Issues and Options Document

(29) 10 Protecting and Enhancing our Environment

(5) Introduction

10.1 National policy is clear that planning has a role to play in minimising vulnerability and providing resilience to the impacts of climate change, including flood risk, coastal change, water supply and changes to biodiversity and landscape. Development in areas potentially vulnerable to climate change should be avoided, and where it cannot be avoided, development should be suitability adaptable to deal with any changes (NPPF paragraph 99).

10.2 Our district is rich in heritage, geology and biodiversity with many miles of undeveloped coastline. The River Crouch forms the north boundary of the district, with the North Sea providing the eastern boundary, and the River Roach flowing east to west through the district. Our coast and estuaries are of great importance and are recognised through their international and national designations for their wildlife and natural habitats. The impact of development on the natural environment, and in particular the character of different areas, was a common issue raised through the early community engagement we undertook in 2016. Local areas of ecological value – such as Local Nature Reserves and Local Wildlife Sites – are also of importance and make a significant contribution to the character of our district. 

10.3 The different landscapes across the district, which have been shaped by the underlying geology, are of significance and are valued, along the rivers and coastline as well as further inland towards the more undulating landscape towards the west of our district. Most of the district is Green Belt, which is important for protecting the open, predominantly rural, character of the area. The history of our district and the preservation of the historic fabric of our urban and more rural areas are also valued and is distinctive. This is reflected in the plethora of Conservation Areas, Listed Buildings, Scheduled Ancient Monuments and locally distinctive buildings spread across the district. 

10.4 Improving the quality of the environment for residents and visitors is important, with key issues such as air quality, light pollution and flood risk, needing to be addressed.

(201) Green Belt

Where are we now?

10.5 Our Green Belt forms part of the Metropolitan Green Belt, which extends eastwards across South Essex from London. The Metropolitan Green Belt is effectively a planning designation that is given to land, which can include both greenfield (undeveloped) and brownfield (previously developed) land in areas with potentially varying landscape quality. Most of our open countryside – 12,763 hectares – is designated as Metropolitan Green Belt; the only exception to this is Foulness Island, which is Ministry of Defence land. The Green Belt provides opportunities for people to access the countryside, to keep land for agriculture, forestry and similar land uses, and for nature conservation. Our Environmental Capacity Study 2015 notes that there are agricultural activities across large areas of the district, predominantly to the north, east and south-east. The quality of our agricultural land needs to be carefully considered.

10.6 A fundamental principle of the Green Belt is to keep a sense of openness between built up areas. The NPPF and PPG are clear that development in the Green Belt should only happen in exceptional circumstances. Subsequent publications released by the Government reiterate the importance of a plan-led system to maintain and, where necessary, review the existing Green Belt boundary to deliver sustainable development. 

10.7 The five purposes of the Green Belt are set out in the NPPF: 

• to check the unrestricted sprawl of large built-up areas;
• to prevent neighbouring towns merging into one another;
• to assist in safeguarding the countryside from encroachment;
• to preserve the setting and special character of historic towns; and
• to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

10.8 However, whilst policies on development in the Green Belt are generally restrictive, there are exceptions to this, for example the construction of new buildings in the Green Belt is generally considered to be inappropriate development, depending on the use. The NPPF also supports certain beneficial uses in the Green Belt including outdoor sport and recreation, improvements to biodiversity, visual amenity and landscapes, access and improvements to damaged and derelict land. Further guidance on this is provided within the PPG. Our Environmental Capacity Study 2015 recognises that Green Belt is a planning tool, rather than an environmental resource as such, however as this designation focuses on protecting open space and through consideration of landscape character and sensitivity, it is an issue affecting the condition of the receiving environment.

10.9 Our approach to the Green Belt is broadly set out in the Core Strategy, which seeks to balance the wider protection of the openness and character of the Green Belt whilst meeting our development needs, as sensitively as possible, up to 2025. This approach takes into account of the very limited opportunities – when our adopted local development plan was being prepared – to accommodate further development within existing settlements. Core Strategy policy GB1 adopts a restrictive approach to development in the Green Belt through allocating the minimum amount of Green Belt to meet development needs, whilst protecting the overall purposes of the Green Belt. Certain types of other development can take place in the Green Belt, and are considered compatible, as set out in the NPPF. Core Strategy policy GB2 sets out the types of rural diversification and recreational uses that may be considered appropriate in the Green Belt. Policy GB2 and more detailed policies in the Development Management Plan are considered in detail in the 'Detailed Policy Issues' chapter.

10.10 Previous community involvement exercises have made it clear to us that residents consider the protection of the Green Belt to be very important – as does national policy and guidance. This is a view which has been reiterated through the more recent community engagement programme in 2016; particularly in relation to retaining the open, rural character of the area and preventing towns and villages merging into one another. As a Local Planning Authority, we value the Green Belt and recognise its importance; our current adopted strategy to deliver new homes and jobs has ensured that in the region of 99% of the district's Green Belt remains as such. The extent of the Green Belt is identified in the Allocations Plan.

10.11 Although there is a general presumption against development in the Green Belt, national policy and guidance is clear that we must explore all reasonable options for meeting our need for homes and jobs in the future. These options are set out in the 'Delivering Homes and Jobs' chapter. There is also continued support through community engagement for the redevelopment of brownfield sites within existing residential areas. We have prepared a revised Strategic Housing and Employment Land Availability Assessment (SHELAA) – in line with the NPPF and PPG – to consider in detail the potential available brownfield land within existing residential areas. We will now consider undertaking an assessment of the Green Belt against the five purposes defined above, in line with national policy and guidance. 

What are the identified issues?

