4.4 Protection & Enhancement of Special Landscapes, Habitats & Species

Thank you for the consultation on the above document. At this stage we have outlined some general principles and key issues that we feel should be included and addressed in the Core Strategy.

I hope this information is of use to you. If you have any further queries, please do not hesitate to contact me.

Rochford District Council have recently commissioned Essex Ecology Services Ltd to conduct a limited review of Local Wildlife Sites in the District. When completed this survey will make recommendations for an updated list of Local Wildlife Sites to be given protection in the emerging LDF. The Council should be aware that this re-survey is limited in its remit, and that further potential Local Wildlife Sites may be identified in the future for inclusion in the LDF.

The RSPB supports the proposed Coastal Protection Belt strategy, we would however like to see it expanded upon to provide a commitment to enhancing these areas. As well as supporting a range of species, intertidal habitats provide green spaces for local communities and can alleviate coastal flood risk.

Section 1 Spatial Portrait

Page 2 Clause 1.7 Does not mention the supermarket now under construction at the Park School site.

Section 2 Spatial Vision

Clause 2.5 This appears to be at variance with proposals later in the document for large amounts of new residential development, which will of necessity mean releasing large areas of green space.

Clause 2.10 There is no evidence to support this assertion. Judging on past performance and lack of drive from the local P.C.T this can only be described as a "wish list" and cannot be substantiated by firm proposals

Section 3 Relationship of Documents

Clause 3.9 The key diagram forming part of this document is very difficult to follow due to the lack of easily identifiable features and has been the subject of adverse comment by members of the public who have seen it. It would benefit from the addition of main roads, the railway line etc.

It appears that the objective of avoiding duplication (3.10) has resulted in the proliferation of a multitude of documents at considerable cost in time and effort to the Council, which could be rendered obsolete overnight at the whim of Central Government.

Section 4 Core Strategy Issues

Clause 4.2.2 Policies SS1 and SS7 of the East of England Plan confirm the need to maintain the Green Belt boundary. However, the proposals later in the document to site a further 1800 dwellings in Rayleigh will require a relaxation and the use of areas of Green Belt.

Development in the Rawreth Lane area is already up to the Green belt boundary and there appears to be no other substantial areas identified in the town capable of absorbing this number of new dwellings.

Clause 4.2.6 and 4.2.7 The strategic buffer between Rayleigh and Rawreth would obviously be in Rawreth Parish and any further development in the area would, in fact, have to take place in the parish of Rawreth unless the boundaries are redrawn.

Clause 4.3.8 It needs to be emphasised that the country park is at the eastern boundary of the district.

Clause 4.4.5.iii States that the area is remote and undeveloped. This is not true of the area around Battlesbridge at the western boundary of the district

Clause 4.4.9 This does not appear to be included on the key diagram

Clause 4.4.14 Would it be appropriate to indicate which of these sites are open for public access?

Clause 4.5.4 Windfall sites should be taken into account since they contribute to a reduction in pressure on the Green Belt

Clause 4.5.5 Central Government has stated that Thames Gateway development will be housing led and it follows from this that it is not possible to rely on infrastructure improvements

Clause 4.5.6 This is a very laudable aim. However, a similar statement was removed from the Replacement Local Plan prior to adoption. It is considered essential to retain this.

Clause 4.5.9. It is true that the Council has no control over the total number of dwellings. However, the East of England Plan does not specify their distribution. This is something that the Council has complete control over and this should be made clear.

Clause 4.5.11 The second bullet point is not specific enough, densities should be set out in this document.

Clause 4.5.12. Windfall development should not be ignored.

Clause 4.6.3. Though these areas have a good range of services they are under extreme pressure and are not able to accommodate further increases in population without considerable upgrading.

Clause 4.6.4. These areas should be brought up to a standard which would make them suitable to take a fairer share of increased development.

Clause 4.6.9. It is incorrect to state that all settlements have had more than their fair share of housing .There is one area that has had more than any other:- WESTERN RAYLEIGH

Clause 4.6.10 It is considered that the allocation must take into account the fact that Rayleigh has taken the lions' share of development in the district to date.

