Comment
New Local Plan: Spatial Options Document 2021
Representation ID: 40424
Received: 22/09/2021
Respondent: Essex County Council
ECC recommends that RDC appreciates the key opportunities future Green Space and GI can provide. ECC has produced a GI assets map, highlighting the huge variety of the GI environments within Essex including the RDC area. It is important that the Local Plan identifies key opportunities and seeks to facilitate future community access to GI.
The ECAC Report recommends a nature-based approach to design and GI requirements included in local planning guidance. Developers should be encouraged to implement green procurement standards for construction and there should be engagement and partnership with developers, including the establishment of an Essex Developers’ Group to collaborate and set up exemplars of green construction.
ECCs welcome the focus on Green Blue Infrastructure (GBI), which should be at the heart of the decision making at every stage in the planning process. GBI should be considered at the earliest stage in the planning process and is expected to be incorporated into design guides and masterplans. Local Plan policy should be strongly worded and commitments to positive action and GBI enhancement and protection.
• ECC recommend that the Essex Green Infrastructure Strategy (2020), and supporting standards and resources, should be utilised to support the delivery of a quality green and blue infrastructure network through RDC’s Local Plan, in addition to the South Essex Green and Blue Infrastructure Study . The Essex GI Strategy was prepared by ECC on behalf of the Essex Green Infrastructure Partnership in 2020 (which included RDC), and champions for high quality green space and GBI in Essex. The purpose of this strategy is to take a positive approach to enhance, protect and create an inclusive and integrated network of high-quality GBI in Greater Essex. This will help to create a county-wide understanding of GI, its functions and values, and to identify opportunities for delivering GBI. The strategy aims to enhance the urban and rural environment, through creating connected multi-functional GI that delivers multiple benefits to people and wildlife. Nine principles and standards for the provision, management, and stewardship of GBI have been identified including:
• Evidence-led: the planning, design and delivery of GBI is evidence-led using natural capital and ecosystem service assessments, and GI GIS mapping to ensure appropriate place-based GBI interventions are being implemented and enhanced.
• Early Collaboration and Engagement: there is early collaboration and engagement with all relevant stakeholders, partners and communities to support the delivery of effective and connected GBI.
• Commitment to delivery (via strong policy wording): Policy for GBI is strongly worded with a commitment to positive action(s) as reflected in statutory plans and industry/local guidance and supported by incentives and clear guidance about what success looks like, and
• Stewardship: The long-term management and stewardship plans are identified at the early stage with the necessary funding and monitoring components in place.
ECC has recently consulted on the Essex Green Infrastructure Standards Guidance that has been developed to support policy and decision making in the planning and delivery of multifunctional GI for placemaking and place-keeping. The document brings together existing guidance, examples of good practices and information on how to meet the GI principles and standards. It can help improve planning policy, better frame planning conditions for planning applications and shape project delivery in securing multifunctional GI. This will help to ensure GI delivers multiple benefits and meet towards the political drivers such as climate, health and ecological emergencies and green growth agenda. The Essex GI Standards and Framework and Guidance was developed through a rigorous programme of collaboration and engagement, including the ‘Make Better Policies for Better Placemaking and Place Keeping’ workshops held in 2020. Building upon the national GI Standards Framework trial programme lead by Natural England in relation to the 25 Year Environment Plan and Environment Bill.
It is recommended that the development proposal applies the Building with Nature standards and achieves an accreditation to highlight what ‘good’ looks like at each stage of the GI lifecycle and strengthen the development and demonstrate the development goes beyond the statutory minima, to create places that really deliver for people and wildlife. The Building with Nature Standards has been developed by practitioners and policy makers, academic experts and end-users, and has been tried and tested in multiple schemes from Cornwall to Scotland and is endorsed by Natural England, who is reviewing the current national GI standards. For more information please visit: https://www.buildingwithnature.org.uk/about
Furthermore, in respect of creating “greener” places and to address climate change, there may be a reliance upon specific policies to ensure new developments in the area to create improved canopy cover. This should include a need to justify a requirement for any tree removal in relation to development to ensure that development enhances the tree provision of an area. There is a risk that by using general comments relating to landscape in policies that the requirement for canopy cover may be diminished. Although there is no specific measure of this, options such as a specified replacement for volume of canopy/diameter of tree lost or Urban Greening Factor could encourage better provision within applications.
With regards to Option 3, further clarification is required on the ‘certain’ new developments and why these would be required above other developments to require a higher provision of GBI.
ECC recommend consideration is given to preparation of specific policies, having regard to the scale of development, clarifying the expectation for a development to enhance the provision of trees on a site, and consideration on how the policy would be monitored and managed. It is anticipated that the provision of GBI would be integral requirement within the provision of large scale development sites through a masterplanning approach.