10.12 Nationally there is a commitment to increasing the number of new homes delivered to address the issues of a greater requirement for a mix of different types and tenures of homes to meet the changing needs of our population, coupled with an historic undersupply. We are required – taking into account all the policies in the NPPF – to 'objectively assess' what our housing need is for the district and for the wider South Essex Housing Market Area. We are also required to assess our need for new jobs in the future. These issues are considered further in the 'Delivering Homes and Jobs' chapter. However the majority of South Essex, outside the existing residential areas, is designated as Green Belt. We need to consider this objectively assessed housing and employment need, within the wider context of the NPPF and PPG, and the Government's commitment to protect the Green Belt.

10.13 Our current policies seek to prioritise the development of brownfield (previously developed) land, wherever possible, whilst enabling some development on greenfield land, previously designated as Green Belt. However, national policy is such that development of new homes and commercial property on brownfield land in the Green Belt can take place. This however could mean that development takes place in the Green Belt, regardless of whether we assess the Green Belt boundaries provided it meets the relevant policies in the NPPF. 

10.14 Our current position in terms of housing need is complicated by the proposals within the Housing White Paper; Fixing Our Broken Housing Market (February 2017), and the Government's subsequent consultation document, called Planning for the Right Homes in the Right Places^[42] (September 2017), which seeks to establish a national methodology for assessing housing need. This is further complicated by an appeal decision within Castle Point Borough, recovered by the Secretary of State. The Secretary of State refused planning permission for new homes in the borough on 21 April 2017 against the advice of a Planning Inspector for the development of a Green Belt site, despite the Inspector finding that the Council only had 0.4 years worth of housing land supply. This is coupled with the withdrawal of Castle Point Borough Council's draft New Local Plan on 4 April 2017, following its failure to meet the legal requirements of the Duty to Co-operate in relation to meeting the need for new homes and the Green Belt. Another Planning Inspector examining St Albans City and District Council's draft plan also concluded that Local Planning Authorities need to leave "no stone unturned" in meeting the need for new homes and jobs. This is considered further in the Duty to Co-operate Topic Paper 2017.  

10.15 The Environmental Capacity Study 2015 considers in detail a range of factors and draws some conclusions and recommendations on the environmental capacity of the district to accommodate additional new homes beyond 2025. It highlights that it is uncertain as to whether the district could accommodate additional growth, and is unlikely to be able to accommodate additional needs from other areas. The study however recommends site-specific studies could be undertaken for small sites around the northern and western urban areas, and that this could include an assessment of the Green Belt. The need for new homes in the district is considered in more detail in the 'Delivering Homes and Jobs' chapter.

What are the realistic options? 

10.16 Three options in relation to the Green Belt have been identified.

Option	Justification
(2) Retain the existing policy on broad Green Belt principles in the Core Strategy	The broad policy on Green Belt – policy GB1 in the Core Strategy – is considered to be appropriate in seeking to direct development away from the Green Belt as far as possible.
(7) Amend the current Green Belt policy in the Core Strategy	The policy may need to be updated to reflect our strategy for delivering new homes and jobs over the next 20 years. In particular, this is likely to be influenced by the new national methodology for assessing the need for new homes. An assessment of the Green Belt as a whole would also need to be taken into consideration.
Do not have a policy on the Green Belt	This is not considered an appropriate position – there is a need to protect the Green Belt wherever possible.

(89) Biodiversity, Geology and Green Infrastructure 

Where are we now? 

10.17 Due to its coastal location the district is particularly important for biodiversity. There are a number of international and national nature conservation designations which reflect this importance: 

• Foulness and the Crouch and Roach Estuaries Ramsar sites – these are wetlands designated for their international importance under the Ramsar Convention
• Foulness and the Crouch and Roach Estuaries Special Protection Areas (SPAs) – these are habitats that are important for migratory birds under the European Birds Directive
• Essex Estuaries Special Area of Conservation (SAC) – these are internationally important for threatened habitats and species which are designated under the Habitats Directive
• Foulness, Crouch and Roach estuaries, and Hockley Woods Sites of Special Scientific Interest (SSSI) – these sites, which are designated under the Wildlife and Countryside Act 1981, cover 12,986 hectares and are the country's very best wildlife and geological sites

10.18 There are many other nature conservation designations in our district that are important including 14 Ancient Woodlands, seven of which lie within the Upper Roach Valley with Hockley Woods being the largest, four Local Nature Reserves at Hockley Woods, Hullbridge Foreshore, Marylands and Magnolia Fields, and a further 400 hectares of land that have been allocated as Local Wildlife Sites. A major intertidal engineering project being delivered by the RSPB at Wallasea Island in the north east of the district on the river Crouch is also becoming a significant haven for migratory birds, and other wildlife^[43].

10.19 River corridors and green open spaces across the district make a significant contribution to our green and blue infrastructure network. Green and blue infrastructure is a term used to describe networks of natural features that provide benefits to people. These features can range from trees along roads to woodlands and from ponds to rivers. As well as contributing to the character of the district, these areas provide additional habitats for our wildlife, and access for local communities to can have positive impact on mental health, social cohesion and physical activity. The NPPF is clear that green infrastructure can increase adaptability to climate change and should be supported. The Green Grid Strategy 2005 identifies a number of potential greenways which could be developed across our boundaries and into the neighbouring areas of Castle Point and Southend Boroughs to improve habitat connectivity and deliver alternative sustainable ways to travel. This is reflected in Core Strategy policy T7. This document however is in need of updating – this will be considered at the South Essex level to take a strategic approach to green infrastructure provision. The Environmental Capacity Study 2015 recognises that key green infrastructure can be found in the Upper Roach Valley in particular, including dedicated bridleways, Ancient Woodland and marked walking routes.

