The Role of Development Management Development Plan Document

It is understood that legally RDC are required by law to consult but the sheer amount of consultation documents, their size and in some cases complexity is likely to overwhelm people. The fact that 'packs' are coming out over a short period is not helping.
If RDC are honest about their willingness to consult then after each consultation they should advise the electorate how the strategy is being changed to meet their wishes.

How inappropriate and so obviously mismanaged DC consultation (planning not their greatest strength!). This document is very detailed and lengthy as are Allocations DPD Discussion and Core strategy documents for any of these to be satisfactorily commented and hence consulted on by the district population in a six week time frame. Timing is far too short especially given at the same time has been two local planning appeal hearings that the locals have been involved in. Us general public need more time to understand and digest these documents before being able to make a truly informed comment in consultation

Allocations and Management Development Plan
Thank you for consulting The Coal Authority on the above.

Having reviewed your document, I confirm that we have no specific comments to make on
this document at this stage.

We look forward to receiving your emerging planning policy related documents; preferably
in an electronic format. For your information, we can receive documents via our generic
email address planningconsultation@coal.gov.uk, on a CD/DVD, or a simple hyperlink which is emailed to our generic email address and links to the document on your website.

Alternatively, please mark all paper consultation documents and correspondence for the
attention of the Planning and Local Authority Liaison Department.

Should you require any assistance please contact a member of Planning and Local
Authority Liaison at The Coal Authority on our departmental direct line (01623 637119).

Re: RDC's Development Management DPD Discussion and Consultation Document Reg 25 dd Feb 2010

I would like to raise some points and ask some questions about the above mentioned document.
I have written them Page by page Para by Para in the hope that it will assist you in understanding how my comments etc., relate to your document. Should anything be unclear or need clarification please do not hesitate to get in touch with me.
I would also like to voice my concerns with the council's communication to us the electorate on the above. I raise the question I stated in my letter to you dated 25th April 2010 on the Allocation DPD Discussion and Consultation Document and Appendix 1, "Might I suggest that in future to comply with your Statement of Community Involvement (CSI) you go beyond just publishing in select media and make sure that people receive, read and hear what you have to say ? You would then not find yourselves n the current situation with many of the electorate objecting so late in the process. Did you think to put a statement in the CSI about what % of the community you expect to respond and use that to manage the effectiveness of your communication? Please consider adding one. ?"
I would point out that your audience must be everyone not just adults, why not ask, before putting out to the public, some children from schools, teenagers, juniors etc., to see if they understand what you have written, why not ask pensioners, people out of work ?
This document describes a management process through policies and I can not see how you can implement policies if they allow developers freedom to do what they want. The constant use of the word "should" through this document means most of the things stated are not restrictions but purely statements, only by using the word "must" do the statements become restrictions and policies become effective.
I am shocked at the quality of this document and wonder what review and authorization processes have taken place before this was published. Is it the council's intention to use the public to proof read and check for content etc?
Most of your intended audience work for a living and have families to look after. There is very little time to sit down and review one 75 page document let alone the additional task of cross referring it to a 169 page document (Core Strategy) which in turn depends upon several large documents. I am fortunate enough to be retired so I have been able to dedicate 12 days to review your document and compose a reply. I have struggled to get through half of it. Do you expect the public to work once they have got home or to give up all their weekend time with the family ? Setting a review period 17th March 2010 to 30th April is unreasonable. I suggest, if you truly want the public to participate, and for the benefit of the document / process and to improve the sense of community involvement you extend the deadline by at least 1 month better still 2 months.


I hope this letter will help you focus on what must be added to provide clarity and assist the public in making valid judgements on the Development Management. I would appreciate you letting me know in writing what your responses to my questions are and what the process is should I wish to ask further questions on your responses.
I am interested in the next stage and any future stages of this document and would like to participate in any further discussions you might schedule, in which I can take part in. Perhaps in you reply you might advise what these are.

Question No. Page. Quote, Question/Comment

Q.1
P.1
It is led by the Local Planning Authority working closely with those proposing developments and other stakeholders
Other stakeholders is a sweeping statement and must not be used unless there is a Glossary that defines stakeholder. Where is the Glossary?

