Protection and Enchancement of the Natural Landscape and Habitats

agree

Please note that Brownfield sites which the core strategy is encouraging to be developed often are more biodiverse than for instance green belt! In effect the core strategy is potentially breaking this commitment statement!

Response to Core Strategy - Local Government Framework Oct 2008-12-24

Thank you for opportunity to comment on the above and I make the following objections.

HOUSING

I object to proposals in Preferred Options under this heading in following 10 paras.

Numbers. I object to ordained housing numbers. Up to 2025, East of England Plan requires 5,600 minimum, of which, after actual and projected completions, gives remainder of 4,700, based on current need - adult children wanting to leave home, break-up of relationships, population projected increase from 78,489 to 87,000 by 2020s. This is largely supposition. Even the original remainder of 3,500 to 2021 after projected completions is too many. Notional redistribution of numbers around District centres following last Core Strategy consultation is fruitless when one studies the map showing areas excluded from development due to: flood plain, SSIs, conservation etc which comprise the bulk of the District. The built area plus projected green belt release won't sustain it. Don't forget, based on history, post 2025 Government will require ever more notional numbers accommodated.

Population. Planning Services express fear of continued out-migration due to housing shortage. In fact much known such migration is caused precisely by over-development, families looking to move to roomier, less claustrophobic environments. It will be necessary to discourage inward migration by persuading other Local Authorities to make improvements to education etc.

Much is made of the old causing a housing problem. This is skewed logic. The under 20 age group will not fall. The Office of National Statistics has reported a further baby boom commenced 2001 - an increase. The over 65 population will increase solely because the ageing earlier baby boom generation mostly under that age now will join them, but that doesn't increase population. The 24 to 64 age group will lose at the top and gain at the bottom.

In this connection complaint is made of the old hanging onto houses instead of down-sizing to so-called sheltered housing and allied ghettoes. If over-65s are found a problem, Third Reich had a solution that should appeal to EEDA: they could set up termination camps, with double benefit: get rid of them and clear their homes for redevelopment.

It should be pointed out much over-large new build market housing is for upwardly mobile, but middle and old aged persons from elsewhere, whose children have left home. An estate of 5 such units houses 10 persons. Some mansions are built or bought purposely for one person.

Distribution/General locations. I appreciate new concern with 'town cramming' and note view that Government target of 60% on 'brownfield' land is unrealistic (that damage already done) and that you propose much less. If this can be done with one Government target, why not cut down others?

I regret, however, that the newly restrictive approach against town cramming does not apply to 'windfall' development - very much of that has been done - over-dense, out of scale with existing dwellings, particularly in Hockley.

In this respect I'm sceptical of your new good intentions, as revised Urban Capacity Study 2007 notes 'intensification of existing residential land has made significantly larger contribution to housing figures than other forms of development..'.

Presumably the proposals listed under H2 and H3 are based on the 'call for sites' letter 2007 and have been offered by developers. The total for south Hawkwell of 350 to 2025 is over the top in relation to impact and land availability. It is bounded by over-busy B1013, former country lane. New roads required for it will mean compulsory purchase and some green belt residents will have to go.

Hockley seems unusually favoured with 50 units, but only as officials know well that windfall development will continue without restriction, as in the past, so no need to overdo target.

Core Strategy Preferred Options is a blank cheque, exact locations to be given in later allocations document.

AFFORDABLE HOUSING

I object to outlined proposals as follows. The noted dire shortage, with waiting list of young looking to leave home, etc, has resulted from shed loads of council housing having been sold off under the Thatcher Government in 1980s, or you would not need this genre. Council housing was meant for two sections: first those who would never be able to afford a mortgage and should not be pressured to do so; secondly, first-timers who could not initially afford ownership, but with aid of cheap rent could save over time for a deposit on their own place.

CHARACTER OF PLACE AND DWELLING TYPES

I object to proposals for reasons in following 7 paras.

Traditional. It is noted that the District 'has character, appearance, much of which stems from traditional buildings that still dominate towns and villages'. Unfortunately, as I noted under housing, much of that has been eliminated, many remaining dwellings now threatened with same, as Locally Listed buildings and their environs have gone, especially in Hockley, though Rochford, Rayleigh, small settlements have been reasonably well spared in this respect.

