CP2 Conservation Areas - Preferred Option

Canewdon's proposed expansion.

With the proposed expansion to Canewdon, and all the noise, dirt and heavy traffic that it would bring with it during construction, how would this be feasible with only one road in and out of Canewdon able to take HGV's? All HGV traffic would need to go throught the High Street - the very area the policy sets out to protect.

Re: Rochford District Council - Core Strategy Preferred Options

Thank you for consulting the Assembly on this matter.

The Regional Planning Panel Standing Committee considered the attached report at its meeting on 5th December 2008 and endorsed the following recommendation:

'Overall, the preferred options put forward in the Core Strategy respond well to the RSS. The Assembly does have some minor concerns but considers that these do not give rise to any major conformity issue'

Our detailed comments, which are set out in Appendix A of the attached report, constitute the Assembly's formal response to this consultation.

If you have any queries concerning the content of the report or any other issue relating to conformity with the Regional Spatial Strategy, please contact myself or James Cutting, Team Leader - Strategy & Implementation

Regional Planning Panel Standing Committee

5th December 2008

Subject: Rochford District Council's Core Strategy Preferred Options consultation document

Report by: Regional Secretariat

Purpose

To give a response to Rochford District Council's Core Strategy Preferred Options consultation document

Recommendation

The Standing Committee is asked to consider the recommendation that the comments in this report and those in Appendix A constitute the Assembly's formal response to Rochford's Core Strategy Preferred Options consultation document.

1. Introduction

1.1 Rochford District Council has published for consultation a revised version of its Core Strategy Preferred Options Development Plan Document. This is the second stage in the Local Development Framework (LDF) process and will, in due course, lead to a Submission Version. As the principle document in Rochford's LDF, the Core Strategy sets out the overall strategy for the district until 2021 and, where appropriate, beyond.

1.2 The Council consulted on an earlier version of its Core Strategy during June and July 2007 (see RPPSC 15 June 2007 - Item3). In submitting its response, the Assembly noted that whilst the document responded well to the then emerging East of England Plan there were issues with regards to affordable housing and major releases of land from the Green Belt.
1.3 The closing date for comments on this revised Core Strategy is 17th December 2008. Further details can be found on Rochford District Council's website.

1.4 A copy of the Core Strategy Key Diagram is included at Appendix B.

2. Background

2.1 Rochford District covers an area of approx. 168 sq. km's (65 sq. miles) and is situated within a peninsula between the Rivers Thames and Crouch. Bounded to the east by the North Sea, it shares land boundaries with Basildon and Castle Point District and Southend-on-Sea Borough Councils. It also has marine boundaries with Maldon and Chelmsford Districts. The A127 and the A13 provide a strategic road link to the M25 Motorway and there are direct rail links into London. London Southend Airport is also located within the district boundary.

2.2 The district has a noticeable east - west divide. The majority of the population, which recent estimates put at 81,300 (expected to rise to 87,000 by 2021), live in the west where the three main urban areas of Rochford, Rayleigh, Hockley are located. To the east, the district is more rural in nature, and is characterised by stretches of unspoilt coastline and countryside, with a scattering of smaller settlements. Approximately 75 per cent of the district is designated as Metropolitan Green Belt.

2.3 A significant proportion of the districts workforce (estimated to be around 68 per cent) work beyond the district boundary. Southend-on-Sea exerts a particularly strong influence, not just as an employment location but also as the largest retail centre in the sub-region. Beyond the three main urban areas of Rochford, Rayleigh and Hockley, which offer greater opportunities to access public transport, there is a high dependency on private car use.

3. Regional and Local Policy

3.1 Regional planning guidance for Rochford is contained within the adopted East of England Plan (hereafter referred to as the RSS) and the remaining six "saved" structure plan policies for Essex and Southend-on-Sea. At a local level, the Core Strategy and other LDF documents will replace the Rochford District Replacement Local Plan (2006).

3.2 In considering general conformity the Core Strategy was assessed against all policies contained within the RSS, with particular attention paid to policies relating to the Essex Thames Gateway (ETG1 - ETG5).

4. Comments

4.1 Overall, the preferred options put forward in the Core Strategy respond well to the RSS. There is recognition that growth needs to be delivered in a sustainable manner and evidence of continued joint working with neighbouring authorities, and the County Council, to ensure delivery of regionally significant schemes such as London Southend Airport and the South Essex Rapid Transit system.

4.2 The Assembly does have some minor concerns over the amount of development that is planned to come forward on previously developed land, and also on the Council's position with regards to larger scale renewable energy schemes. However, it considers that these do not give rise to any major conformity issue.

5. Recommendations

5.1 The Standing Committee is asked to consider the recommendation that this report and the comments in Appendix A constitute the Assembly's formal response to Rochford District Council's Core Strategy Preferred Options consultation document.