Q.2
P.1
It is led by the Local Planning Authority working closely with those proposing developments and other stakeholders
The core strategy talks about sustainable community yet this statement does not include the community. Currently I believe this is done through the Parish Councils. As a minimum and to obtain benefit of community involvement as documented in Statement of Community Involvement jan 2007 page 3 " A more democratic form of planning" and "A greater sense of ownership of the district for local people" the Parish Councils and perhaps council recognised Action Groups must be named here.
As a result of the core strategy several official action groups have formed these also must be named. Why aren't they both included ?

Q.3
P.1
Adopting the development management approach will enable us in conjunction with local communities with local communities and stakeholder, to promote and achieve the vision and objectives contained within the development .....
Other stakeholders and local communities are sweeping statements unless there is a Glossary that defines them.
(See question 1).

Q.4
P.1
Adopting the development management approach will enable us in conjunction with local communities with local communities and stakeholder, to promote and achieve the vision and objectives contained within the development .....
Working closely is not the same as working in conjunction with. To achieve a sustainable and cohesive community I would suggest you need to work closely with the Parish Councils and Action Groups. And you must define their roles in the process. What roles do you perceive the Parish Council's and Action Groups performing ?

Q.5
P.1
The Development Management DPD will set out the detailed, day- to-day planning policies through which development ........
What are the non day-to-day planning policies and where are they set out ?

Q.6
The Core Strategy is the overarching document of the Local Development Framework. It sets out our core issues and policies for the future development of the District, which the development management policies just conform to in order to be found "sound" and to deliver our vision. As such, the development management policies must not repeat the policies in the Core Strategy and should be read in conjunction with them. Therefore both these documents will be used in the determination of planning applications for the development and use of land and buildings in the District.
This is ludicrous! To make a statement that makes it very clear the importance to this document by the policies stated in the Core Document and then to say this document should not include those policies defies common sense as it will create reconciliation / management problems later on and runs the risk of policies being omitted.
This document must be using the policies of the Core Strategy and therefore must be cross referencing them to where used in this document to the Core Strategy, not omitting them. What justification is there to use this approach?
This method only creates more work later on when any reviewer will have to look at two documents instead of one to make sure the development complies with all policies. Is it that the council wishes and have they considered that people will not be bothered to look into two documents ?
How does the council prove that all the policies in the Core Strategy have been used in this document ?
How do they expect the community to see that the council have ensured all policies have been covered this methodology is not promoting effective communication?
It is not an effective way of communicating and obtaining the communities participation, the methodology is obstructive. Did the council ever check if this is an effective way of communicating by asking people in the community prior to adopting this approach ? If so where can I see that surveys results ?

Q.7
P.1
This consultation document is the first stage in the process and has been developed having regard to our approach to the future development of the District as set out in the emerging Core Strategy
What specifically in the Core Strategy ? Cross reference it !
Why are you so adverse to cross referencing to such a key document on which everything is based. ?
The Core strategy is not in a final approved state, so you are not sure what changes may be made to it. If changes are made by having cross referencing you are able to see the impact of those changes upon other documents and make the relevant changes necessary.

Q.8
P.1
Supplementary Planning Documents, however, do not contain policies and as such are not part of the Development Plan. These documents will sit below the policy documents and provide additional advice and guidance where appropriate.
I would put to you that the use of so many titles of documents without an attached Glossary summarizing them is almost like using Jargon which is not in compliance with Statement of Community Involvement page 5 Box 3.

Q.9
P.1
Supplementary Planning Documents, however, do not contain policies and as such are not part of the Development Plan. These documents will sit below the policy documents and provide additional advice and guidance where appropriate.
What is a Supplementary Planning Document ?
Please provide examples, only then can we the community make a judgement on whether this approach is correct!

Q.10
P.1
The Development Management DPD will need to be adapted to reflect the approach of the adopted Core Strategy, as appropriate.
Therefore this document must list how this will be done.
I can not see any document in the massive number of documents to form the LDF and Core Strategy that talks about the document management and how changes will be captured and existing approved documents amended.
If there is can you please inform me where ?