10.20 We have a number of current policies in our adopted local development plan, which seek to protect and enhance our natural landscapes and important habitats. Core Strategy policy ENV1 sets our broad commitment to maintaining, restoring and enhancing our sites of nature conservation importance and the implementation of the Crouch and Roach Estuary Management Plan. The Environmental Capacity Study 2015 notes that there is a risk of non-compliance with the Water Framework Directive for ecological quality along parts of the Rivers Crouch and Roach however.

10.21 Our varying landscapes are partly shaped by the underlying geology of the district. Brickearth is found in shallow seams in south east Essex with significant deposits found throughout our district as identified in the Essex Minerals Local Plan 2014. Although these are not currently worked, they could be capable of economic use in the small-scale manufacture of bricks, roof tiles and clay materials, and should be safeguarded. Essex County Council is the minerals and waste local planning authority responsible for planning for the effective use of available minerals and has identified a number of Minerals Safeguarding Areas, which apply to the development of one or more new homes. Minerals deposits, such as brickearth across the district, are safeguarded from sterilisation under policy S8 of the Essex Minerals Local Plan 2014. There is also one of three Strategic Aggregate Recycling sites in Essex, located at Purdey's Industrial Estate in Rochford, which is well placed to serve south-east Essex, and is safeguarded under policy S5 of the Essex Minerals Local Plan 2014). One of seven coated stone plants in Essex, located at Suttons Wharf in Rochford, is also safeguarded under policy S9 of the Essex Minerals Local Plan 2014.

10.22 National policy broadly seeks to prevent the loss or deterioration of irreplaceable habitats, including Ancient Woodland and the loss of aged or veteran trees found outside Ancient Woodland. It also recommends the use of criteria based policies to assess schemes which may impact on protected wildlife sites. Policy DM25 of our Development Management Plan provides more local detail on how applications which may impact on trees and woodlands would be treated; with the aim of conserving and enhancing existing trees and/or woodlands wherever possible. It also supports the creation of new woodland. Our Development Management Plan has other policies on the natural environment, including policy DM26 which relates to the protection of important landscape features (such as hedgerows, lakes and ponds), and policy DM27 which relates to the protection of priority species and habitats. The Environmental Capacity Study 2015 also recommends investigating the scope for enhanced local food production and security, including restoration of the traditional orchards and revival of local market gardens and allotments. A mix of different types of open space is an approach which has been promoted through our adopted local development plan; in particular the provision of public open space and allotments.   

10.23 A number of our woodlands are currently designated as Local Wildlife Sites in the Allocations Plan (policy ELA1). These are the minimum habitats needed to be protected in order to maintain current wildlife levels across the county. They can also function as corridors for wildlife through providing key connections between other habitats. We have identified 39 such sites in the Local Wildlife Sites Review prepared in 2007; however this is in the process of being updated to ensure that our evidence on current biodiversity levels, threats and management arrangements is both up-to-date and effective.

What are the identified issues?

10.24 The potential impact of climate change on the adaptability from small to larger scale habitats is a concern. This, coupled with the fragmentation of habitats, can have a negative impact on the biodiversity and wildlife. Ensuring that appropriate networks are available throughout the district is important to help local populations adapt to any change in the local climate. A landscape scale approach can help to build resilience in wildlife responding to climate change, development and other potential pressures.

10.25 National policy requires us to plan positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure, and make connections between the hierarchy of international, national and locally designated sites. This is to ensure that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks. We therefore need to work with neighbouring local authorities to identify local wildlife corridors and networks across boundaries, to show the links between the different hierarchies of international, national and locally designated sites of importance for biodiversity.

10.26 Given this district's coastal location there are many habitats designated as Special Protection Areas (SPA's), Special Areas of Conservation (SACs) and Ramsar sites, which create a network of important habitats along the Essex coast. Natural England have identified the need to develop a joint Essex-wide strategy to identify how the potential impacts of recreational disturbance resulting from the delivery of new homes in the county (not just the coastal authorities) may be mitigated against. This is to address concerns that Natural England have identified within the Habitat Regulations Assessments (HRAs) prepared to support emerging Local Plans. HRAs are a legal requirement for formal stages of plan-making. We are therefore working with Natural England and other authorities to prepare an Essex Coastal Recreational Avoidance and Mitigation Strategy to ensure compliance with HRA Regulations.

What are the realistic options? 

10.27 Two options have been identified in relation to biodiversity and geodiversity in the district.

Option	Justification
(6) Retain or amend our current broad policy on sites of nature conservation importance	Core Strategy policy ENV1 sets out our commitment to maintaining, restoring and enhancing our sites of nature conservation importance. It could however be strengthened to identify and seek to enhance local wildlife corridors and networks which support the adaptability of wildlife to any change in climate. Reference could also be made to the geology of the district as per the Minerals Local Plan 2014.
Do not have a policy on sites of nature conservation importance	The broad approach set out in Core Strategy policy ENV1 is considered to be appropriate in in setting out our commitment to sites of nature conservation importance, and supports more detailed policies on protecting specific habitats.

10.28 Five options have been identified to support and protect local habitats which have important ecological value.

Option	Justification
(2) Retain our current policy on trees and woodlands	Development Management Plan Policy DM25 on trees and woodland is considered to be fit for purpose in terms of requiring appropriate mitigation for any loss of habitats, their retention and enhancement and the creation of new habitats. This approach is supported by national policy.
(1) Retain our current policy on other important landscape features	Development Management Plan Policy DM26 sets out our approach to protecting other important landscape features that have been identified. This policy is considered to be fit for purpose and this approach is supported by national policy.
(1) Retain our current policy on species and habitat protection	Development Management Plan Policy DM27 sets out our approach to protecting priority habitats and species. This policy is considered to be fit for purpose and this approach is supported by national policy.
(1) Update our current policy on Local Wildlife Sites	Allocations Plan Policy ELA1 will need to be updated to reflect the findings of the latest Local Wildlife Sites assessment; and allocate these sites accordingly.
(3) Condense and merge our current policies on nature conservation	Whilst our current policies are considered to be appropriate; there is potential to strengthen our broad, strategic policy and supplement this with more succinct detailed policies.