Intensification. Rochford District recognises defects of intensification of residential areas and proposes limiting redevelopment not in keeping with density and character of the area. But failure to clarify that those terms both mean not only destruction of heritage, but replacement with edifices out of scale in bulk, area, height, will lead to jeopardy of existing homes. Some new build may be out of character, but might be acceptable if not out of scale. Planning Services have been known to decide planned over-large buildings comply with density - they might do numerically, but are over-dense proportionally.

Strategic Housing Market Assessment is happy for market housing to be out of scale with existing: '...recommends Local Authorities don't set rigid requirements for size of dwellings, particularly...market housing, market is adept at matching dwelling size to market demand at local level'. Precisely. The upwardly mobile private sector have no regard for others and want multi-bedroomed dwellings massively out of scale with neighbours (who are often unfortunate to be north of them) plus all sorts of intrusive security systems to match. This should be resisted.

Planning Policy Statement 3 states: 'Design which is inappropriate in its context and which fails to take opportunity for character and quality of area should not be accepted. Development which is not inclusive and does not fit with surroundings..'. This is just what the typical 'executive' house, in gated site, 'town' house (also 3 storey where locale is 2 storey), flats etc, encouraged for Hockley has done. So clearly Government dictate has not been followed in this regard.

Character of place. Much has been made of the idea that, unlike Rochford, Rayleigh, the small settlements, Hockley village is not where once sited - around Hockley Church a 12C Listed building, but is a construct arising with the railway in 1887, all growth haphazard and dated subsequently, having no heritage value. This is inaccurate.

The road from Rayleigh to Rochford, via Hockley was a country lane. What is now B1013 was made a toll road in 18C for coaches, which is why it by-passed the church. To my certain recollection a dozen period houses, as good or better than Rochford's, from Marigold Corner (Hawkwell end of Hockley hill) to the Spa Hotel, dating 17C to 19C, have been destroyed since c.1975 for redevelopment.

4 Tiers. Core Strategy proposes dividing District settlements into 4 tiers of graded sustainability for more housing, those in the 4th tier being thought unsuitable. No wonder such places as Paglesham, Foulness, Stambridge have closed schools, churches, for lack of people.

MATERIALS

My objections here should be included in those under Character of Place. Core Strategy notes 'modern standardised building materials and design have begun to erode character of the District'. That is very true: there is a new element of hard sell by contractors, who want to replace traditional work, materials, with eg. Plastics, spray paint, steel. Personally, to avoid this I have had to engage a contractor specializing in heritage work to do standard painting, repair of external cast iron, timber work. Formerly, any general building would have done the work required as asked without argument.

It is a joke that design is expected to be sympathetic to locale and in-house building styles to fit local setting, not other way round. It is too late. Developers have strived to spoil local setting precisely to jeopardise existing housing, so it can be acquired for redevelopment.

LOCAL LIST

I list my objections to proposals for preferred options under this heading in following 6 paras.

I note Rochford District Council dropped Local List just prior to enabling demolition of Black's Farm (1 Southend Road), which was on that list, a house and garden that certainly conformed to 'local distinctiveness and [central to] a cherished and local scene' in Hockley.

The List was ostensibly dropped as, so a former Planning policy Manager said, 'Government frowns on such Lists'. Other councils, unaware of that, retained theirs. His comment to an Inspector on objection to proposed flats redevelopment of 1 Southend Road 'Just politics, lot of local interest, nothing of character in that area', presumably presaging his plans for the area. He also remarked on intended replacement 'flats sell well' - not a planning consideration. Surprise, surprise! As soon as the item was successfully demolished, we learned more recent Government guidance encouraged Local Lists! 'There is now positive encouragement from Government in recent White Paper for such Lists and we propose to reintroduce one for the District'. How disingenuous can you get.?. Were they holding it back, then?

It seems to me where Hockley is concerned notional land values for developers are more important than anything standing on it. In fact a former councillor once said exactly that.