Q.10a
P.2
This document is a public consultation document which explains our preferred approach to managing future development within the District.
The intended audience of this document is the public and so it must be using common everyday language and where this is not possible provide detailed explanations in a Glossary, why does this not have one. It is unreasonable of the council to think that the public have the time and inclination to trawl through loads of documents to see what is relevant to this document. The council should create each document under its own merits and not be lazy and cut corners by just referring to a document. The minimum they must do is cross reference to a document/ version/ page no. paragraph no. Despite of what the say in their document "Statement of Community Involvement" dd Jan 2007 " page 1 "1.To engage effectively with all sections of the community" they are failing to do so with this document.

Q.10b
P.2
Where is a statement of the aim of this document relating to the public. What is its purpose with respect to developers, communities, neighbouring councils and general public ?
At present it appears only to serve the council's purposes.

Q.11
P.2
This document, although not the final version, should be read in conjunction with the approach outlined in the emerging Core Strategy submission document.
Please see questions 6 and 7.
It is unrealistic to expect the community to read and compare two or more documents to see if this document is ok. Why should the community be bothered to prove you have done your job properly it must be your role to prove to the community you have. And cross referencing is a tool to do so and you are not using it. Why ?
Why do you not take the time to identify where in the 169 page Core Strategy submission document the "approach" is captured ?

Q.12
P.2
It sets out the preferred options for development Management policies reflecting the priorities set out in the emerging Core strategy, and where appropriate, alternative options with explanations as to why such an approach is not preferred. This document has been subject to a sustainability appraisal.
Whose preferred options, Councils?, Communities ? Developers ?

Q.13
P.2
It sets out the preferred options for development Management policies reflecting the priorities set out in the emerging Core strategy, and where appropriate, alternative options with explanations as to why such an approach is not preferred. This document has been subject to a sustainability appraisal.
What is a sustainability appraisal? Who conducted it ? When , where are the results, proof ?

Q.14
P.2
It sets out the preferred options for development Management policies reflecting the priorities set out in the emerging Core strategy, and where appropriate, alternative options with explanations as to why such an approach is not preferred. This document has been subject to a sustainability appraisal.
What is the difference between the Core strategy and an emerging Core Strategy, an adopted Core Strategy ?
How can you be writing a document that relies on another document's policies, when that document has not been finally approved and published.?

Q.15
P.2
It sets out the preferred options for development Management policies reflecting the priorities set out in the emerging Core strategy, and where appropriate, alternative options with explanations as to why such an approach is not preferred. This document has been subject to a sustainability appraisal.
Where in the emerging Core strategy ?

Q.16
P.2
It sets out the preferred options for development Management policies reflecting the priorities set out in the emerging Core strategy, and where appropriate, alternative options with explanations as to why such an approach is not preferred. This document has been subject to a sustainability appraisal.
If the Core strategy is unfinished (emerging) how can this document cover the policies in the strategy if some can be added after this document has been approved etc.,

Q.16a
P.2
This document has been subject to a sustainability appraisal.
This should be at the very front of this document on Page 1.

Q.17
P. 2
This is the first stage in the preparation of the Development Management DPD. Following the initial round of community involvement, the submission version of this document will be prepared, having regard to these findings.
Where in the document does it capture the process of taking feedback from the community and reflecting it in this document ?

Q.18
P.2
....before a final version of the document is agreed.
Agreed by whom ?

Q.19
P.3
Preferred Options public consultation
The level of public involvement in the early stages of the Allocations DPD Discussion and Consultation Document was not high and towards the end was much better as people responded in anger at how the council communicated to the public as was seen in the massive increase in letters from Hullbridge. What steps have the council taken to improve the methods of communicating and ensuring public participation to make the consultation periods effective ?

Q.20
P.3
Our vision is shared with that of the Local Strategic Partnership;
Who or what is the Local Strategic Partnership ? Where is the Glossary ? You might just as well say "shared with that of the Green Men form Mars !

Q.21
P.3
... we have four main corporate objectives.
What is meant by corporate objectives ? What other type of objectives are there and what are they ?