10.29 Two options have been identified in relation to greenways in the district.

Option	Justification
(6) Retain our current policy on greenways	Core Strategy Policy T7 sets out our approach to greenways, which are important walking and cycling corridors which promote biodiversity and connectivity of habitats. No strategic greenways have been developed in the district to date, however we are committed to reviewing the appropriateness of these greenways, set out in the Green Grid Strategy and promoting their delivery.
Do not have a policy on greenways	Ensuring the connectivity of habitats as a response to climate change pressures, and facilitating a network of green open spaces and greenways to promote health and well-being, are national policy considerations. To not have a policy on greenways would not be an appropriate approach.

(5) Wallasea Island and the RSPB's Wild Coast Project

Where are we now?

10.30 Work to create an RSPB nature reserve on Wallasea Island is well underway with development of the reserve expected to continue until around 2025^[44]. This RSPB project is progressing to create wildlife habitats consisting of mudflats, saltmarsh, lagoons, grazing marsh and pasture. Policy URV2 in the Core Strategy supports the development of this project in the district, including promoting recreational use, additional marina facilities and access improvements. There is significant potential for the area to become a tourism and leisure destination, in addition to the wider ecological benefits of the project. There are two walking routes that have been delivered on Wallasea Island; Allfleets Marsh Trail which runs from the temporary car park for 3km along the length of seawall on the River Crouch; and the Jubilee Marsh Trail which runs south from the Allfleets Marsh Trail for 2.4km to reach the River Roach.

10.31 Current policy supports the delivery of the nature reserve, including the development of recreational facilities and the development of Essex Marina which is located before the entrance to the reserve, provided that any potential adverse ecological impacts are avoided or mitigated against. There are limited facilities on site (as of October 2017) including a 24 space car park, visitor's information board and a number of bird hides. The RSPB predict that the number of visitors in 2016/2017 is in the region of 22,000; so there is a need to support and monitor this site in conjunction with the RSPB. Improving access to this facility has the potential to positively impact on the health and well-being of local communities. 

What are the identified issues?

10.32 As Wallasea Island is located in the north eastern extent of the district, the current opportunities are rather constrained by its relatively remote location, and inaccessibility. Access is therefore a key issue to overcome, although there is potential to improve sustainable access to this location over the long term. 

10.33 The designation of the area as Green Belt may be challenging for the provision of facilities on the island, although these are needed to support this area as a destination in the longer term. However, provided these facilities would not have a detrimental impact on the Green Belt – particularly in terms of openness – this issue could be overcome. 

What are the realistic options?

10.34 There are three realistic options that have been identified for Wallasea Island and the RSPB's Wild Coast Project:

Option	Justification
(4) Retain the current policy which supports the Wallasea Island Wild Coast Project	This policy in the Core Strategy supports the RSPB's project, including promoting recreational use, additional marina facilities and access improvements. It would also support the development of sustainable access such as cycle routes to the Island to connect homes, jobs and this key leisure destination.
(2) Continue to support further development at Essex Marina as per current policy	Essex Marina is identified, alongside Baltic Wharf, as a major developed site in the Green Belt in the Core Strategy and Allocations Plan. This area may be able to support further development, provided that any adverse ecological impacts are avoided or mitigated, as set out in the Core Strategy.
Do not support further development at Essex Marina	Essex Marina, alongside Baltic Wharf, provides rural employment opportunities in the district. Although Essex Marina by its nature requires a coastal location, any detrimental impact on the environment should be avoided or mitigated. Applications should be considered on a case-by-case basis.

(6) Landscape Character 

Where are we now? 

10.35 The district has a varied nature in terms of local landscape character. The vast majority of our Green Belt remains open and undeveloped and, as a district, we continue to perform the role of the green part of South Essex. The Essex Landscape Character Assessment 2003 identifies at a high-level the changing landscape across the county. There are three broad landscape characters that have been identified across the district;

• Crouch and Roach Farmland – extends south from the River Crouch then skirts around Hockley, Rochford and Rayleigh, to the east of Rochford as far south as Great Wakering
• Dengie and Foulness Coast – covers the far eastern extent of the district, meeting the eastern boundary of Great Wakering
• South Essex Coastal Towns – encompasses Hockley, Rochford and Rayleigh and the area in between, and Great Wakering

10.36 The Essex Landscape Character Assessment 2003 also recognises that traditional landscape characters – such as the Upper Roach Valley and the Crouch Valley – survive well and need particular protection from landscape or development change. A specific assessment was undertaken in 2005 for the coastline; the Landscape Character Assessment of the Essex Coast. This assessment identified a number of landscape character areas along our coastline including: Crouch Estuary and Foulness, Rochford mixed farmlands, River Roach, Canewdon sloping claylands, and River Crouch. These areas broadly align with the Coastal Protection Belt. The Essex Wildlife Trust have identified the Upper Roach Valley, the Crouch and Roach estuaries, areas to the east of Rochford and Foulness Island as 'living landscapes'^[45], which will need to be considered further as part of a local level landscape character assessment for the district.

10.37 National policy supports the protection of valued landscapes and requires us to implement criteria based policies to assess any schemes which may impact on landscape areas. It requires us to maintain the character of the undeveloped coast and to protect and enhance its distinctive landscapes, whilst improving public access to and enjoyment of the coast. We are required to plan for biodiversity at a landscape-scale across local authority boundaries.

