would be inconsistent with the aspirations of the NPPF which states in paragraph 84 that planning policies should enable the sustainable growth of businesses, rural tourism and the development of accessible local services. It is through a balanced and sustainable spread of growth across the district that the prosperity of rural economies would be most highly supported through the new local plan.
By this same token, this flexibility and the positive impacts to rural communities means that greenfield and green belt release development opportunities can be realised as part of a holistic approach, thereby increasing the strength of options available for development and supporting infrastructure across the district.
Based on the ‘Assessment of the spatial strategy options’ within section A4, the following positive outcomes are particularly strong in the case of option 4 when compared with other options:
Tailored housing options to meet local needs through a more balanced supply of housing and land options;
• Facilitating health and wellbeing capacity upgrades;
• Strategic improvements to green infrastructure;
• Opportunities to capitalise on the Thames Estuary Growth Area;
• Delivery of transformative growth opportunities and wider development in the most accessible areas;
• Delivery of new regional parkland, biodiversity, ecological and landscape enhancements;
• Growth that can be tailor suited in location, massing and design to the historic environment of the district;
• Greater flexibility to avoid areas of greater flood risk and improvement of drainage strategies;
• Delivery of local and strategic infrastructure to mitigate traffic congestion from increased growth; and
• Effective use of brownfield development opportunities to minimise negative impacts on mineral resources and waste management.
Therefore in planning positively for growth and given that option 4 presents the most positive outcomes, leaves the least uncertainty regarding significant effects, and that any negative significant effects can be mitigated, we recommend that spatial strategy option 4 is pursued and that the Green Belt Study and Landscape Character, Sensitivity and Capacity study papers be immediately reviewed in the context of this.

Comment

Representation ID: 40815

Received: 22/09/2021

Respondent: Countryside Properties (UK) Ltd

Agent: Strutt & Parker LLP

At Table 1.1 of the Integrated Impact Assessment (IIA), the assessment framework is set out. This explains that the objectives of the population and communities theme are
1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identity.
In respective of objective 1, Table 1.1 explains that assessment questions relate to the following:
 Meet the identified objectively assessed housing needs, including affordable, for the plan area?
 Ensure an appropriate mix of dwelling sizes, types and tenures to meet the needs of all sectors of the community?
 Improve cross-boundary links between communities?
 Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
 Promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?
We support the above decision-aiding question, but suggest that, in addition to meeting the District’s housing needs (including affordable housing), the Local Plan should seek to improve the affordability of housing for local residents.
The median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’). The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average. In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69 –
significantly below the District’s 11.57.

Comment

Representation ID: 41689

Received: 22/09/2021

Respondent: M Scott Properties Limited

Agent: Strutt & Parker LLP

3.0 Response to Integrated Impact Assessment

Assessment Framework

We welcome the recognition within the Integrated Impact Assessment (IIA) (at A.3) that “delivery of suitable homes for an ageing population…is a particular issue for the district”.

Furthermore, we agree with the findings of the IIA at A3 that medium and higher growth options provide greater opportunity for a wide range of different types of homes to be delivered, including specialist housing for older people.

However, we are concerned that, despite the recognition of this as being a particular issue for Rochford District, there is otherwise very little within the IIA regarding the need to ensure appropriate accommodation for older people is delivered.

Table 1.1 of the Integrated Impact Assessment (IIA) sets out the assessment framework for the IIA. This explains that the objectives of the population and communities theme are 1) to cater for existing and future residents’ needs as well as the needs of different groups in the community; and 2) maintain and enhance community and settlement identify. We support these objectives.

The IIA then sets out assessment questions intended to be used to assess whether options will meet these objectives. This includes:

Will the option / proposal promote the development of a range of high quality, accessible community facilities, including specialist services for disabled and older people?

And

Will the option / proposal meet the identified objectively assessed housing needs, including affordable, for the plan area?

We suggest that, given the requirements of the NPPF and PPG to address the diverse range of accommodation needs for older person, together with the acknowledgement that delivery of suitable homes for ageing population is a particular issue for the District, the IIA should include an assessment question which specifically asks whether options / proposals would help meet the accommodation needs of older people.