Q.22
P.3
The vision and objectives for that topic as determined in the emerging Core Strategy have been set out
Set out where ? Cross reference !!!!!

Q.23
P.3
Sustainability Appraisal
Can you please explain this. This is not clear ?
Also see question 13.

Q.24
P.4
In preparation of this preferred options document, regards has been had to the community involvement exercises from the various public consultation stages which have informed the preparation of the emerging Core Strategy.
What is meant by "has been had" ?

Q.25
P.4

In preparation of this preferred options document, regards has been had to the community involvement exercises from the various public consultation stages which have informed the preparation of the emerging Core Strategy.
So does this mean that the alternative options do not have regard to the community involvement exercises ?

Q.26
P.4
The Core strategy is being developed having regard to a wealth of other strategies at higher and lower tiers to the District
What are these Higher and Lower tiers and what is the relevance to this document ?

Q27
P4
The Sustainable Community Strategy (2009) is the long term vision for the District and sets out the priorities for improvement intended to deliver the vision. It is developed by the Local Strategic Partnership - a partnership of local public, private and voluntary sector organisations who play a key part in the provisions of services within the District.
Who exactly are these organizations ? A list must be cross referred to and SCS must be in a Glossary.

Q27a
P4
Sustainable Community Strategy identifies seven key priorities :-
Why do you not cross refer than as follows:-
Sustainable Community Strategy 2009-2021 dd April 2009 (http://www.rochford.gov.uk/PDF/sustainable_community_strategy_2009_2021.pdf )
identifies seven key priorities :-
Supporting the Ageing Population (page 9)
Fostering Greater Community Cohesion (page 10)
Strengthening the Third Sector(voluntary sector) (page 11) etc.,.....

Q.28
P.4
Strengthening the Third Sector
What are sectors one and two are there any more ? Is this Jargon ?

Q.29
P.4
Increasing Accessibility to services
What services, where is there a list ?

Q.30
P.4
There are a number of other strategies which influence our Local Development Framework as outlined below :-
Do these strategies only appear in the LDF?, are they not relevant to the Core Strategy ?

I do not see how a Assessment, Plan, Guide, Supplement , Delivering the future is a strategy. Don't you mean documents that detail strategies ?

Q.31
P.6
Planning Policy Statements (PPSs)
What is this, where is an example ? How has these shaped the document.

Q.32
P.6
Planning Policy Guidance Notes (PPGs)
What is this, where is an example ? How have these shaped the document ?

Q.33
P.6
And circulars
What are circulars, whose are they, for what period of time ? How have these shaped the document ?

Q.34
P.6
This document, where appropriate, has also drawn upon the extensive evidence base which has informed the development of the emerging Core Strategy. These key documents are as follows:-
Whose extensive evidence base?
Over what period has this been captured ?
By whom ?
When were the documents without dates published ?
Do the dates in brackets represent the published or start dates ?
How old do these documents have to be to be considered out of date ?
Are all these documents in their approved and published state ?
Are there any immediate plans by the parties who wrote these documents to conduct reviews new studies in the next year ?
If any of these documents change during the production of this document how are they monitored, captured and reflected in this document.

Q.35
P.6
This document, where appropriate, has also drawn upon the extensive evidence base which has informed the development of the emerging Core Strategy. These key documents are as follows:-
Where can these documents etc., be found specifically.

Q.36
P.6
This document, where appropriate, has also drawn upon the extensive evidence base which has informed the development of the emerging Core Strategy. These key documents are as follows:-
What has been used from these key documents to help create this document? Cross reference !!!!!

Q.37
P. 9
New sustainable, residential developments are planned that are well related to infrastructure.....
What does well related mean ? Within 1mile, 100 Km's ?
where in the document is well related defined ?

Q.38
P.9
New sustainable, residential developments are planned that are well related to infrastructure.....
What and how is sustainable measured ? What is meant by sustainable ? Where in this document is it described ?

Q.39
P.9
New sustainable, residential developments are planned that are well related to infrastructure.....
What is meant in this document by Infrastructure, community facilities, play space ? Where in this document is it described ?