10.38 The Environmental Capacity Study 2015 notes that there is an evident east to west divide across the district in terms of landscape, with mostly low lying land with marsh and sandy flatlands to the east of the district creating far-reaching views. The undeveloped coast is one of the most important landscape assets of our district; an area which is recognised for its wildlife and natural importance through the national and international nature conservation designations. We are encouraged by national policy to protect such areas but to also improve access. Core Strategy Policy ENV2 on the Coastal Protection Belt seeks to direct development away from the undeveloped coastline wherever possible. This includes preventing the potential for coastal flooding and not permitting development in areas at risk of flooding, erosion or land instability. The extent of the Coastal Protection Belt is allocated within policy ELA2 of the Allocations Plan. A Marine Management Plan is also being prepared by the Marine Management Organisation – the marine area beyond the district will be covered by the South East Marine Plan^[46]. Until this is adopted, the UK Marine Policy Statement^[47]shouldbe referred to.

10.39 The Upper Roach Valley is located between the towns of Rayleigh, Hockley and Rochford, and includes Hockley Woods – which is Ancient Woodland – and Cherry Orchard Jubilee Country Park. This is an area with special landscape characteristics. The role of the Upper Roach Valley as a large 'green lung' has been further reinforced providing a substantial informal, accessible area for recreation, with green links criss-crossing the valley and connecting Rochford with Rayleigh and linking the Cherry Orchard Jubilee Country Park in the south with Hockley Woods in the north. This area is known for its landscape, as well as biodiversity, importance. Core Strategy Policy URV1 seeks to protect this area from development which would undermine it as a vast 'green lung', but provide recreational opportunities for local residents. It supports the expansion of the Country Park, and the creation of links with other parts of the Upper Roach Valley, effectively creating a single, vast informal recreational area. This broad policy is supported by policy ELA3 of the Allocations Plan which identifies its boundary.

10.40 National policy also recommends that landscape character assessments are prepared, and integrated with an assessment of historic landscape character. These assessments should consider the sensitivity of the landscape. Taking a landscape scale approach can help to build resilience in wildlife. A Historic Environment Characterisation Project was undertaken in 2006 which considers the rich history of the area, the historic natural landscape and the potential for significant archaeological deposits across the district, and their sensitivity to change. A further district-level landscape character assessment; taking account of the Historic Environment Characterisation Project will be prepared in due course to inform the next stage of plan-making to provide a greater understanding of the value and importance of landscapes across the district. The Environmental Capacity Study 2015 also recognises that there is good quality (grade 1-3) agricultural land through most of the district with high quality (grade 1-2) in the central area. There are also large areas of safeguarded mineral (brickearth) deposits in the central area of the district. The study recommends a further distinction between grade 3a and 3b to identify any possibilities for small scale housing development in the western area of the district.

What are the identified issues?

10.41 Any proposed schemes need to take into account the different landscape characters across the district with the aim of protecting and enhancing the diversity and local distinctiveness of the countryside. However some landscapes are more sensitive to development than others, and any schemes need to be carefully considered within this local context. We therefore need to prepare more detailed evidence on local landscape characters within the context of the wider landscape character areas identified through the Essex Landscape Character Assessment. The Environmental Capacity Study 2015 considers landscape character, historic environment and key recreational areas together to determine potential sensitivity; unsurprisingly the areas comprising the Upper Roach Valley and Dengie and Foulness Coast are considered to have a higher sensitivity compared to the other two areas. 

10.42 There is potentially some policy conflict between the direction of policies in our Development Management Plan (such as policy DM10) – which supports schemes within the South Essex Towns Landscape Character Area, which is predominantly covered by our Upper Roach Valley Special Landscape Area, and Hockley Woods which is Ancient Woodland. It was clear from the early community engagement programme in 2016 that residents value the open, rural nature of the area. This further reinforces the need to have more detailed evidence on local landscape characters.

10.43 From an agricultural land quality perspective, the district can be divided into three different areas, as set out in the Environmental Capacity Study 2015, with varying sensitivity to change. The land to the east of the district has medium to high sensitivity due to the quality of the land and soils, and their importance to wildlife; whereas as you move further to the west of the district towards the central area the sensitivity is medium due to the soil types and minerals deposits. The west of the district has the lowest sensitivity as it contains our three towns with lower quality agricultural land.  

What are the realistic options? 

10.44 Five options have been identified for landscape character.

Option	Justification
(2) Retain the current policies on the Upper Roach Valley	Our Core Strategy (policy URV1 and ELA3) are considered to be appropriate and in line with national policy, however the extent of the Upper Roach Valley may be reviewed as part of a local level landscape character assessment.
(1) Retain the current policies on the Coastal Protection Belt	Our Core Strategy (policy ENV2 and ELA2) are considered to be appropriate and in line with national policy. However the extent of the Coastal Protection Belt will reviewed as part of a local level landscape character assessment.
Develop a broad policy on landscape character	This policy would consider the varied landscapes across the district, and identify any particular sensitivities.
Ensure consistency throughout Development Management Plan policies in relation to supporting development in appropriate landscape character areas and special landscapes.	A more detailed assessment of landscapes within the district should help to resolve any potential issues of conflict within existing policies.
Do not have a policy on landscape character	The NPPF supports the protection of distinctive and valued landscapes, including the undeveloped coast. It would therefore not be appropriate to fail to have a policy addressing landscape character.

(12) Protecting and Enhancing Heritage and Culture

Where are we now? 

