Dear Sir/Madam

Rochford District Council Issues and Options Document and Draft Sustainability Appraisal (Screening) Public Consultation

Thank you for your consultation on the above dated 6th February 2018 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Local Plan (Issues and Options Document)

Section 3: our characteristics

 Under key Environment Characteristics: (page 12) the first bullet point states "our district has significant areas of ecological value, particularly the Crouch and Roach estuaries and Foulness Island". We advise that this sentence includes the international and national designated importance of the estuaries.

Section 4: our special challenges

 Section 4.10 highlights cooperation between Essex authorities in strategic and cross-boundary matters. We advise that the natural environment is included as a cross-boundary matter in light of the strategic approach required to address recreational disturbance impacts on coastal protected sites. Rochford District Council has signed a Memorandum of Understanding to work with neighbouring authorities though the Essex Recreation Avoidance Mitigation Strategy (RAMS) project and we recommend that this is recognised in the list of cross-boundary matters which will be addressed through the Duty to Cooperate.

Section 5: our vision and strategic objectives

 The draft vision for 2037 (page 25) is written as "Rochford District is a green and pleasant place with a focus on business and high quality homes supported by accessible and responsive services and facilities, creating healthy and sustainable communities". We suggest the following amendment: Rochford District is an environmentally rich and pleasant place with a focus on business and high quality homes supported by accessible and responsive services and facilities, creating healthy and sustainable communities.

Our Environment (page 26): as in line with the NPPF and the commitment of the 25 Year Environmental Plan to "embed an environmental net gain principle for development, including housing and infrastructure" we recommend a commitment to delivering net gain for the natural environment, in order to compensate for residual impacts of development on environmental assets. In addition this could be included and expanded in Strategic Objective 19.

Section 6: delivering homes and jobs

Strategic Priority 1.6: Houseboats and Liveaboards (page 54): further information on current houseboat and liveaboard numbers and location in Rochford and the wider Essex area would be useful as baseline data to understand potential impacts of increased numbers to designated sites. Impacts should include both disturbance to species and habitats and pollution from waste effluent.

We support the following options:
o B) Amend existing policy to strengthen criteria.
o D) Amend the definition in the Development Management Plan with the aim of agreeing a clear definition at county level and one that reflects potential impacts on protected sites
o C) Allocate specific areas of coastline where such uses may be acceptable
 Policy should align with best practice proposed by the Essex RAMS project to ensure recreation disturbance is adequately managed within a strategic framework that is Habitats Regulations Assessment compliant (HRA).

 Natural England welcomes the opportunity to work with the Local Planning Authority to address the issue, with regard to potential ecological impacts, and help formulate a policy that does not pose an adverse impact on any designated sites.

 Strategic Policy 1.9: London Southend Airport (page 65): any potential impacts to air quality resulting from an increase in flights, duration and/or adjustment in aircraft or flight paths (including the operational implications of stacking) and road infrastructure should be considered and HRA compliant. It is likely any proposed expansion would require a Habitats Regulations Assessment and this needs to be addressed at a strategic level as part of the Local Plan. Delivery of any mitigation recommendations identified through the HRA and SA will need to be secured through robust Plan policies.

 Natural England's preferred option is A, "retain and update the Core Strategy policy supporting London Southend Airport's growth". This option will update existing policy and ensure reflection of any environmental impacts particularly on any Sites of Special Scientific Interests (SSSI's) and Natura 2000 sites.

 Strategic Policy 1.10: supporting tourism and rural diversification. This policy should consider any potential impacts to the natural environment including recreational disturbance.

 This section should also recognise that the England Coast Path may provide economic opportunities for tourism and the rural environment.

Strategic Policy 3: the provision of infrastructure for transport, telecommunications, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat)

 Strategic Policy 3.4: water and flood risk management. Natural England supports the proposal to update the Water Cycle Study and we advise that the results of this study should be used to inform the HRA. We acknowledge that that the Environmental Capacity Study found that water supply and capacity for water treatment was sufficient until 2032. The revised Local Plan extends this time period until 2036 and consideration should be given to ascertain if additional capacity is required to meet the needs of development up to 2036. Evidence should be provided to demonstrate that any measures needed to address capacity shortfalls can be implemented ahead of / in line with development. This is needed to demonstrate that Local Plan development is sustainable and will not have an adverse effect on the environment including nationally and internationally designated sites. Delivery of mitigation measures should be secured through robust Plan policies.

 In Para 8.46 this section states "As noted within the Environmental Capacity Study 2015 the Essex and South Suffolk Shoreline Management Plan policy is to hold the line with maintaining or upgrading defences along the coast." This implies that 'hold the line' is the SMP preferred policy along the whole of the Rochford shoreline. We advise this section is revised to reflect the SMP fully and include coastline areas under managed realignment.