Q.40
P.9
These have begun to be implemented. A number of residential developments, along with additional infrastucture, have been completed and are meeting the needs of local communities.
Why is this statement in here when it states In five years...
These developments did not fall under the Development Management so why are they relevant ?
What benefit does this statement bring to the document ?

Q.41
P.9
The council has adopted a Local list which has afforded additional protection to locally significant buildings.
Where is this local list ?
Does it identify current protection and what the additional protection is. Why is there additional protection planned for a building in five years, surely they need it now !
Or what has this to do with the vision in 5 years time ?

Q.42
P. 9
Work has begun on implementing the conservation Area Management Plans which is having a positive impact ....
This statement must be talking about how much conservation land, buildings etc., would be expected in the district in five years time. It currently does not state what it will be like in five years time only that it is having an impact now.

Q.43
P. 9
By 2025
A range of high quality, sustainable new dwellings .....
What defines a dwelling as being high quality , simply because it is new ?

Q.44
P. 9
By 2025
A range of high quality, sustainable new dwellings .....
What defines a dwelling as being sustainable ? That the council can provide services ?

Q.44
P.9
By 2025
The vast majority of the District's Green Belt remains undeveloped.....
Define vast, 75% ? Is that against todays Green Belt or that in 2025 ?

Q.45
P.9
By 2025
Where is there a statement about being Green as is in SCS 2009-2021 page 15 ?
Why are you not listing the National Indicators ?

Q.46
P.9
1. Ensure the delivery of an adequate supply of sustainable dwellings to cater for the District's growing demand....
I would like to see added :-
Ensure the delivery of an adequate supply of sustainable dwellings to cater for the District's growing demand by re- developing vacant existing properties and then building new homes, as per the requirements of the East of England Plan and a 15 year housing land supply.

Q.47
P.9
2. Deliver a balanced strategy for the distribution of housing, directing housing growth to the most sustainable locations having regard to social, economic and environmental considerations
I would also like to see added cost effective. What is the point of doing all this if it will cost the electorate the earth ? The financial impact upon the community must come into the decision.

Q.48
P.9
2. Deliver a balanced strategy for the distribution of housing, directing housing growth to the most sustainable locations having regard to social, economic and environmental considerations
What is the definition of "a balanced strategy" ?

Q.49
P.9
3. Ensure the District's settlements remain viable and that rural services can be sustained.
If I understand this correctly, very commendable but the District Council and County council can not in certain communities do this today. In Hullbridge there are numerous problems relating to infrastructure, youth opportunities, empty houses and shops etc., are you advocating that things are viable today and that this is the level you intend measure against ? When are settlements non viable ? How do you identify when a settlement is on the down turn towards becoming non viable ?

Q.50
P.9
4 Prioritise the redevelopment of appropriate brownfield sites for housing, to minimise the release of Green Belt land for development.
This is not precise enough. I would prefer :-
Ensure the redevelopment of all brownfield sites is done before the release of Green Belt land and to not change the status of Green Belt land till 1 year before the planned development on that land. This way should any brownfield sites become available because of economic decline in the area then these would be developed and the district would not have lost Green Belt land. ?

Q.51
P.9
5 Ensure the delivery of housing which caters for the needs of all communities in terms of tenure, type and location
The following must be added: Social needs. What is the point in putting a islamic family in a village that has no islamic religious buildings near by ?


Q.52
P.9
6 Ensure that appropriate infrastructure accompanies new housing development.
What is appropriate infrastructure ? Where does it state specifically what is required for a housing development without this how can it be ensured ?

Q.53
P.9
7 Ensure that the new development respect and make a positive contribution towards the built environment .
Where in his document does it detail how something can be evaluated as a positive or negative contribution to the built environment.

Q.54
P.9
8 Support and enhance the local built heritage
Why is the word built in here, surely it is to Support and enhance the local heritage with in the district. ?
How do you define local ?

Q.55
P.10
....and identifies general locations which could accommodate appropriate sustainable extensions to the residential envelope to ensure a 15 year supply....
Isn't residential envelope jargon ? What does it mean ?

Q.56
P.10
....and identifies general locations which could accommodate appropriate sustainable extensions to the residential envelope to ensure a 15 year supply....
What is appropriate sustainable extensions ? How do you know if something is appropriate, where have you detailed what you consider appropriate ? Without this how do developers know what their restrictions are and the communities know what their rights are ?