10.45 There is a strong sense of heritage and culture within the district, ranging from the natural environment, with miles of unspoilt coastline, to the historic Conservation Areas in many of our town and village centres. The district is predominantly rural and is rich in natural heritage, consisting of miles of internationally and nationally protected stretches of our coastline, 14 ancient woodlands, five scheduled ancient monuments and many nature reserves. The heritage of our district – both the natural and built environment – was highlighted as important through the early community engagement programme in 2016.

10.46 There are over 330 Listed Buildings across the district, with concentrations in our towns and villages. Area Action Plans have been adopted for the town centres of Hockley, Rayleigh and Rochford, with the latter two encompassing their Conservation Areas highlighting the importance of their historical identity. These plans are centred upon increasing the attractiveness of the centres to shoppers and visitors, partially through regeneration to preserve and enhance the character and heritage of the area.

10.47 In order to preserve the character of the district high quality design is an essential practise. Through the implementation of Core Strategy policy CP1 we seek to promote good design which takes into account to the local setting following guidance from our Housing and Design Supplementary Planning Document, the Essex Design Guide and Urban Place Supplement. Any schemes within our 10 Conservation Areas are subject to Core Strategy policy CP2, requiring that the actions recommended in the adopted Conservation Area Appraisal and Management Plans are implemented in order to protect these areas against inappropriate development. Essex County Council's Essex Design Guide is also referred to inform heritage-led developments within sensitive areas. This document is currently being updated.

10.48 Some buildings carry historic value providing a sense of identity and place in addition to being the physical evidence of our cultural heritage. These buildings are listed, applying a statutory protection to them, resulting in proposed building works, both internal and external, requiring an additional level of approval to be sought. Some buildings, despite not being listed, are of local distinctiveness and form part of a familiar and cherished local scene. These buildings form part of the Local List Supplementary Planning Document and, although not statutory, through implementing Core Strategy policy CP3, we encourage land owners to be sympathetic, avoiding demolition or any alterations which would diminish the architectural, historic or townscape value of these locally important buildings.

10.49 Development Management Plan policy DM7 provides further guidance on the treatment of locally listed building through the planning application process. Policies DM8 and DM9 in this plan relate to demolition within Conservation Areas and development just outside these areas; and further seek to protect the character of the Conservation Areas. Policy DM23 also seeks to specifically manage schemes proposed in Conservation Areas within the Green Belt. 

What are the identified issues?

10.50 There is a risk of inappropriate development in Conservation Areas. These areas are afforded statutory protection under the Planning (Listed Buildings and Conservation Areas) Act 1990 for alterations such as extensions, boundary treatments, the demolition of unlisted buildings and works to trees. However, designation of a Conservation Area does not prevent all changes and the area may be subject to pressures (good and bad) that will affect their character and appearance.  

10.51 There are numerous Listed Buildings within the district. However there are many buildings which do not merit statutory listing but are important in contributing to the local distinctiveness and form a familiar part of the local streetscene. Those buildings are protected within Conservation Areas, but outside there is no statutory protection. We have prepared a Local List Supplementary Planning Document to identity and seek protection of their important assets, including resisting unsympathetic alterations.

What are the realistic options? 

10.52 There are two options that have been identified for heritage and culture.

Option	Justification
(5) Retain the existing policies	Core Strategy policies CP1, CP2 and CP3 are considered to be appropriate and fit for purpose in seeking to maintain high quality design and preserving the local heritage and culture in the district. The supplementary policies in the Development Management Plan (policies DM7 DM8, DM9 and DM23) contribute to this purpose through appropriately managing schemes within sensitive areas. The policies within the Area Action Plans for Rayleigh and Rochford, in particular, due to their historic significance are also heavily focussed on protecting the character of these town centres. Locally listed buildings, which do not have statutory protection, are afforded some protection through the planning polices by Core Strategy policy CP3 and Development Management Plan policy DM7.
Do not have policy or  additional guidance relating to culture and heritage	This is not seen as a feasible option. It is vital to protect the culture and heritage of the district, through maintaining good design practises and preserving historically important areas. The policies seek to maintain the character of the district which is steeped in history, which is important not only for the welfare of local people through preserving a quality environment but also the local economy through tourism opportunities.

(5) Good Design and Building Efficiency

Where are we now?

10.53 Good quality design is essential for creating safe, attractive and prosperous places where people want to live, work and visit. It is important that the design of any scheme is of high quality and sensitive to our local areas, through drawing on the existing strengths of our rich natural and built environment to create a sense of place. National policy places great importance on achieving high quality, inclusive design and a good standard of amenity within schemes. Accessibility is also important through the provision of clear pedestrian routes and high quality public spaces.

10.54 The general thrust of national policy is reflected in our current policies on design in the Core Strategy and Development Management Plan. Policy CP1 sets the broad approach that should be taken to design; to reflect local character and distinctiveness and take cues from the existing historic fabric of the area. It recognises that good design can prevent further erosion of the area's character. Guidance in Supplementary Planning Documents and Village Design Statements are recommended, and other design guidance such as the Essex Design Guide and Urban Place Supplement are referred to. It is appreciated that, whilst creating a sense of place, good design can also encourage community cohesion by designing out crime and anti-social behaviour, and reduce inequalities. It is also recognised that other aspirations such as small-scale renewable energy projects could conflict with good design principles, so the location, scale, design in particular needs to be carefully considered. Policy DM1 sets out a criteria-based approach to how good design principles should be applied to any schemes. This is supported by our Housing and Design Supplementary Planning Document.