ECC can provide information on the specific location and designation of common land and village greens, that may assist in informing Local Plans.
ECC recognises that there is an opportunity for the emerging Local Plan to include a policy/policies covering the GBI principles and themes that encompasses the value of wider multi-functional GBI for people and wildlife. It provides an opportunity to identify GBI deficiencies, which can be addressed through planning, such as improved connectivity to existing and new green spaces and types of green facilities (e.g. play parks, SuDS) and the provision of new open space as part of development. ECC recognises the importance of ensuring that development contributes to improvements in green space based on community need.
ECC Response to Rochford New Local Plan: Spatial Options Consultation July 2021
Thank you for consulting Essex County Council (ECC) on the Rochford New Local Plan: Spatial Options Consultation (SOC) published in July 2021. ECC has engaged with Rochford District Council (RDC) in the preparation of the new Local Plan, and our involvement to date has been proportionate at this early stage of plan preparation, building on the Issues and Options consultation in 2017/18. Once prepared, the new Local Plan will include the required strategies, policies and site proposals to guide future planning across the District, and will replace the current suite of adopted Development Plans up to 2040.
ECC welcomes the opportunity to review and comment on the emerging new Local Plan vision, strategic priorities and objectives, initial growth scenarios, spatial options, thematic themes and ‘Planning for Complete Communities’. As Plan preparation continues, ECC is committed to working with RDC through regular and on-going focussed collaborative discussions to prepare evidence that ensures the preferred spatial strategy, policies and site allocations are sound, viable and deliverable, where future development is aligned to the provision of required local and strategic infrastructure.
A Local Plan can provide a platform from which to secure a sustainable economic, social and environmental future to the benefit of residents, businesses and visitors. A robust long-term strategy will provide a reliable basis on which RDC, ECC and its partners may plan and provide the services and required infrastructure for which they are responsible. To this end, ECC will use its best endeavours to assist on strategic and cross-boundary matters under the duty to cooperate (Duty), including engagement and co-operation with other organisations for which those issues may have relevance.
It is acknowledged that RDC has engaged ECC under the Duty, during the past year, in addition to the joint and regular meetings established with the South Essex authorities, through specific South Essex strategic planning duty to co-operate groups for Members and Officers respectively to explore strategic and cross boundary matters.
ECC interest in the Rochford New Local Plan – spatial options consultation
ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy for the existing and future population that lives, works, visits not only in Rochford District, but Essex as a whole. This includes a balance of land-uses to create great places for all communities, and businesses across all sectors; and that the developer funding for the required infrastructure is clear and explicit. As a result, ECC is keen to understand, inform, support and help refine the formulation of the development strategy and policies delivered by LPAs within and adjoining Essex. Involvement is necessary and beneficial because of ECC’s roles as:
a. the highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan; the lead authority for education including early years and childcare (EYCC), Special Education Needs and Disabilities, and Post 16 education; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on public health;
and adult social care in relation to the securing the right housing mix which takes account of the housing needs of older people and adults with disabilities;
b. an infrastructure funding partner, that seeks to ensure that development proposed is realistic and does not place an unnecessary (or unacceptable) cost burden on the public purse, and specifically ECC’s Capital Programme;
c. major provider and commissioner of a wide range of local government services throughout the county (and where potential cross boundary impacts need to be considered);
d. Advocate of the Essex Climate Action Commissioner’s (ECAC) Report 2021 Net Zero – Making Essex Carbon Neutral providing advice and recommendations for action on climate change mitigation and adaption including setting planning policies which minimise carbon. This work has been tailored for use in the county of Essex; and
e. involvement through the Association of South Essex Local Authorities (ASELA) and Opportunity South Essex Partnership (OSE), promoting economic development, regeneration, infrastructure delivery and new development throughout the County.
In accordance with the Duty, ECC will contribute cooperatively to the preparation of a new Rochford Local Plan, particularly within the following broad subject areas,
• Evidence base. Guidance with assembly and interpretation of the evidence base both for strategic/cross-boundary projects, for example, education provision and transport studies and modelling, and wider work across South Essex as part of the joint strategic plan.
• ECC assets and services. Where relevant, advice on the current status of assets and services and the likely impact and implications of proposals in the emerging Local Plan for the future operation and delivery of ECC services.
• Sub-regional and broader context. Assistance with identification of relevant information and its fit with broader strategic initiatives, and assessments of how emerging proposals for the District may impact on areas beyond and vice-versa.
• Policy development. Contributions on the relationship of the evidence base with the structure and content of emerging policies and proposals.
• Inter-relationship between Local Plans. Including the Essex Minerals Local Plan (2014) and the Essex and Southend-on-Sea Waste Local Plan (2017).