It is unacceptable that the majority of the proposed future development should fall in Rayleigh. The split must be reviewed.

Clause 4.6.18. This is at variance with the fact that the A127 is not anymore considered by the Government to be the main road distributor for S.E.Essex. This is proven by the fact that the A13 is now the main trunk road connecting to London and the A127 has been demoted to a mere County route.

Clause 4.6.20 This is no worse than the daily congestion in Rawreth Lane which is due to get worse on completion of the ASDA superstore.

Clause 4.6.21 Mentions protection of Rochford's Conservation Area. There is no similar statement about Rayleigh's Conservation Area

Clause 4.6.23 Believe the figures are flawed and unbalanced

Clause 4.6.23 This statement needs to be far more robust with greater emphasis on transport infrastructure etc. improvements preceding housing development

Clause 4.7.10 Much affordable housing appears to be being purchased on a "buy to let" basis for profit. The policy needs to contain means for discouraging this practice.

Clause 4.8 Employment. For the forseeable future the main employment pattern is likely to be commuting to London. Until higher salary employment is the norm. in the district it will be difficult if not impossible to meet these targets.

Clause 4.9.9 Generally agree though 25% appears to be a rather low figure.

Clause 4.10.3. Corporate identities etc. have often in the past been used as excuses to ignore Conservation Area requirements, particularly with shop fronts and signage. This statement needs to be made more robust.

Clause 4.10.8. Should be reworded to contain specific reference to Conservation Areas

Clause 4.14.3. This is impractical:-Where hotels don't already exist in town centre locations there is not much possibility of hotel development due to lack of suitable sites

Section 5 Implementation & Monitoring

Clause 5.4 Rochford and Castle Point PCT no longer exists as a separate entity.
Also the steering group should include secular groups as well as faith groups eg: Essex Humanists (who are affiliated to The British Humanist Association)

Thank you for your letter dated 21 May 2007 consulting Natural England on the preferred options report.

This letter is provided as our formal response of Natural England to your request for advice for this plan or programme and is intended to be considered in conjunction with previous English Nature consultation advice provided for the emerging Strategic Environment Assessment.

Natural England notes the significance of the nature conservation assets within Rochford District Council. We believe these assets significantly contribute to the character of the district and provide vital ingredients to the quality of life it offers. Opportunities exist to further enhance these qualities through an appropriate integration of measures towards economic, social and environmental aspirations.

Natural England encourages local planning authorities to include policies for the protection and enhancement of the natural environment and natural resources. We are likely to e supportive of suitably worded policies that seek to conserve environmental assets such as biodiversity, water, energy, air quality and promote effective flood risk management, appropriate landscaping and pollution control.

Consistent with PPS9 and the accompanying ODPM Circular 06/2005 we advocate adopting an informed approach utilising information about biological and geological assets, from sources such as Phase I surveys, Country Wildlife Site inventory's and previous geological surveys (RIGS - regionally important geological sites). In our previous advice about the Strategic Environmental Assessment we have advised that in addition to designated sites, other areas (notably local wildlife sites, local nature reserves, green corridors) can make a significant contribution to the green infrastructure of the district. Accounting for this, and the challenges of enabling progress towards growth targets we refer you to the following points for consideration:

i) Developing within the urban area is likely to involve development on brownfield land, which can be rich in biodiversity interest
ii) Different types of land may have strategic significance for the conservation of biodiversity assets.
iii) In some locations, the green belt can provide a significant buffer (and in some cases supporting habitat) for sites of national and international significance and opportunities may exist through landscape enhancement schemes for these areas to provide a more multifunctional accessible natural greenspace role.
iv) The requirements of the Habitat Regulations should be considered particularly if options for development are within or adjacent to intertidal areas.
v) The plan needs to account for environmental issues that span local authority boundaries. This is significant, noting Southend-on-Sea Borough Council's growth targets.