An adviser proposed an Article 4 Direction be served for 1 Southend Road (an embargo on demolition while listing is considered. If it fails, compensation may be payable to the developer by council). The council refused because of that risk. English Heritage, well documented, as also Dept. of Culture, didn't visit, but left the matter to Essex County Council heritage department, who were inevitably not interested from scratch. After all was too late, English Heritage even advised another time one should get a period building under threat put on the Local List! Meanwhile in the time when 3 Hockley period houses were demolished for redevelopment, including No1, there was sickening sight of several Rochford buildings under repair 'sponsored by English Heritage' and other funded organisations. In Rayleigh large sums of public money, including from Thames Gateway, Lottery, were spent on schemes such as the Mill. And to think the council begrudged an unlikely financial risk in respect of Article 4 on 1 Southend Road Hockley.

I insist that a draft Local List be issued for consultation for ALL residents, which right to propose or refuse what goes on it. If, as suggested in earlier Strategy document, new development is to be included, then all adjacent properties are to be included as a conservation area.

Heritage, etc, Award by RDC. In view of all the above, there is hypocrisy in this scheme for heritage style redevelopment. Period houses now demolished, are replaced with out of scale pseudo-period redevelopment, particularly, as a planner said, on 'important, significant hill top, hillside sites' (money) such as Etheldore Avenue and Southend Road. These are of doubtful marketability, but this award is a pretence of concern with heritage to hide the real facts.

INFRASTRUCTURE AND TRANSPORT

I list objections to proposals under this heading in following 5 paras.

Standard Charges. Though I welcome proposals at CLT 1 for developers to pay towards the problems caused by their plans, it is a pity these are not to be set at a realistically punitive level to discourage them from excessive schemes. It has been suggested if a developer won't provide required infrastructure, opportunity will be given to another who will. But what if first developer already owns the site council is keen to see developed? Also, there is still a risk that retention of S.106 Planning Agreements will cause developers to buy Consents they might not otherwise get.

South Hawkwell building proposal. Re H2 alternative options, namely N E Hockley thought unviable for development due to impact on highway network of traffic heading through/out of Hockley to Ashingdon, but development south of Hawkwell found better placed in relation to highway network and employment growth at Southend Airport - this is grossly illogical.

I certainly don't support further development for N E Hockley. It is already burdened by Etheldore/Wood Avenue, Broadlands estate and much new else, and appreciate Greensward traffic, though less than main roads, does meet extra traffic traversing Lower Road. But to suggest that B1013 through Hockley and Hawkwell, busiest B road in UK, carrying 2000/hour quiet times, gridlock at peak times, now threatened by vast economic expansion proposal at the airport, is a suitable venue for 330 extra dwellings in south Hawkwell is ludicrous. Since opening of Cherry Orchard Bypass, all area traffic has been directed through Hockley and Hawkwell to Southend on B1013. B1013 (like the above roads) is a winding country lane. It has been hinted there will be new roads - where, and will this also involve compulsory purchase?

Highway improvements. I note these are under consideration to serve new developments, particularly to cast-west routes. Please do not subject home owners along B1013 winding lane to compulsory purchase of frontages to effect highway efficiency. This was done to owners on both sides of that road along Southend Road on Hockley hill in the 1960s. Apart from loss, speeds increased, accidents occurred and owners have had on-going problems. Any more and owners would lose homes as well.

Public transport improvements. Presumably as Standard Charges, are envisaged for new development at H Appendix 1 and CLT1. You need to watch crafty manoeuvres by services to get more money this way. For example, it is not coincidence that, since the revised Core Strategy consultation, with proposed large developments for Hawkwell, Ashingdon, Rochford was issued, Arriva bus company propose cutting back further their already abysmally poor Nos 7 and 8 services, presumably as ploy to get more money to reinstate them. Don't forget also that, unlike eg a community centre, classroom etc once provided a bus service is on-going. What happens to bus service when the builder has made his profit and moved on?

RETAIL AND TOWN CENTRES

I list my objections to proposals in Core Strategy under this heading in following 5 paras.

'2008 Retail/Leisure Study shows significant leakage out of the District...[should] direct retail development to town centres: Rayleigh/Rochford/Hockley'. You should understand Hockley has always been a village, traditionally having staple day-to-day shopping needs, eg grocers, butchers, bakers, fishmongers, greengrocers, haberdashers, hardware, newsagents, pharmacy, shoemenders, post office, building society or bank. Hawkwell also has a small shop parade with similar basics. At most, a modest extra supermarket might be set in the industrial estate in Eldon Way.

