Rochford District Core Strategy Regulation 26 Draft

The following represents the comments of the Crouch Harbour Authority (CHA) on the Core Strategy Preferred Options (Regulation 26) Draft.

CHA welcomes the Regulation 26 Draft subject to the following reservations:

In general the document makes insufficient reference to the existence and importance of the estuarial, island and marshland landscape and the creeks and rivers which make up a very large part of the Rochford DC area and must be considered its most important asset in terms of landscape, heritage, ecology and biodiversity and public recreation and amenity. The vision statement '...to make Rochford the place of choice in the country to live, work and visit' must surely depend very largely on the continued and enhanced appeal of its marine margins, yet they apparently receive scant consideration or potential protection in the Core Strategy Document.

This deficiency is noticeable in both the 'Spatial Portrait' Section 1 of the Draft and also in Section 2, 'Spatial Vision'. Whilst the latter makes passing reference to 'green tourism projects and initiatives' it fails to focus sufficiently or at all on the issues of managing development and activity on and around the rivers Crouch and Roach which lie substantially within the District Council Area.

The document makes frequent reference to the forthcoming Thames Gateway development and to providing recreational facilities for its residents but gives insufficient attention to the development pressures and the major issues surrounding management of activity on shore and afloat which will result from the Thames Gateway development.

Specifically the Core Strategy Preferred Options draft is seriously deficient in failing to identify the Management, Protection and Enhancement of the Rivers Crouch, Roach and Islands as a Core Strategy Issue. The document does identify the protection and enhancement of the upper Roach Valley as a core strategy issue. How much more important must be the much larger task of preserving the landscape and environment of the rivers, creeks, marshes and islands. While some of the issues are peripherally dealt with under other headings that represents a much less than complete or holistic consideration of the problems of preserving and enhancing the largest single and most characteristic feature of the district.

It is understood that the Core Strategy Options document is in nature a scoping document and not the vehicle for detailed or specific planning policies. However unless the document properly prioritises and identifies the principal issues there will be no framework or justification in place for the introduction of those badly needed policies. It is understood that in the past effective enforcement and management action by the council has been inhibited by the lack of relevant and cogent policies. It is critical at this stage that these matters do not again go by default.

The matters on which it will be necessary to have robust and enforceable policies in relation to the rivers, creeks, islands and marshes include:

* Marine related recreational and residential development (marinas etc.)
* Siting, access to and management of moorings.
* Structures/jetties/pontoons etc within the river.
* Siting, use of, servicing of and access to residential vessels/houseboats.
* Management of fast powered boating activity.
* Management of noisy, intrusive, hazardous or adventurous boating activity.
* Policies which encourage quiet/low impact/environmentally friendly boating activity.
* Vehicular and launching access to the rivers/creeks.
* Management of 'Dry Stack'/park and launch boating facilities.
* Environmentally friendly/sustainable management, maintenance, storage, servicing and repair of boats.

CHA offers partnership and full assistance in generating, publicising, supporting and enforcing these policies. We have certain powers, limited in scope, geographically and in terms of resources but RDC has much wider and more effective powers and it is RDC's responsibility to ensure that sustainable, robust and enforceable policies are in place to manage the entirely foreseeable increases in development pressure and the continually evolving management challenges that the rivers, creeks, islands and marshes will assuredly face within the time horizon of the LDF.

It is rather too easy to assume from the document as it stands that RDC considers its responsibilities to end at the river wall. That is not the case and it is not proper for RDC to consider that the various conservation designations and protections together with a little marine intervention from CHA adequately covers the issue. RDC must understand and address its responsibilities to the rivers, creeks, islands and marshes and it must do so with urgency and priority.