Q.57
P.10
Whilst ensuring the required quantum, of housing
Isn't quantum jargon ? What does it mean ?

Q.58
P.10
...and requires compliance with the Lifetime Homes Standard ......
You must be stating which version and or publication date.

Q.59
P.10
...meeting the District's changing demographic needs.
Is demographic jargon ? What does demographic needs mean ?

Q.60
P. 10
Partnership working and consultation with the Council's Housing Strategy Team is required to ensure that this is achieved.
Why, what does the CHST bring to the plan ? What is the role of the CHST ? Who are they ?
When should consultation take place, is sign off required of a development by CHST ? What other teams will have a role in the Development Management and what are their roles ?

Q.61
P.10
Partnership working
Isn't partnership working jargon ? What does it mean ?

Q.62
P.10
The protection and enhancement of the District's distinct settlement characteristics are also key issues which are covered in the emerging Core Strategy.
Where in the core strategy ? Cross reference it.
A word search of the Core Strategy document shows that the term Settlement Characteristics does not exist in the document, so how are we supposed to know what you refer to as settlement characteristics ?

Q.64
P.10
It is important to ensure the high quality design of new developments and regard must be had to local design guidance.
Try speaking English ! What are you saying here ?
It is important to ensure the high quality of developments.
To achieve this regard must be given to the local design guidance. Is this what you are trying to say ?

Q.64
P.10
It is important to ensure the high quality design of new developments and regard must be had to local design guidance.
Why only new ?

Q.65
P.10
It is important to ensure the high quality design of new developments and regard must be had to local design guidance.
What is local design guidance ? Is it a document ? Where is the guidance captured ?

Q.66
P.10
...through the appropriate management of
the District's Conservation Areas and the reintroduction of the Local List.
What happened to the Local List and what steps are planned to ensure it does not have to be reintroduced.
Where are the details advising how the Local List has been compiled and will be maintained and by whom ?

Q.67
P.10
It is important to ensure a positive impact on the surrounding environment and a coherent and interesting character through following good design principles and using locally distinct settlement characteristics.
Is "coherent character" jargon ? What is meant by a coherent character ?

Q.68
P.10
It is important to ensure a positive impact on the surrounding environment and a coherent and interesting character through following good design principles and using locally distinct settlement characteristics.
Is "interesting character" jargon in this context ? What is meant by this ?

Q.69
P.10
It is important to ensure a positive impact on the surrounding environment and a coherent and interesting character through following good design principles and using locally distinct settlement characteristics.
What are "locally distinct settlement characteristics". ?
Where is there a list and description of these ?

Q.70
P.10
The design of new developments must also be considered with respect to the wider implications of such development on the form, flow and character of the built environment and its impact on sustainability objectives.
Isn't "development on the form of the built environment" jargon ? What does it mean ?

Q.71
P.10
The design of new developments must also be considered with respect to the wider implications of such development on the form, flow and character of the built environment and its impact on sustainability objectives.
Isn't "development on the flow of the built environment" jargon ? What does it mean ?

Q.72
P.10
The design of new developments must also be considered with respect to the wider implications of such development on the form, flow and character of the built environment and its impact on sustainability objectives.
Isn't "development on the character of the built environment" jargon ? What does it mean ?

Q.73
P.10
The design of new developments must also be considered with respect to the wider implications of such development on the form, flow and character of the built environment and its impact on sustainability objectives.
What are the sustainability objectives and where are they listed ?

Q.74
P.10
Protecting and enhancing the existing character and individual identities of the District's settlements is a key objective of the emerging Core Strategy.
Where are the individual identities of the District's settlements listed. I ran a word search of the Core Strategy and could find only 1 instance of "individual identities" that was page 64 point 2 which is just a statement. So why are you stating it is in the emerging core strategies ?

Q.75
P.10
Therefore new development both within, and on the periphery of, existing settlements is encouraged to have regard to the character of the established streetscene in addition to the District's dwelling type requirements.
Streetscene isn't even in the English dictionary. What does it mean ?