Regrettably, several prime Hockley units have become occupied by numerous estate agents. These should be reduced to two. An instructive example follows: in late 1980s, with already 6 agents, owner of one unit wanted change of use to estate agent. Planning Services refused on grounds it would be one too many. He appealed and won. In 1990 recession he closed, as did all the rest bar two, proving for once planners were right. A number of trivia shops have also arisen, which last a short time.

Residents have always expected to travel to Southend for furniture, clothing, large DIY stores other than hardware, bathrooms etc. This is NOT going to change. Any attempts have failed.

You need to understand there won't be any 'national multiples' in Hockley. Presumably Eldon Way industrial estate was considered a possible venue. The crowds and traffic would build up further in Spa Road, already a bottleneck. Remember your point that further housing for NE Hockley would increase traffic impact passing through Hockley. Also how would this fit with possible plans for extra housing in Eldon Way?

I have heard central Hockley central area might be regenerated. That will be resisted; there must be no demolition or compulsory purchase here, where there are listed and period buildings, too many of latter have been destroyed in Hockley already, intentionally to change its character.

There is also no space for large multiple stores in either Rayleigh or Rochford, which would be damaged. Southend High Street and Hamlet Court Road are ideal for large scale shopping.

ECONOMIC DEVELOPMENT AND EMPLOYMENT GROWTH

I object to proposals in Core Strategy preferred options as follows. 'East of England Plan specifies the number of jobs any sub-region must provide'. Apart from the airport, Rochford District is not within Thames Gateway and EEDA are not qualified to dictate 3000 jobs must be found. EEDA's idea the airport will generate large employment is unrealistic - jobs from this will be temporary.

Many attempts have been made to 'reduce reliance on out-commuting' without success. Vide the empty office blocks in Southend once occupied by eg Willis Faber, C E Heath & Co., Prudential, CU - all now elsewhere. You cannot replicate London employment in Rochford.

EDUCATION

I understood 'new residential development' was for extension of existing population, not meant to 'result in more people living in the District' already overcrowded. I'm surprised Hockley isn't expected to generate additional educational needs. I conclude the new upwardly mobile moving to executive mansions from elsewhere get their young tutored at private prep schools in Southend to pass the 11+ and get into Southend grammar schools. It should be noted parents have for years had a problem getting their children into any of the 3 overcrowded primary schools.

HEALTHCARE

It seems appropriate to propose under CLT4 that 'new developments be accompanied by a Health Impact Assessment... and developers be required to address negative effects prior to development implementation'.

Having, with other existing neighbours, experienced deafening noise 7am to 7pm 7 days per week for several years, polluting and furnace heating fires, daylight denying and night dark removing huge edifices in course of adjacent development, there is a definite impact on health by development.

PLAY SPACE

I object to preferred options proposals under this heading for following reasons. I thought Strategy said RDC would be abolishing practice of removing homes and gardens to get greater density. Gardens for children are essential. Even if out of sight, they are within earshot of adults. I note couples with small children are usually keen to have a place with garden. Communal play space advocated under CLT7 means children must be escorted. There is one on Hawkwell green, adults not permitted to enter.

AGEING POPULATION

I object to preferred options comments here. Core Strategy is obsessed with this. It is nonsense that ageing population leads to a smaller workforce with higher dependency ratio. Many persons of retirement age forced out of jobs by the baby boom continue to earn a living if allowed to do so, well beyond retirement.

Final insult under Youth Facilities '...ageing population (which could lead to increased demand for health and social care, rather than services for youth) it is important....needs of young people...catered for..'. The old, as well as striving to keep economically sound, also take steps to remain healthy and so are no more a burden to NHS and social services than younger groups.

As I said under Housing, if you feel the old are in the way in various ways, EEDA could clear them with termination camps.

PROTECTION, ENHANCEMENT OF LANDSCAPE AND HABITATS

I object that landscape and gardens in built area gardens have been excluded.

This is laudable, but it should be noted that landscape and habitat are also found in local gardens. Any wild life if found in same would need protection - definitely not translocation as at Etheldore Avenue etc, with unfortunate results. Developers have been known to drive protected wildlife out ahead of building and Rochford Woodland office to designate flourishing hedgerows 'dying, diseased'. So I object to landscape and habitats in gardens, built area being omitted from preferred options here.