The plan should refer to the relevant Shoreline Management Plan and take forward applicable actions. Local Authorities should use Shoreline Management plans as a key evidence base for shaping policy in coastal areas.

Sea level rise and coastal change are inevitable and bring both challenges and opportunities for people and nature. Sustainable coastal management needs to embrace long-term change and achieve positive outcomes for both.

Local Plans should therefore provide for coastal adaptation and work with coastal processes. Plans within coastal areas should recognise the need to respond to changes over long timescales and adopt an integrated approach across administrative and land/sea boundaries. A successful integrated approach should set levels of sustainable levels of economic and social activity whilst protecting the environment.

We would also advise that Local Plans should help facilitate the relocation of valued environmental assets away from areas of risk.

Strategic Priority 4: The provision of health, security, community and cultural infrastructure and other local facilities

Strategic Policy 4.3: open space and outdoor sports recreation. We advise that open space policy corresponds with Natural England's Accessible Natural Green Space Standards (ANGST), which describes the amount, quality and level of visitor services we recommend for all areas. This will help to ensure the delivery of sufficient levels of high quality informal open space to meet the needs of new residents and to buffer and enhance the resilience of the natural environment, particularly more sensitive designated sites.
Strategic Policy 5: protecting and enhancing our environment

Strategic Policy 5.2: biodiversity, geology, and green infrastructure (10.27). We recommend the strengthening of existing policy ENV1 and a commitment to net gain in line with the requirements and aspirations of the NPPF and 25 Year Environmental Plan.

Protection of local habitats of important ecological value (10.28).We agree that option F should be updated to reflect the findings of the latest Local Wildlife Sites assessment. If options C-F are merged to form a singular strategic nature conservation policy, it should include the same level of protection and enhancement as existing policy.

Section 10.43 identifies broad soil sensitivity and its importance to wildlife across the district. The Local Plan should give appropriate weight to the roles performed by the area's soils. These should be valued as a finite multi-functional resource which underpins our wellbeing and prosperity. Decisions about development should take full account of the impact on soils, their intrinsic character and the sustainability of the many ecosystem services they deliver.

The plan should safeguard the long term capability of best and most versatile agricultural land (Grades 1, 2 and 3a in the Agricultural Land Classification) as a resource for the future in line with National Planning Policy Framework paragraph 112 to safeguard 'best and most versatile' agricultural land. The plan should recognise that development (soil sealing) has an irreversible adverse (cumulative) impact on the finite national and local stock of Best and Most Versatile (BMV) land. Avoiding loss of BMV land is the priority as mitigation is rarely possible. Retaining higher quality land enhances future options for sustainable food production and helps secure other important ecosystem services.

 Strategic Policy 5.3: Wallasea Island and the RSPB's Wild Coast Project. Natural England supports option A which retains existing policy and supports Wallasea Island Wild.

 Strategic Policy 5.4: landscape character. Natural England expects the Plan to include strategic policies to protect and enhance valued landscapes, as well as criteria based policies to guide development, as set out in the National Planning Policy Framework (NPPF).

 We support the review of the Upper Roach Valley and coastal protection belt as part of the Local Landscape Character Assessment and new evidence should be used to strengthen and adapt existing policy.

Detailed policy considerations

 D.P1.13: light pollution (page 163): light pollution can give negative impacts on local amenity, intrinsically dark landscapes and on nature conservation, particularly invertebrate and bats. We advise that policies should address impacts on the natural environment in accordance with government guidance on light pollution1. Light pollution policy should ensure the protection of existing dark skies and that new developments increased local light pollution in sensitive areas.

 The Campaign to Protect Rural England have produced maps on light pollution which may be a useful evidence resource for local policy.

Sustainability Appraisal

Natural England is broadly satisfied that the Sustainability Appraisal has been prepared in accordance with the requirements of the SEA Directive, as transposed through the Environmental Assessment of Plans and Programmes Regulations 2004. We have provided advice on the Issues and Options Document and Draft Sustainability Appraisal below.

1. Do you think the Local Plan might have a 'likely significant effect' on Natura 2000 sites? If so, in which broad locations and what might be the likely effects?
Depending on the quantum and location of development, the local plan may have a likely significant effect on:
 Crouch and Roach Estuaries SPA and Ramsar,
 Foulness SPA and Ramsar
 Essex Estuaries SAC
 three SSSIs Hockley Woods, Foulness and the Crouch and Roach Estuaries

However, details of new housing location allocations is not provided in the sustainability appraisal or issues and options document. The local plan will need to have its own Habitats Regulations Assessment (HRA) in due course. The findings and recommendations of the HRA should inform the SA. Mitigation recommendations should be referenced, and implementation secured, through robust Plan policies.