Appendix A
LOCAL DEVELOPMENT DOCUMENT CHECKLIST
PART TWO - GENERAL POINTS

Question - Does the area covered lie within the Eastern Region?
Answer - Yes


Question - Are all references to the East of England Plan correct?
Answer: - Yes

Question - Does the area covered include a Key Centre for Development and Change?
Answer - Yes
Comments - London Southend Airport is included within the Essex Thames Gateway policy area.

Question - Are there any key issues covered by the document that are of strategic or regional importance?
Answer - Yes
Comments - Expansion at London Southend Airport and the regeneration of the Thams Gateway are of regional importance.

PART THREE - CONSISTENCY/CONFORMITY CHECKLIST

Question - Is there a clear push for sustainable development?
RSS Policy - SS1
Local Policy - All
Comments - The overall objectives and policies seek to achieve a balance between bringing forward sufficient new growth to meet the needs of the district whilst protecting its natural and historic built environment. There is also clear recognition of the need to ensure that the necessary infrastructure is delivered in a timely and effective manner.

Question - Does policy seek to maximise the use of previously developed land (PDL), and will it contribute towards the 60% target?
RSS Policy - SS2
Local Policy - H1
Comments - (See also comments below relating to Green Belt.)
While local policy H1 supports prioritising the reuse of PDL, the findings of the Council's recent Urban Capacity Study (2007) and concerns over town cramming will mean that only some 30% of new housing development will come forward on PDL.
Although accepting that the 60% target may not be deliverable in all parts of the region, the Council is encouraged to maximise the development potential of all brownfield sites (including "windfall' sites) and, through its monitoring procedures, ensure that delivery does not fall below the proposed 30% level.

Question - Is there a clear pattern of development for 'Key Centres' or for other urban and rural areas?
RSS Policy - SS3, SS4
Local Policy - Various

Question - Is the role of city/town centres clear? Is there a clear retail hierarchy?
RSS Policy - SS6
Local Policy - RTC1 to RTC5
Comments - The influence of out-of-district shopping facilities; particularly those provided at Southend, is acknowledged. Local policy seeks to maintain and enhance the current market share of retail spending, with the focus for development centered on Hockley, Rayleigh and Rochford.

Question - If appropriate, is there a policy dealing with the Green Belt?
RSS Policy - SS7, ETG1
Local Policy - Page 4, GB1, GB2
Comments - RSS policy SS7 states that the broad extent of the Green Belt in the region is appropriate and should be retained. There are no plans for a Green Belt review around Rochford.

Whilst local policy seeks to protect the existing Green Belt, it does allow for some limited reallocation in order that built development can come forward. Where this release is considered to be unavoidable, the Core Strategy proposes that development occurs at a reasonably high density.

In accepting that some Green Belt land will be released, using that which contributes least to its main purpose seems appropriate. Either through this document or through relevant future documents, the Council should clarify what level of development constitutes a 'reasonably high density'.

Question - Is there a policy on coastal issues?
RSS Policy - SS9
Local Policy - ENV2
Comments - The biological/landscape value of the District's coastline is recognised.

Question - Is the East of England Plan employment target met?
RSS Policy - E1, ETG5
Local Policy - Econ' Dev' Chapter, ED1, ED2
Comments - The introductory paragraphs set out districts job requirement figure as quoted in RSS policy ETG5. There is acknowledgment of the important role that London Southend Airport can play in bringing forward employment and other economic development opportunities, as expressed through local policy ED1.

Question - Is employment land protected and is its designated use consistent with relevant RSS policies?
RSS Policy - E2 - E4
Local Policy - ED3, ED4, ED5

Question - Is the RSS housing target met? Is there a housing policy post 2021?
RSS Policy - H1
Local Policy - Housing Chapter H2, H3
Comments - The introductory section sets out district housing figures in line with RSS requirements. Local policies H2 & H3 relate to general distribution, including indicative housing numbers within settlement areas for the period to 2015, from 2015 to 2021, and post 2021.

Question - Is there an affordable housing policy and does it meet the RSS target?
RSS Policy - H2
Local Policy - H4, H5
Comments - The Preferred Option is consistent with the RSS target (35%) and national site size thresholds (15 or more dwellings). It is noted that local evidence shows the actual level of need is much higher, but that the Council is seeking to strikes a balance between deliverability of affordable housing and overall site viability.

Question - Is there a clear policy for meeting the accommodation needs of Gypsies and Travellers?
RSS Policy - H3
Local Policy - H7
Comments - Local policy H7, which states that provision will be made in line with recommendations set out in the RSS Single Issue Review, is welcomed. It is also noted that local authorities in Essex have expressed concerns over the RSS review process.
The Assembly encourages all local authorities to make provision in line with its recommendations to 2011 and beyond, noting that they will need to be mindful of any amendment to district pitch requirement figures as the RSS Single Issue Review is progressed.