CONCLUSION

I appreciate all this sounds negative, but development and inward migration ideas are out of hand.

Greenbelt. The perceived need to release some and recognition that existing settlements have increasingly limited space for further development clarifies that further government/developer demands must now be resisted. S E Essex is overcrowded and too small for further incursion.

Flood risk. Practically all Thames Gateway is a flood basin. From RDC map, most of the District is either at flood risk from N. Sea, rivers Crouch, Roach or else enjoys special protection. Permeable pavement is a good idea to stop surface flooding from paved residential frontages (now needing planning permission), but another problem is the many drainage ditches that have been filled in in residential and other areas.

Car dependency and congestion will continue with any population growth.

Energy consumption. Small wind turbines don't produce relevant energy. Most homes don't have cavity walls (doubtless an excuse for demolition as not sustainable).

In sum, I object to Core Strategy preferred options as further extensive development in Rochford District cannot be contained.

Revised Core Strategy Preferred Options Consultation

Thank you for consulting Natural England on the above, in your letter received by this office by email on 5 November 2008. We refer you to previous comments made in our letter of 27 June 2007 during the initial preferred options consultation. Whilst we are generally supportive of the plan, we would like to make the following comments.

Evidence Base
Natural England is pleased to note that the Essex Landscape Character Assessment (2003) and the Local Wildlife Site Review (2007) has been included under this heading.

Vision
Natural England supports the vision because it sets out the intention to retain the essential landscape characteristics of the district and the distinctiveness of both the natural and built environment. These are aspects which are compatible with our own objectives. We also support the recognition of the District's position within Thames Gateway South Essex to promote the District as the "green part" of the sub region.

Objectives
Whilst Natural England generally supports the objectives we would liked to have seen specific reference to "landscape" within the fourth bullet point. We also consider that there should be a stronger reference to climate change within the objectives, linked particularly to the transport objective (6th bullet point) by referring to the need to reduce carbon emissions. An additional objective should also be included on the issue of renewable energy and climate change, for example "to promote renewable energy and address the causes and potential impacts of climate change"

The Green Belt

GB2 Rural Diversification and Recreational Uses - Preferred Option
Natural England supports the Council's preferred option on this issue. We have recently assessed the case for a review of green belt policy where the role of the green belt is reconsidered. The value of the green belt should be judged on its contribution to quality of life, nature conservation, landscape protection, flood mitigation and the impact of a changing climate. Linked with this is a desire to improve the environmental quality of existing green belt. We would therefore support rural diversification within the green belt such as green tourism and outdoor recreation, provided these activities are linked with environmental enhancements and an increase in biodiversity.



Economic Development

ED1 London Southend Airport - Preferred Option
Natural England reiterate our previous comments on the London Southend Airport, that is we are concerned with the impact of the growth in the airport on air quality and on the disturbance of Natura 2000 sites. We also would actively encourage enhanced North South links including greenways, as envisaged in the Thames Gateway South Essex Greengrid

Environmental issues

Crouch and Roach Estuary Management Plan (Page 52, 4th paragraph)
In this paragraph a list of stakeholders is given who are working with Rochford District Council on the above plan. Natural England should also be actively involved in this project and listed accordingly.

All references to 'English Nature' should be changed to read 'Natural England', e.g. page 52, 1st paragraph.

ENV1 Protection and Enhancement of the Natural Landscape and Habitats - Preferred Option
Natural England supports the overall aims of the preferred option and we are pleased to note that the wording now includes "maintain, restore and enhance" rather than just protect. However we consider that the policy does not fully cover all aspects of the natural environment but concentrates on the protection and enhancement of designated sites. We therefore suggest that the policy is expanded to include the following points:

i. Wildlife Networks- Natural England would like the policy wording to encourage an approach to conservation management which is focussed not solely on individual site protection but which seeks to rebuild the fabric of the landscape in which individual sites sit. Actions such as reducing habitat fragmentation and creating green corridors for wildlife can help to achieve this. PPS9 states specifically at paragraph 12 that "Local authorities should aim to maintain networks by avoiding or repairing the fragmentation and isolation of natural habitats through policies in plans." This policy could link to a wider policy on Green Infrastructure. We would therefore suggest that the following point is added to the policy wording: "The Council will ensure the protection and enhancement of a network of local wildlife sites and wildlife corridors, links and stepping stones between areas of natural green space to avoid fragmentation of habitats".