Sufficient evidence should be provided through the HRA to demonstrate any significant effects including increased recreational pressure and changes in air quality associated with new development, with suitable and proportionate mitigation included. The district is sensitive to changes in air quality and evidence through air quality modelling may need to be provided. A likely increase in visitor pressure at key locations may also need to be delivered and measures to address adverse effects should follow the mitigation hierarchy, i.e. measures to avoid impacts should be prioritised. Where adverse impacts cannot be avoided, detailed measures to mitigate these will need to be provided.

Natural England welcomes the commitment to develop an Essex wide strategy to identify potential impacts of recreational disturbance resulting from the delivery of new homes and mitigation delivery through the Essex Coastal Recreational Avoidance and Mitigation Strategy.

We fully support the ambition to work with neighbouring local authorities to identify local wildlife corridors and networks across boundaries

2. Have all the policies, plans, and programmes that are relevant to the production of the Plan been considered? Or are there other documents that should be added to those outlined in the 'Schedule of Plans, Policies & Programmes relevant to the Plan'?

Natural England has not reviewed the plans listed. However, we advise that the following types of plans relating to the natural environment should be considered where applicable to your plan area;

Green infrastructure strategies
 Biodiversity plans
 Rights of Way Improvement Plans
 Shoreline management plans
 Coastal access plans
 River basin management plans
 Relevant landscape plans and strategies

3. Is the data collected in the 'Schedule of Baseline Information relevant to the Plan', to the best of your knowledge, factually correct?

No comment

4. Is the data collected in the 'Schedule of Baseline Information relevant to the Plan' is relevant and suitable for the Plan? Do you know of, or have, any additional data that you think should be added to the list already collected?

We advise that local habitat policy is reviewed and aligned with up to date baseline data to ensure maximum positive effect on biodiversity, health and wellbeing
Please see attached Annex A for our advice on additional sources of local plan evidence on the natural environment.

5. Do you agree that the issues identified as 'Key sustainability issues' are the main sustainability issues relevant to the Plan? Are there any other sustainability issues that you believe should be added?

Strategic Priority 1: Delivering homes and jobs

3.2.1.4 Tourism and rural diversification - option B: if the council seeks to expand the current approach to tourism and include other forms of rural diversification, consideration should be given to increased recreational disturbance and assessed as part of the HRA process. Any mitigation should be proportionate to insure sustainable growth in this area.

6. Will the indicators and data identified in the 'Schedule of Baseline Information relevant to the Plan' provide an effective framework for monitoring the performance of the Plan against the SA Objectives in the 'Draft Sustainability Objectives and SEA Topic'?

As set out in Planning Practice Guidance, you should be monitoring the significant environmental effects of implementing the current local plan. This should include indicators for monitoring the effects of the plan on biodiversity (NPPF para 117).
The natural environment metrics in the baseline information are largely driven by factors other than the plan's performance. They are thus likely to be of little value in monitoring the performance of the Plan. It is important that any monitoring indicators relate to the effects of the plan itself, not wider changes. Bespoke indicators should be chosen relating to the outcomes of development management decisions.

Whilst it is not Natural England's role to prescribe what indicators should be adopted, the following indicators may be appropriate.

Biodiversity:
 Number of planning approvals that generated any adverse impacts on sites of acknowledged biodiversity importance.
 Percentage of major developments generating overall biodiversity enhancement.
 Hectares of biodiversity habitat delivered through strategic site allocations.
Green infrastructure: Percentage of the city's population having access to a natural greenspace within 400 metres of their home.
 Length of greenways constructed.
 Delivery of objectives and targets in the Green Grid Strategy
 Hectares of accessible open space per 1000 population.

7. Are there other/additional methodologies that could be used to identify the significant effects of the Local Plan?

No comment

Sources of local plan evidence on the natural environment

The following sources of evidence may be useful in ensuring local plans are evidence based, in line with paragraph 165 of the National Planning Policy Framework (NPPF) and assist in meeting Strategic Environmental Assessment (SEA) requirements. A range of additional locally specific evidence is also likely to be needed to underpin plan preparation.

i. General natural environmental evidence

National Character Areas (NCAs) divide England into 159 distinct natural areas. NCA profiles contain descriptions of the area and statements of environmental opportunity, which may be useful to inform proposals in your plan. Natural England has also published downloadable natural capital maps. There is a suite of ten maps, of different aspects of natural capital, which contributes to our understanding of where our natural capital is.

The Magic website will provide you with much of the nationally held natural environment data for your plan area in downloadable GIS format.
Local environmental record centres may hold a range of additional information on the natural environment, principally ecological. The following local organizations may also hold environmental information where applicable: Local Nature Partnerships, Wildlife Trusts, Areas of Outstanding Natural Beauty Partnerships and Nature Improvement Areas.