10.55 In terms of efficient building design, our Core Strategy includes a policy on the code for sustainable homes (policy ENV9) which was the national single standard on energy efficiency for new homes and involved an environmental assessment method for new homes based on a scoring system of six levels. The Government's aim was for all new homes to be carbon-neutral (code level 6) by 2016. As part of housing standards review by the Government in 2014, however, most of the initiatives within the code for sustainable homes were put into Building Regulations to deliver a more standardised and clear approach to efficiency expectations; which limits efficiency standards to code level 4. However, energy efficiency measures such as limited water, energy, access and space can still be required through planning.

10.56 BREEAM standards for commercial and industrial buildings – which are set out in the Core Strategy (policy ENV10) – were not affected by this review and can still be required through planning. BREEAM (Building Research Establishment Environmental Assessment Method) is the most widely used environmental assessment method for buildings. BREEAM covers a wide range of building types such as BREEAM Offices and BREEAM Retail, which are assessed against set criteria. There are four levels of rating for all commercial and industrial buildings to achieve (Pass, Good, Very Good and Excellent). We require a 'Very Good' standard as a minimum unless this would affect the viability of a particular scheme.

What are the identified issues?

10.57 Overall, it is considered that our current policies are broadly sufficient in being able to deal with design issues when assessing any schemes. However, at times it is recognised that good design principles – from an urban design perspective – could create conflict with security. Security principles set out in the national guidance Secured By Design^[48]are referred to in the Development Management Plan, but are not specifically referenced in any design policies.

10.58 The Essex Design Guide provides guidance on principles for reflecting local character within the county. There are currently no Village Design Statements that set out design criteria for specific areas, or other area level plans that have established design principles (other than the Area Action Plans). Many of the district's towns and villages are however covered by Conversation Area Appraisals and Management Plans due to their historic importance.

10.59 The Housing White Paper raises concerns that design guidance is not localised enough to ensure that schemes reflect the character and identity of individual areas. We have specific design guidance within our Supplementary Planning Documents on housing design, design, landscaping and access but the paper recommends detailed guidance within policies – whether they are local or neighbourhood plans. It suggests that design codes or similar be prepared in consultation with local communities, which would mean – it is suggested – that if a scheme complies with a particular code, then design would not be a valid reason to object to the scheme at the planning application stage. 

10.60 There are limitations on the efficiency measures that can be required through planning for new homes. It is also challenging to enforce compliance with the remaining efficiency measures which still fall within planning, given the types of measures that would be required for energy efficiency such as shallower baths and more efficient toilet systems.

10.61 We still require commercial and industrial buildings to comply with BREEAM standards. This approach is still considered to be appropriate in the drive for efficiency; however in practice viability has proved to be an issue. Complying with BREEAM may not be appropriate for all building types, for example warehouses, and the BREEAM assessment itself, and even proving that it is not economically viable has been found to have a detrimental affect on the deliverability of schemes.  

What are the realistic options?

10.62 Four options have been identified in relation to ensuring design principles are appropriate.

Option	Justification
(3) Retain the existing policies on design.	The current design policies are considered to be broadly sufficient in being able to deal with design issues when assessing any schemes. However any changes in national policy or guidance, such as design codes, may need to be considered.
Ensure design policies make specific reference to Secured by Design, and the need to strike an appropriate balance between urban design and security.	It is important to ensure that any scheme – whilst being appropriately sensitive to the local context – is also suitably secure over the lifetime of the development.
(1) Retain current guidance within our Supplementary Planning Documents.	Our current guidance provides broad principles that schemes should follow to ensure that they are appropriately designed, which is considered to be fit for purpose. However this could be further expanded to provide more specific design guidance for each area.
Develop specific design principles for individual towns and villages building on the current guidance within our Supplementary Planning Documents.	This would ensure that any new schemes, potentially  outside of those covered by the Area Action Plans and Conversation Area Appraisals and Management Plans,  are suitably designed for each area, in consultation with local communities, which have already agreed a design code or framework for schemes.

10.63 Seven options have been identified for building efficiency standards for new homes, and new commercial and industrial buildings.

Option	Justification
Remove reference to the Code for Sustainable Homes and replace with a simpler policy on water efficiency.	Core Strategy policy ENV9 has mostly been replaced by changes to Building Regulations. However the NPPF promotes sustainable development, and resilience to climate change.
(1) Continue to drive up energy efficiency standards for new homes through replacing the Code for Sustainable Homes with one that focuses on energy, thermal and water efficiency in particular.	This option would ensure that all new builds meet minimum standards for energy, thermal and water efficiency which would improve their sustainability and reduce greenhouse gas emissions in line with national policy. However, this may prove to be challenging to enforce.
Do not have a policy on energy efficiency standards for new homes.	Promoting sustainable development is a thread running through the NPPF. The potential impacts of climate change are also a concern, so improving the sustainability and efficiency of homes is supported by national policy.
Retain existing policy on BREEAM.	Core Strategy policy ENV10 is considered to be fit-for-purpose in terms of ensuring a high standard of energy efficiency for commercial buildings in accordance with national policy and guidance. However applying it to all types of commercial buildings may not be appropriate.
Amend the existing policy on BREEAM to apply to only certain types of buildings.	Given the viability challenges that affect schemes trying to assessment BREEAM; therefore the requirement could just be applied to public buildings as an example of good practice, so that the delivery of private schemes is not hindered.
(1) Include a specific policy on the efficiency of conversions, extensions and alterations to existing homes.	This option would ensure that conversions, extensions and alterations to existing homes meet minimum standards for energy, thermal and water efficiency which would improve their sustainability and reduce greenhouse gas emissions in line with national policy.
(1) Do not have a policy on energy efficiency standards for conversions, extensions and alterations to existing homes.	Promoting sustainable development is a thread running through the NPPF. Potential impacts of climate change are also a concern, so improving the sustainability and efficiency of homes is supported by national policy. This is not considered to be an appropriate option.