1. Assessment in accordance with Habitat Regulations

Where a plan may affect a European site, the European Court of Justice ruling (October 2005), has concluded Article 6(3) of the Habitats Directive provides that any plan or project not directly connected with or necessary to the management of a European site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, must be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In practice, the SEA should aim to be sufficiently detailed in its assessment to address the requirements of The Habitats Directive 92/43/EEC of 21 May 1992.

The Assessment will require an initial screening of all policies alone and in combination with other plans and projects. This aims to establish whether any policies should be regarded as likely to cause/have a significant effect on the interest features of the European Sites, either alone or in combination with other plans or projects. Options should then be considered to establish whether amendments to individual policies, suite of policies or supporting text could effectively address concerns to 'not likely significant effect'.

Those policies that are still regarded as likely to have a significant effect will then require an appropriate assessment in accordance with Regulation 48 of the Habitat Regulations. National Government direction encourages local planning authorities to develop local development documents that clearly demonstrate that they avoid an adverse affect on the integrity of the Natura 2000 sites, either alone or in combination with other plans or projects. A summary diagram (Figure 1) of the processes within the assessment is attached for your consideration. Furthermore, consistent with the cross-border working that is necessary in delivering strategic solutions we recommend you gain a brief appreciation of the assessment from the developing Habitat Regulations Assessment for Southend on Sea Borough Council's Core Strategy (see Topic Papers for Examination in Public www.southend.gov.uk).

Our initial assessment indicates that the particular elements of the strategic direction could be likely to have a significant effect, either alone or in combination with other plans or projects and these are listed below:

1) Overall grown targets, alone and in combination with relevant Regional growth area targets, will lead to increased population and subsequent increased recreational pressure on Natura 2000 sites.

ii) The aspirations for significant growth in airport movements at Southend Airport, which may result in increased air quality and/or disturbance impacts on Natura 2000 sites.

iii) Development in, or immediately adjacent to, intertidal or coastal areas that either requires land-take through encroachment or exacerbates the effects of coastal squeeze.

2. Additional Advice

2a) Consistent with the point (ii) raised above, Natural England welcomes the proposed Joint Area Action plans for Southend Airport and Foulness MOD land. We recommended that the latter should include surface access. The Joint Area Action Planning process should provide opportunities for enhanced North-South links including greenways, as envisaged in the Thames Gateway South Essex Greengrid.

2b) Natural England supports the Council's preferred options for the enhancement and protection of the Upper Roach Valley including the Country Park. These are consistent with the objectives of the Thames Gateway South Essex Greengrid and it is recommended that wording to that effect should be included in the document. Natural England would be happy to advise with regard to a possible overall Upper Roach Valley Strategy as a means to delivering it's full potential.

2c) The Plan needs to align with the direction provided by PPS9 to conserve and enhance designated sites and biodiversity assets rather than merely to 'protect'.

2d) Consistent with the advice provided in paragraph 5 above we recommend that the environmental baseline is updated through a County wildlife site review and Phase 1 survey.

2e) Natural England encourages Rochford District Council to align with emerging strategic direction to address flood risk management. This includes principles set out in the Crouch and Roach Estuaries Strategy, the Essex ChaMP, the Great Wakering Flood Risk Management Strategy and the emerging Thames Estuary 2100 project.

2f) We encourage Rochford District Council to include specific measures and policy direction to promote the integration of biodiversity into development. This can be through a package of measures, outlined in the CD-Rom resource 'Integrating Biodiversity into development .....realising the benefits' available from www.essexbiodiversity.org.uk.

2g) Natural England supports the Council's strong promotion of good design with regard to new developments via the Essex Design Guide and Urban Place Supplement. Opportunities should be sought to promote accessible natural greenspace provision that meets local requirements and provides functional links for people and wildlife. Where possible these should also enable contributions to BAP targets. Natural England recommends that the authority should consider the use of policies to promote the delivery and long-term management and maintenance of greenspace and green linkages. These could be financed through planning gain/section 106 and would further encourage innovative and high quality design in new developments and regeneration initiatives.