ii. Designing in Wildlife - We would recommend the inclusion of designing in biodiversity measures within this policy. By incorporating ecologically sensitive design and features for biodiversity early on within a development scheme, significant improvements for biodiversity can be achieved, along with easier integration with wider environmental, design and planning aspects. For example designing for biodiversity can include the retention of sensitive or valuable habitats present, or enhancements for protected species that may be present, whilst integrating other development design requirements such as drainage and engineering. By addressing ecological aspects early on, design aspects such as site layout can be tailored to provide enhancements and improvements for biodiversity that may not be possible later on within the design process. Measures to encourage biodiversity can include green roofs, planting and landscaping using native species, setting up bird and bat boxes and sustainable urban drainage systems. We would suggest that the following point is added to the policy wording: "The Council will ensure development seeks to produce a net gain in biodiversity by designing in wildlife, and ensuring any unavoidable impacts are appropriately mitigated for."

iii. BAP Targets - We would suggest that this policy is linked to the Essex Biodiversity Strategy (1999) which has established targets to boost priority habitats and targets. The policy should therefore include the additional wording: "The Council will promote wildlife enhancements which will contribute to the habitat and species restoration targets set out in the Essex Biodiversity Strategy."

iv. Landscape Character - In addition this policy, although it mentions "natural landscape" in the title does not fully cover the protection and enhancement of landscape character and quality. The Landscape Character Assessment of Essex (2002) should be specifically mentioned in the policy wording. LCAs are a tool to understand the intrinsic character of the landscape and direct appropriate sustainable development and should be used as part of the evidence base to underpin planning and management decisions in the preparation of the LDF. We therefore suggest the insertion of wording which seeks to achieve the following: "The landscape character and local distinctiveness of the District will be protected, conserved and where possible enhanced. Proposals for development will take into account the local distinctiveness and sensitivity to change of distinctive landscape character types. These landscape character types are described in the Essex Landscape Character Assessment"

ENV2 Coastal Protection Belt - Preferred Option
Whilst Natural England generally supports the aims of the preferred option and agrees with the overall approach of protecting the open character of the undeveloped coast and its important wildlife sites, we suggest that this policy should give explicit recognition to the implications of climate change and sea level rise, and the need for necessary adaptation. The current draft appears to defend a 'static' situation. We also draw your attention to policy SS9 of the East of England Plan, which states that LDDs should (inter alia):
• protect important coastal environmental assets, if practicable and sustainable without causing adverse impacts elsewhere. If it is not practicable to protect sites and habitats in situ, including sites of European or international importance for wildlife, shoreline management plans and development plans should include proposals for their long-term replacement and the recording of any lost historic assets;
investigate and pursue opportunities for the creation of new coastal habitats, such as salt marsh and mudflat, in areas identified for managed realignment. New development should not be permitted in such areas.

ENV4 Sustainable Urban Drainage Systems (SUDS) - Preferred Option
Natural England agrees that Sustainable Urban Drainage Systems (SUDs) should be encouraged within new developments as part of sustainable design. SUDS can be used to provide open space and wildlife habitats around areas of vegetation, water channels and storage ponds which are positive steps to increasing biodiversity.

ENV6 Large Scale Renewable Energy Projects - Preferred Option
Natural England agrees that large scale projects should only be considered where there is no significant adverse affect on the landscape or wildlife. We would also recommend that when considering locations for renewable energy installations that the Essex Landscape Character Assessment should be referred to. This will help to ensure that installations are located in places which will cause minimum impact on the surrounding landscape.

Notwithstanding the above, and the current policy wording to protect site integrity, we highlight to the Council the supplement to PPS1: Planning and Climate Change, which requires that: "19. In developing their core strategy and supporting local development documents, planning authorities should provide a framework that promotes and encourages renewable and low carbon energy generation. Policies should be designed to promote and not restrict renewable and low-carbon energy and supporting infrastructure."
And
"20. In particular, planning authorities should:.......
ensure any local approach to protecting landscape and townscape is consistent with PPS22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances"
Natural England therefore comments that an appropriate balance needs to be struck between site protection and the promotion of renewable and low-carbon energy generation projects. We also suggest that a fuller criteria-based policy is included in the Development Control Policies DPD.