Comment

Representation ID: 41746

Received: 22/09/2021

Respondent: Generator Group LLP

Agent: Strutt & Parker LLP

2.28 National policy is clear on the importance of promoting thriving rural communities. The NPPF states at paragraph 79 that:

“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services”.

2.29 In addition, the Planning Practice Guidance (PPG) notes that housing in rural settlements can be important in ensuring their sustainability, and that villages in rural areas often face issues relating to housing supply and affordability. It states:

“People living in rural areas can face particular challenges in terms of housing supply and affordability, while the location of new housing can also be important for the broader sustainability of rural communities”.

2.30 Great Stambridge is considered an established rural community. Within the Settlement Role and Hierarchy Study (2021) Great Stambridge is categorised as ‘Tier 4: Other Villages’. However, as stated within the RLPSO, the ‘Tier 2’ Rochford and Ashingdon Town is less than a mile from the western edge of the village and provides an important service base for the population of Great Stambridge.

2.31 Such locations that already benefit from infrastructure and services with easy connectivity to higher scoring settlements are the type of rural settlement the NPPF encourages new housing to, to support the vitality of the area. As such, we consider it important that the Local Plan ensures the sustainable, proportionate growth of Great Stambridge as part of any option taken forwards.

2.32 To take advantage of the existing services and facilities, it will be important for any development to be well located in relation to the existing developed area of Great Stambridge. Such an approach also allows development to commence quickly given that significant infrastructure is not required to be delivered, which will be important to help meet housing need in the short and medium term.

2.33 In relation to Great Stambridge, Land at Stewards Elm Farm (reference CFS141) is located immediately adjacent to the existing developed area and is a logical extension to the settlement. It should, therefore, be utilised to provide new market and affordable homes to help meet identified needs and maintain the vitality of the rural area.

2.34 The Site comprises Stewards Elm Farm and surrounding grassland located to the west of Great Stambridge. It measures approximately 11.2 hectares in total and is relatively flat and featureless, with the exception of ponds and trees in the north-west; and trees / hedgerows around the site boundary.

2.35 The Site is not subject to any additional landscape-related policies that seek to restrict development other than the Green Belt, which is pertinent given the Coastal Protection Belt to the east.

2.36 Together with the Green Belt designation, parts of the Site are identified as being within Flood Zones 2 and 3. As stated above, detailed proposals are yet to be prepared for the Site but we are confident that development can be accommodated with suitable mitigation where necessary.

2.37 In terms of the designation of the Site within the Green Belt, it is important to consider the contribution it makes towards the Green Belt purposes. Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’) considered the Site as part of Parcel 79 in the Stage 1 Assessment. Parcel 79 is a large area of land covering the entire eastern side of Rochford and Ashingdon. Clearly an assessment of this size parcel of land has limited use when assessing specific sites given that the characteristics are very different. We would caution the Council against giving this weight in the assessment process. Instead, as identified through the Welwyn Hatfield Local Plan Examination, it is important that Green Belt is considered at a sufficient fine grain. In the Examination of the Welwyn Hatfield Local Plan, the Inspector advised as follows:

“The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might reasonably be considered further”.

2.38 The Green Belt Study (2020) Stage 2 assessment did not consider the Site specifically in detail, with it considered as part of assessment area AA126. However, only a brief assessment was provided with an overall conclusion on the level of harm rather than a detailed assessment against each purpose of the Green Belt.

2.39 The Green Belt Study (2020) found that the Site makes a strong contribution to preventing encroachment on the countryside as it was considered predominantly uncontained, open and undeveloped and to have a strong relationship with the wider countryside due to a lack of significant boundary features. However, it should be noted that the Site does contain an existing dwelling and numerous large agricultural buildings. Further, it must be recognised that for any site not already within a built up area, these conclusions are highly likely to be similar.

2.40 The Site is bounded by existing residential development to the east, with formal tree lined and fenced boundaries to the south and west. As such, the boundaries of the Site are currently defined and through the development of the Site, these could be enhanced through new planting. As such, it is considered to have low potential to lead to unrestricted urban sprawl when considered against purpose 1 of the Green Belt.