(58) Air Quality

Where are we now? 

10.64 Access to clean air is a fundamental requirement when seeking to ensure a high standard of living. Exposure to poor quality air is associated with health risks, environmental damage and pollution.

10.65 Air quality in a particular area can be affected by a number of factors, including emissions from nearby industrial and commercial activities and vehicle movements, as well as the density and scale of buildings through the potential to affect the dispersal of pollutants. Vehicle movements are responsible for the majority of nitrogen dioxide (NO2) emissions across the country^[49]. Growing dependence on cars in the district has increased air pollution in recent decades; however technological improvements and shifts towards more sustainable ways to travel (such as walking, cycling and public transport) may help to counteract this.

10.66 We are required to monitor air quality periodically within our administrative area, in order to monitor and assess air quality against set standards. Where air quality is particularly poor, we need to designate an Air Quality Management Area (AQMA) and propose an action plan to improve air quality in that area. Air quality was identified through the early community engagement programme, which took place in 2016, as an area of concern. 

10.67 Paragraph 124 of the NPPF states that planning policies should sustain compliance with, and contribute towards, EU thresholds or national objectives for pollutants, taking into account the presence of Air Quality Management Areas (AQMAs) and the cumulative impacts on air quality from individual sites in local areas. Core Strategy policy ENV5 states that schemes for new homes will be restricted in any areas designated as AQMAs, in order to reduce public exposure to poor air quality. The policy also states that we will seek appropriate measures to reduce the impact of poor air quality and to address the causes of poor air quality. Our approach to supporting and encouraging sustainable ways to travel and requiring travel plans (considered in the 'Delivering Infrastructure' chapter) seeks to reduce carbon emissions produced by vehicles wherever possible. Development Management Plan policy DM29 specifically requires all major schemes (10 or more homes, or a site area over 0.5 hectares) to undertake air quality assessments, with conditions attached to any approval of permission to offset the impact on local air quality.

10.68 The Environmental Capacity Study 2015 examines the issue of air quality and notes that a key cause of air quality issues in the district is congestion and emissions from road traffic. It recommends that to mitigate additional vehicle use arising from new homes and businesses, the following measures should be supported: highway improvements, particularly to reduce congestion; provision of better and more efficient public transport; improved walking and cycling routes and improved rail lines and train services. Policies relating to these measures are considered in more detail in the 'Delivering Infrastructure' chapter.

What are the identified issues?

10.69 The district has high sensitivity to changes in air quality, as noted in the Environmental Capacity Study 2015, due to the capacity of the road network. We   currently have one area designated as an AQMA, Rayleigh High Street. This AQMA area envelops the Rayleigh High Street (A129) from the junction with Sweyne Court to the junction with the A127, at the Rayleigh Weir. This AQMA was declared in February 2015 after monitoring showed marginal exceedances on Government guidelines on Nitrogen Dioxide. The Rayleigh Town Centre Air Quality Action Plan (AQAP), due to be adopted in 2017, sets out the Council's strategy for tackling the poor air quality in this AQMA area. The AQAP notes that the Council's adopted local development plan includes policies and measures which will help to reduce poor air quality over the plan period, such as promotion of greener, sustainable transport options and potential improvements to Rayleigh town centre. However, the AQAP also suggests further actions which may help to alleviate the poor air quality in the AQMA, of which some actions may fall within the scope of the new Local Plan. Such actions include highway management schemes and alterations, electric vehicle charging points, and enhanced pedestrian and cycling routes.

10.70 The development of new homes in areas with poor air quality, particularly areas designated as an AQMA, may have the potential to exacerbate the air quality situation, and expose a greater number of residents to poor quality air. Where such schemes are proposed, it may be necessary to consider the impact such a proposal would have on the quality of air in the area, and the potential harm to those residents living within the AQMA area. However, our current policy seeks to restrict residential development within AQMAs. The Environmental Capacity Study 2015 however notes that poorer air quality is likely to the west and south-west of the district and associated with road traffic emissions and the key transport corridors of the A130 and A127, including routes into Southend-on-Sea and to London Southend Airport.

10.71 During our early community engagement programme in 2016, concerns were raised by some residents regarding the quality of air in certain areas of the district, and whether air quality was being monitored in these areas. Whilst the monitoring of air quality is fundamentally dealt with by the Council's Environmental Health team, it may be necessary to consider the impact that proposed developments have on air quality across the district, and any areas which are declared AQMAs in the future, in order to adequately safeguard residents against exposure to poor air quality.

What are the realistic options? 

10.72 There are four options that have been identified in relation to air quality.

Option	Justification
(3) Retain the existing policies on air quality	Core Strategy policy ENV5 is still considered to be fit for purpose and allows us to restrict schemes for new homes where it would increase exposure to poor air quality or exacerbate existing poor air quality situations. Development Management Plan policy DM29 is also still considered to be appropriate in requiring air quality assessments for specific schemes.
(2) Continue to promote clean air initiatives, such as sustainable ways to travel and renewable energy projects	Such proposals, where implemented, may help to improve air quality in that location and reduce the risks associated with exposure to poor air quality. Making use of technological innovations can result in positive contributions to managing air quality.
(1) Support, where appropriate, the actions put forward in the Rayleigh Town Centre Air Quality Action Plan	The Rayleigh Town Centre Air Quality Action Plan includes specific proposals to combat poor air quality within the designated Rayleigh High Street AQMA. Where these actions require planning permission, or other planning involvement, supporting the implementation of these actions, provided they are considered appropriate, may help to alleviate the poor air quality situation in this area.
Do not have a policy on air quality	Such an approach is not considered to be a realistic option as national policy requires us to consider the impact proposed development has on air quality, and the presence of AQMAs.