Question - Are culture issues addressed?
RSS Policy - C1, C2
Local Policy - CLT6 - 11

Question - Is there a policy seeking to change travel behaviour? Is there a policy seeking to enhance provision for non-motorised forms of transport?
RSS Policy - T2, T9, T13 & T14
Local Policy - T1 - T6
Comments - The Core Strategy recognises that, away from the three main urban areas, there will continue to be a high dependency on private car use. Policies that encourage and bring forward the delivery of alternate and non-motorised forms of transport are supported.
Opportunities to facilitate home-working within new development proposals should not be ignored.

Question - Are any major transport generators covered by appropriate proposals?
RSS Policy - T11, T12
Local Policy - ED1
Comments - [The Council is referred to concerns raised by the Assembly during recent consultation on the JAAP Issues & Options consultation stage - see RPPSC 18 July 2008, Agenda item 4]

Question - Are any transport schemes being promoted that match regional priorities?
RSS Policy - T15
Local Policy - T3
Comments - Local policy T3 supports the implementation of the South Essex Rapid
Transport (SERT) scheme.

Question - Is there a policy dealing with green infrastructure?
RSS Policy - ENV1
Local Policy - ENV1, ENV2, T6

Question - Are landscape, wildlife and other conservation issues addressed?
RSS Policy - ENV2, ENV3
Local Policy - ENV1, ENV2, URV1, URV2

Question - Is agricultural land and soil conservation covered by a policy? Is there a policy relating to rural diversification?
RSS Policy - ENV4
Local Policy - GB2
Comments - The introductory paragraphs in the Environmental Issues chapter (pg 51) states that the Council will endeavour to ensure that the districts agricultural land will not be adversely affected. Local policy GB2 offers support for rural diversification schemes within the designated Green Belt.

Question - Are woodlands protected by a policy?
RSS Policy - ENV5
Local Policy - ENV1, URV1 (ENV6)
Comments - The Preferred Options seek to ensure that areas of ancient woodland are protected.

Question - Is the conservation/enhancement of the historic environment addressed?
RSS Policy - ENV6
Local Policy - CP2, CP3
Comments - The Council intends to reinstate a 'Local List' which will afford protection to local buildings with special architectural / historic value.

Question - Is there a policy that seeks to achieve a high quality built environment, including sustainable construction?
RSS Policy - ENV7
Local Policy - H6, ED5, ENV8, ENV9, CP1
Comments - Local policies ENV8 & ENV9 advocate the implementation of Code for Sustainable Homes (CSH) and BREEAM3 standards. It would be helpful if a timescale was included showing when the Council expects to implement the various code standards.

Question - Is there a policy dealing with the reduction of CO2 emissions? Is there a policy on renewable energy, including the setting of a target?
RSS Policy - ENG1, ENG2
Local Policy - ENV6, ENV7
Comments - The Core Strategy contains two policies on renewable energy - ENV6 and ENV7. While the Assembly is supportive of any policy that actively seeks to implement renewable energy technologies it is concerned that (i) as worded, policy ENV6 seemingly discourages any large scale scheme from coming forward and, (ii) that whilst local policy ENV7 is welcomed, difficulties may arise in measuring the effectiveness of small scale schemes and relating this back to regional and national targets.

Local policy ENV6 should be more 'proactive' by, for example, indicating which type of scheme(s) the Council would be wiling to support. The Assembly will be looking to the relevant Development Control documents to ensure that appropriate targets are set in line with regional targets.

Question - Is there a policy promoting water efficiency?
RSS Policy - WAT1
Local Policy - ENV8, ENV9
Comments - Water efficiency measures are being promoted through policies that adopt BREEAM and Code for Sustainable Homes (CSH) standards

Question - Is Flood Risk Management addressed? Are proposals to implement Sustainable Urban Drainage technologies included?
RSS Policy - WAT4
Local Policy - ENV2, ENV4

Question - Is there a policy dealing with waste management?
RSS Policy - WM1 - WM8
Local Policy - ENV8, ENV9
Comments - It is implied that domestic/commercial waste management practices will addressed through adoption of CSH and BREEAM Standards.

Question - Is there a policy that deals with implementation and monitoring?
RSS Policy - IMP1 - IMP2
Local Policy - Page 107 and Table

PART FOUR - OVERALL ASSESSMENT

Question - Is the document in general conformity with the RSS? If the answer is 'no', what is needed to rectify this?
Answer - Yes
Comments - Overall, the preferred options put forward in the Core Strategy respond well to the RSS. There is recognition that growth needs to be delivered in a sustainable manner and evidence of continued joint working with neighbouring authorities, and the County Council, to ensure delivery of regionally significant schemes such as London Southend Airport and the South Essex Rapid Transit system.

The Assembly does have some minor concerns over the amount of development that is planned to come forward on previously developed land, and also on the Council's position with regards to larger scale renewable energy schemes. However, it considers that these do not give rise to any major conformity issue.