2.41 In relation to purpose 2, the Site is some distance from the nearest other settlement, being approximately 1 mile from the edge of Rochford to the south west. Its development would not have any risk of either actual or perceived coalescence of Great Stambridge with any other settlement.

2.42 In respect of purpose 3, there is no existing, strong defensible boundary between the urban area and adjoining countryside. There are tree lined and fenced boundaries to the south and west but no dominant landscape features. Existing development is present and visible within the landscape, with the Site providing an opportunity to reframe this edge. The Site is not currently considered to strongly assist in safeguarding the countryside from encroachment.

2.43 The Site is not subject to any heritage or ecological designations, but is in proximity to a Grade II listed building to the south east. This listed building is nestled amongst the existing built up residential area and separated from the Site by numerous existing buildings. Therefore, redevelopment of the Site would not be harmful to its immediate or wider setting. The Site makes no contribution towards preserving the setting and special character of historic towns in respect of purpose 4.

2.44 In respect of purpose 5, this is only applicable where development needs can be met in full on previously developed land. For Rochford District, this is not an option as the amount of market and affordable homes that could be delivered is significantly below the identified need.

2.45 Overall it is considered that the Site makes limited contribution towards the purposes of the Green Belt, and its residential development would not undermine the strategic purposes of the Green Belt.

2.46 The Council’s SHELAA 2017 considered that the Site is available and achievable, with the suitability dependent on an assessment of the Green Belt purposes. It was considered suitable in other regards subject to flood risk mitigation. As set out above, the Site is considered to make limited contribution towards the Green Belt purposes and detailed proposals for the Site would identify suitable flood risk mitigation where necessary. It should, therefore, be considered suitable, available and achievable.

2.47 The Site can deliver homes early in the Plan period to meet local and wider needs, whilst providing an important role in helping to maintain the vitality of the rural area and provide choice and new homes for local residents.

2.48 Overall, we consider that a balanced combination of utilising appropriate small scale and larger sites, on both brownfield and greenfield sites is the best approach to seek to meet identified housing needs within the District. This balanced approach provides opportunities to deliver housing close to existing communities, making use of existing sustainable locations whilst providing new homes for people in their local community.

Comment

Representation ID: 43086

Received: 14/09/2021

Respondent: Chelmsford City Council

Thank you for also consulting Chelmsford City Council (CCC) on the Integrated Impact Assessment (IIA).

It is noted that the IIA fulfils the requirements and duties for the Sustainability Appraisal (SA), Strategic Environment Assessment (SEA), Equalities Impact Assessment (EqIA) and Health Impact Assessment (HIA).

CCC is supportive of the proposed topic headings for the assessment and has no further comments to make at this stage.

Comment

Representation ID: 44322

Received: 27/09/2021

Respondent: Natural England

The following comments are principally focussed on the Integrated Impact Assessment that
accompanies the Spatial Options document. They also reflect Natural England’s response to the
previous consultation on the Draft Sustainability Appraisal Scoping Report (our letter dated 31
January 2017, reference 204441).
IIA Theme – Health and Wellbeing
Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by
adding a reference to neighbouring authority areas. The amended wording would be:
“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring
authority areas?”
This adjustment is still considered advisable as green infrastructure networks may well involve land
that extends beyond the District boundary and restricting the provision to the District boundary
could exclude the scope for landscape scale provision. This could be particularly important given
the location of some of the growth options now being considered. It is of note that the
recommended adjustment to the appraisal question was made in the Final Scoping report dated
March 2017.
There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question
features in the “Climate Change” theme, it would still be a relevant consideration in assessing the
extent to which a proposal meets the Health and Wellbeing IIA Objective.
Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020
as this could provide a relevant addition to the evidence base for this aspect of the emerging Local
Plan.
IIA Theme – Landscape
Natural England supports the inclusion of an appraisal question that considers the relationship and
potential impact of any option/proposal on existing areas of tranquility.
IIA Theme – Climate Change
As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and
Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options
document. The following wording is suggested for the appraisal question:
“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”
IIA Theme – Biodiversity
Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme
and should be referenced and adjustments are recommended to the appraisal questions to better
reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is
made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will
be an increased emphasis on the delivery of biodiversity net gain. The following wording is
suggested for the first appraisal question:
“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”