Objectives

It is unclear how settlements are determined to be "viable" although Paragraph 4.8 provides some criteria.

The principle of prioritising the re-use of previously developed land is a well-established approach to maximising sustainable development. The Core Strategy acknowledges the strategic and local importance of the Green Belt. However Whilst accepting that most new development should be on brownfield land and limiting the amount of development in the green belt, recognition should be given to the need for some additional development on greenfield sites adjacent to existing settlements. This will particularly be the case where there is insufficient previously developed land to accommodate the need for growth within the district.

ROCHFORD LOCAL DEVELOPMENT FRAMEWORK
CORE STRATEGY SUBMISSION DOCUMENT

Thank you for your letter dated 21 September 2009 consulting English Heritage on the above document. Our comments are set out below.

CHAPTER 4 HOUSING

Vision and objectives
While we note that character of place is addressed in chapter 5, it is important that this consideration is recognised as relevant within the Housing chapter. Paras 2.33, 2.69 and 2.73 also recognise the importance of character and sense of place in the built environment. We recommend that this consideration should be integrated into the vision and objectives for housing in order to improve the clarity of the plan, and its consistency with advice in PPS1.

Recommendation:
The following amendments are suggested:
- Vision in five years: add 'settlement character' after 'infrastructure'
- Vision by 2025: add 'and places' after 'communities' in bullet 1
- Objectives: In objective 2 amend to '...sustainable locations, enhancing sense of place and having regard to..'
- Para 4.19: Amend bullet 5 to read 'The historical, agricultural and ecological value of land, and settlement character'

CHAPTER 5 CHARACTER OF PLACE

We strongly support this section and policies CP1, CP2 and CP3. In the absence of policy coverage for listed buildings and scheduled monuments we recommend that para 5.9 should refer to PPGs 15 and 16, as well as draft PPS15.

CHAPTER 8 ENVIRONMENTAL ISSUES

We welcome the references the historic environment in the objectives and in policies ENV1 and ENV2.

Policy ENV6 Large Scale Renewable Energy Projects

We consider that this policy should refer to the historic interest of sites to reflect the advice in PPS22 more appropriately.

Recommendation: amend the first bullet in policy ENV6 to read '...it's ecological, historic or landscape value...'

CHAPTER 11 ECONOMIC DEVELOPMENT

Policy ED2 London Southend Airport
We understand that the grade I listed church in the vicinity of the runway will be protected in any proposals for expansion of the airport and the Core Strategy policy does not suggest otherwise. We will respond to the detail of proposals for the airport through responses to consultations on the Joint Area Action Plan and any planning applications.

In the interests of clarity, the above comments where we suggest changes to the Core Strategy should be recorded as objections to the soundness of the plan in terms of consistency with national guidance. However, we hope that it will be possible to agree amendments on these points prior to the public examination.

We would be happy to discuss any of these comments if you would find this useful.