ENV7 Small Scale Renewable Energy projects - Preferred Option
We are supportive of small scale energy projects as part of sustainable design and construction.


ENV8 Code for Sustainable Homes - Preferred Option
Natural England supports the preferred option as it is compatible with our own promotion of sustainable design and construction including energy efficiency in homes. We would draw the Council's attention to our project "A New Vernacular for the Countryside" which addresses broad sustainable design and construction principles for the countryside.

Transport

T5 Cycling and Walking - Preferred Option
Natural England supports the preferred option. Footpaths and cycleways should be provided as part of new development layouts which will contribute to sustainable transport and also provide informal recreation opportunities to help improve the health and well-being of residents.

T6 Greenways - Preferred Option
Natural England is supportive of the Thames Gateway Green Grid Strategy and would see the provision of greenways as a contribution to a wider network of green infrastructure. We therefore welcome this commitment to the implementation

Character of Place

CP1 Design - Preferred Option
Natural England supports this preferred option and acknowledges the importance of setting high standards of design in all new development. We would like to ensure that development is "good enough to approve", accessible to all, locally distinctive and makes a positive contribution to the character of the area, utilising the opportunities presented by the location. In particular we are glad to note that Village Design Statements have been included in the policy wording as this is an initiative which Natural England actively promotes.

In our previous comments on this issue we also made the point that opportunities should be sought to promote accessible greenspace provision that meets local requirements and provides functional links for people and wildlife. We recommended that the authority should consider the use of policies to promote the delivery and long-term management and maintenance of greenspace and green linkages.

Community Infrastructure, Leisure and Tourism

CLT1 Planning Obligations and Standard Charges - Preferred Option
Natural England would suggest that countryside recreation projects including the management and maintenance of greenspace, wildlife sites and environmental improvements should be included in the list of activities that planning obligations and charges could contribute to.

CLT5 Opens Space - Preferred Option
Whilst Natural England supports the preferred option we consider that it should be expanded in greater detail. We would like the point emphasised that all development should incorporate sufficient new green space in accordance with Natural England's Natural Green Space Standards of achieving natural greenspace within 300m of every home.

The policy should also emphasise how open spaces and green areas could be improved and enhanced and linked to a wider network of open spaces, footpaths, amenity areas, river corridors i.e. Green Infrastructure. Wherever possible opportunities should be taken to improve the biodiversity and amenity value of these areas by suitable planting with native species or improved management regimes. It may also be possible to introduce footpaths or cycleways through these areas which would increase the provision of informal recreation and contribute to sustainable transport measures.

CT11 Tourism - Preferred Option
Natural England supports the preferred option particularly the proviso that green tourism projects should not adversely impact on character of place or biodiversity. We would reiterate our previous comments that it should be mentioned in the policy wording that this approach is consistent with the objectives of the Thames Gateway South Essex Greengrid. We would also make the point that the conversion of rural buildings could involve damage to protected species such as barn owls and this should be mentioned in the explanatory text.

Upper Roach Valley and Wallasea Island

URV1 Upper Roach Valley - Preferred Option
As we said in our previous comments Natural England supports the Council's preferred option for the enhancement and protection of the Upper Roach Valley including the Country Park. This provides an opportunity to link this area with the wider green infrastructure network and improve access to the countryside from surrounding areas. We suggest however that the policy is reworded to refer to 'appropriate management', as 'minimum of interference' as presently set out may not in fact 'permit certain flora and fauna to flourish.'

URV2 Wallasea Island - Preferred Option
Natural England supports the Council's preferred option as it supports the Wallasea Wild Coast Project which will create a variety of wildlife habitats and enhance the biodiversity of the area. We suggest however that the policy is reworded from 'no adverse impacts' to 'provided any adverse ecological impacts are avoided, mitigated, or compensated for.'

Habitat Regulations Assessment

As discussed in our responses to the previous Core Strategy Preferred Options and Strategic Environmental Assessment, dated 27 and 13 June 2007, we remind the Council that the Core Strategy will require assessment against the Habitats Regulations. I provide an extract below from our 27 June 2007 letter:

"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.

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:

i) Overall growth 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."

I trust these comments are of assistance to you and please do not hesitate to contact me if you wish to discuss any of the above further.