Evidence relating to the significant environmental effects of the current local plan should be available (in line with SEA legislation), as should suitable biodiversity evidence for any plan adopted after the NPPF came into effect (27 March 2012), usually through the current plan's Annual Monitoring Report.

ii. Landscape

The Magic website provides data on the extent of protected landscapes (National Parks and Areas of Outstanding Natural Beauty). National Park/Area of Outstanding Natural Beauty Management Plans may also be a source of useful evidence. These are usually found on these organisations websites.

Most areas have local landscape character assessments. These are tools to help understand the character and local distinctiveness of the landscape and identify the features that give it a sense of place. It can help to inform, plan and manage change in the area. Data on tranquillity is held by CPRE. They also hold mapping data on light pollution.

iii. Biodiversity and geodiversity

The most relevant layers on Magic for you to consider are Ancient Woodland, Local Nature Reserves, Priority Habitat Inventory, Sites of Special Scientific Interest (including their impact risk zones), Special Areas of Conservation, Special Protection Areas, and Ramsar Sites (including, where relevant, marine designations).
You may also wish to draw on more detailed information on specific Sites of Special Scientific Interest and the Conservation Objectives and Site Improvement Plans for Special Areas of Conservation and Special Protection Areas.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Larger areas of priority habitat will usually be mapped either as Sites of Special Scientific Interest on the Magic website or as Local Wildlife Sites or Local Geological Sites. Local wildlife site data is usually held by local planning authorities themselves as is local geological site data. Local Environmental Record Centres and local wildlife and geoconservation groups are also a source of information on Local Sites.

Natural England maintains the Open Mosaic Habitat on Previously Developed Land Inventory (a priority habitat dataset currently not integrated into the Priority Habitat Inventory on Magic) and is available on request from Natural England via email; NaturalEnglandGIDataManagers@naturalengland.org.uk.
Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area. Local Geodiversity Action Plans (LGAPS) identify agreed local action for geodiversity, a list of active LGAPs can be found at UK Geodiversity Action Plan (http://www.ukgap.org.uk/getting-involved/lgaps.aspx).
Some areas have identified Biodiversity Opportunity Areas or similar for spatially targeting biodiversity restoration work.

Protected species are those species protected under domestic or European law. Local environmental record centres are likely to hold much of the available data on such species.

APIS holds data on air pollution in particular in relation to protected nature conservation sites.

iv. Access

The Magic website holds the following access related data: National Trails, Public Rights of Way (on the Ordnance Survey base map), Open Access Land (the Countryside and Rights of Way Act 2000 layer), together with national and local nature reserves, country parks and the England Coast Path.

Locally held data will include the definitive Public Rights of Way, and may include Rights of Way Improvement Plans where they exist, and any locally mapped open space audits or assessments.

Natural England's work on Accessible Natural Greenspace Standards (ANGSt) may be of use in assessing current level of accessible natural greenspace and planning improved provision.

v. Green infrastructure

Green infrastructure strategies may comprise or contain useful evidence sources where they exist.

vi. Soils

A provisional Agricultural Land Classification (ALC) map is on Magic, and the GIS layer 'Likelihood of Best and Most Versatile Land' is available on request from Natural England via email;

Some areas already have detailed ALC maps. The coverage of existing detailed MAFF post 1988 ALC surveys is shown on Magic. The MAFF post 1988 ALC survey reports and maps themselves are available from Natural England or from Gov.UK. Our publication Agricultural Land Classification: protecting the best and most versatile agricultural land may also be of help.

General mapped information on soil types and Agricultural Land Classification is available (under 'landscape') on the Magic website and also from the LandIS website, which contains more information about obtaining soil data.

vii. Climate change

The Climate Change Adaptation Manual provides evidence to support nature conservation in a changing climate. The National Biodiversity Climate Change Vulnerability Assessment Model provides a spatially explicit assessment of the relative vulnerability of priority habitats. The data files can be accessed here: National Biodiversity Climate Change Vulnerability Assessment data. The LWEC Climate Change Impacts Report Cards present the latest evidence on how climate change is affecting different aspects of our environment, economy and society.

viii. Coastal and Marine issues
The following may be of help:
 Catchment flood management plans (considers all types of inland flooding, from rivers, groundwater, surface water and tidal flooding).
 Shoreline management plans (considers flooding from the sea).
 Any estuary or harbour management plans that are held locally.
 River basin management plans (covers entire river systems, including river, lake, groundwater, estuarine and coastal water bodies).
 Coastal Erosion Maps.

 The Marine Management Organisation has a marine planning evidence base which supplies a range of information on marine planning.

 There may be specific Heritage Coast information held locally, such as a management plan.

ix. Water Quality and Resources and Flood Risk Management

The Planning Practice Guidance provides guidance on information sources for the water environment.