2h) Rochford District Council's Option regarding leisure and tourism is consistent with the objectives of the Thames Gateway South Essex Greengrid and it is recommended that wording to that effect should be included in the document.

I trust that this is helpful, but please do not hesitate to contact me at the above Colchester address or telephone number should you wish to discuss this matter further. For further advice regarding greenspace/openspace strategy and implementation of the Thames Gateway South Essex Greengrid, please contact my colleague Pat Crosby (E-mail: partricia.Crosby@naturalengland.org.uk).

Hawkwell is a small rural village which could not easily support a largish settlement of houses. It has very little industry and most new residents would need to commute to London to work, not a desirable option, especially as the trains are already overcrowded at peak times. Hawkwell also has a poor bus service. The village currently has a pleasant environment despite its lack of public spaces and amenities. We do not see how more industry could be provided without losing more of our valuable open spaces. If housing estates are built, even more land will go and this would be environmentally damaging to our wild life, already endangered.

We are disappointed we did not have the opportunity to attend the meeting concerning the Core Strategy which was held at the village hall on 31 May. We understand this was poorly attended due to the poor advertising of this important event. please ensure we are placed on your mailing list so that we can attend the next meeting scheduled for this autumn.

These simplified responses will tend to refer to areas of concern rather than items such as the proposals for the extension of protection of the Roach Valley and the Cherry Orchard Jubilee Park, which the Parish Council welcome and support.


Spatial Vision

* 2.6 The PC sees the delivery of mixed dwelling types and affordable accommodation as essential, as through its planning comments it has repeatedly expressed concern over the loss of mixed accommodation within Hockley.
* 2.8 Given progress to date there is serious concern as to whether completion at the airport will be achieved within the next five years.
* 2.24 Again given progress to date there is concern that should be made an absolute priority.


Core Strategy Issues

* 4.2.6 The PC would wish to know whether sites such as Pond Chase Nurseries, or other sites in and around Hockley, would come in this category.
* 4.3.3 Will RDC increase spending and man power to achieve this?
* 4.4.9 The PC would remind RDC of recent efforts to get the very important historical area around the parish church of SS Peter and Paul included in an appropriate protection designation.
* 4.5.4 The PC continues to be concerned over the effect of infilling, Particularly "windfall Sites". on the infrastructure.
* 4.5.6 Again, would this affect sites such as Pond Chase Nurseries?
* 4.5.8 Logically Infrastructure and services should be in place before development to avoid strain or disruption on those existing.
* 4.5.10 The PC would wish to be advised of any such proposals for Hockley.
* 4.6.23 There is indeed a current need to improve public transport, particularly busses. Over the years the PC has received requests for the extension of a bus service, at least to Apex corner in Plumberow Avenue.

Affordable Housing

* As a general comment the PC considers this the highest priority. It is also concerned that infilling will contribute little to this. The authorities views on this would be welcomed.


Employment

* Again a general comment. It is to be hoped that the authority is working closely and directly with local school and not just the County Authority.




Good design and Design Statements

* The PC's Planning Committee has been seriously concerned over the contrasting quality of many single and small developments in Hockley. Of particular concern has been the very poor design of many rooms in the roof. The PC welcomes clear and enforceable policies that require a high standard of good design.
* Irrespective of any listing the PC would wish the authority to have regard for the preservation of buildings of quality, historic interest and character when considering redevelopment. ( For example the old doctor's ouse, Southend Road, now demolished.)

Community, Leisure & Tourism Facilities

* There is an urgent need for improvements to youth facilities, particularly unstructured leisure.

On Behalf of The Hockley Parish Council
Cllr R Vingoe.

On behalf of Aston Unit Trust and Mr J Needs, I enclose representations in respect of the Rochford Core Strategy Preferred Options.

As you will be aware from previous correspondence, my clients have a particular interest in land at Wellington Road, Rayleigh. Should you require any further information on this particular site or this batch of representations, please do not hesitate to contact me.