To achieve this, ECC seeks a formal structure for regular and ongoing engagement with RDC through the next stage of Plan preparation. Of critical importance is the additional evidence required for the site assessment process at both the individual and cumulative level to refine and develop the spatial strategy, which will be informed by the provision of sustainable and deliverable infrastructure and services at the right scale, location and time, for the existing and future residents of Rochford. There are also challenges arising from COVID-19 and how these can be addressed through the Local Plan and the future growth ambitions for London Southend Airport.
Key issues and messages of the ECC response
The ECC requirements are set within the context of national policy and ECC’s organisation plan proposals within “Everyone’s Essex” and commitments for “Renewal, Ambition and Equality” based on ECC’s strategies, policies, objectives and evidence base. The ECC response therefore identifies where we support emerging options and proposals, and where we recommend further work and engagement with ECC in order to refine and inform the “Preferred Options”, the next iteration of the local plan preparation, scheduled for consultation in Spring 2022. The key messages in ECC’s response are summarised below.
1. ECC support RDC preparing a new Local Plan and will assist with the preparation of sound evidence and policies, that plan for long term sustainable infrastructure delivery.
2. It is still too early for ECC to provide detailed comments on the impacts, opportunities and requirements for the full range of ECC infrastructure and services, and additional evidence is required on a range of matters to inform the selection of a preferred strategy and sites, together with supporting policies. It is acknowledged that ECC has engaged with RDC on the preparation of the transport evidence base to date, which has been proportionate to this stage of plan preparation.
3. The preferred strategy and site allocations will need to ensure that the requirements of ECC infrastructure and services are met to secure their sound, viable and sustainable delivery at the right scale, location and time, that is commensurate with housing needs and growth aspirations.
4. This will include engagement with preparing additional evidence, that will include, but is not limited to,
o Transportation modelling (including sustainable transport) to develop a strategy to realise modal shift including analysis of existing active and sustainable travel infrastructure (including bus network and services). In collaboration with ECC, it is recommended that RDC prepare a Local Cycling and Walking Infrastructure Plan (LCWIP).
o Scenario testing for education provision including early years and childcare and the approach to Special Education Needs with Disabilities provision.
o Minerals and waste policy compliant assessments.
o Flood and water management assessments through revised Critical Drainage Areas (CDAs) and revisions to the South Essex Water Management Action Plan.
o Economic need and employment evidence including an up to date Economic Development Needs Assessment to refine the level of economic growth to be planned for.
o ECC will also contribute to the evidence in respect of skills, Adult Social Care, Public Health, climate change, and green and blue infrastructure to that can deliver safer, greener, healthier communities.
o There is also benefit in undertaking a Health Impact Assessment to ensure health and wellbeing is comprehensively considered and integrated into the Local Plan, including a strategic health and wellbeing policy, an area where ECC can advise and assist, and one successfully implemented and included in other plans across Essex.
5. RDC will need to engage and work closely with ECC to inform site selection and the range of preferred sites both individually and cumulatively, having regard to the evidence.
6. Spatial Growth Scenarios – the preferred scenario should meet national policy to deliver housing and other growth requirements; climate change resilience and adaptation; and environmental aspirations of RDC. As a minimum, the standard methodology should be met and any buffer to drive local economic growth or address unmet need from elsewhere is supported but will need to be based on sound evidence.
7. Spatial Strategy Options – the spatial strategy option to proportionately spread growth across the district would not deliver the necessary scale of growth to secure the viable and sustainable delivery of local or strategic infrastructure and services (most notably a secondary school) and would not be supported. Based on the information presented in the SOC, a preferable option is likely to see a combination of the options presented resulting in urban intensification, a focus on main towns, and concentrated growth in one or more locations (resulting in a new neighbourhood the size of a larger village or small town). The option will need to be informed by the evidence base and further site assessments.
8. ECC will need to be involved in any cross boundary development proposals. To this end, Option 3a would need to be delivered in the longer term given current constraints of the strategic road network (Fairglen Interchange) and have regard to emerging proposals and aspirations arising in Basildon and Castle Point Boroughs; and Option 3b will require close and formal working arrangements with Southend-on-Sea Borough Council.
9. It is noted that several of ECC’s comments and observations made in response to the Issues and Options consultation from 2017/18 continue to apply, given the early stages of Plan preparation. We therefore reiterate where important our previous comments and additional points where this is necessary to do so.
The ECC response is set out in table from page 5 onwards and reflects the order of the SOC paper including responses to specific questions; the Integrated Impact Assessment; supporting Topic Papers; and Site Appraisal Paper.
[Due to tabular format of submission, please refer to attached documents for full submission]