Q.76
P.10
Therefore new development both within, and on the periphery of, existing settlements is encouraged to have regard to the character of the established streetscene in addition to the District's dwelling type requirements.
What is meant "to have regard to the character" ?

Q.77
P.10
Reducing the District's carbon emissions and planning to adapt to climate change is an important theme running through the Sustainable Community Strategy (2009), and this is reflected in the emerging Core Strategy.
What is the Sustainable Community Strategy (2009). Is it a document, a web page, a statement ? If a document what version etc., ?
Where is it reflected in the emerging Core Strategy ? Without you showing me where in the strategy how can I make a comment on something that reflects and not document. How do I know the emerging Core strategy and this document has captured all of the theme in the Sustainable Community Strategy (2009). ?

Q.78
P.10
Planning can play an important role through
ensuring the sustainability of new developments and alterations to existing buildings, whilst seeking to increase the energy efficiency of existing dwellings, as appropriate.
What is appropriate ? Where has this been detailed ?
Why does the statement of increasing the energy efficiency only about existing dwellings why is there not a statement alongside stating that all new developments must comply with .......... (state the energy efficiency standards).

Q.79
P.10
The historic environment of the District contributes to the unique character and history of individual settlements, as well as the established local streetscene. The significant historic townscapes ....
Why is this not following along behind chapter 3 which is about the same subject, the historic environment? Jumping all over the place with random paragraphs causes confusion. The Intro., must be properly constructed with a logical order.

Q.79
P.11
1 The Council considers major development as defined within the Town and Country Planning (General
Development Procedure) (Amendment) (England) Order 2006
This is not helpful. How do we know where to see this, why not add it as an addendum ?

Q.80
P.11
It is important that additions or alterations to the residential envelope are inkeeping with the local characteristics and reflect the distinctiveness of the District's towns and villages to ensure the cohesion of new communities into existing settlements.
"inkeeping s/b in keeping.
Where is the distinctiveness of the districts towns and villages captured ? If there is no such list how can you make any judgement against them ?

Q.81
P.11
It is important that additions or alterations to the residential envelope are inkeeping with the local characteristics and reflect the distinctiveness of the District's towns and villages to ensure the cohesion of new communities into existing settlements.
When does a village become a town ?

Q.82
P.11
The planning of sustainable extensions to the residential envelope will be design-led and community focused to secure high quality sustainable development.
See questions 55 and 56.
What is high quality sustainable development ? How do you differentiate between High quality and Low and Medium quality ? If you do not have clear definitions how can you secure it ?

Q.83
P.11
This will require the appropriate integration of the means of access for pedestrians, cyclists, cars etc. and allowing sufficient functioning of the Council's recycling scheme. This will also require the integration of public open space, historic features, landscaping, public art and habitat creation, recreational facilities and educational provision, community facilities, including the provision of primary health care, as appropriate, and housing of mixed size and tenure within the new and adjoining communities.
This is not a complete list (etc.,) why not, where is the complete list captured? If you do not have a complete list how can you secure hqsd? Whatever that is?
Where is the statement about developments cost impact upon the community? Surely any development must not be approved if the cost to the community financially is too expensive 5% increase in council tax etc.,) So how will you ensure this ?
Have you identified the need for wider pavements on the main route(s) to school to accommodate parents walking rather than driving the children to school. Lots of parents have prams, buggies, young children on scooters etc., and in some places existing pavements are in adequate ?

Q.84
P.11
This will require the appropriate integration of the means of access for pedestrians, cyclists, cars etc. and allowing sufficient functioning of the Council's recycling scheme. This will also require the integration of public open space, historic features, landscaping, public art and habitat creation, recreational facilities and educational provision, community facilities, including the provision of primary health care, as appropriate, and housing of mixed size and tenure within the new and adjoining communities.
What is meant by appropriate integration ?

Q.85
P.11
This will require the appropriate integration of the means of access for pedestrians, cyclists, cars etc. and allowing sufficient functioning of the Council's recycling scheme. This will also require the integration of public open space, historic features, landscaping, public art and habitat creation, recreational facilities and educational provision, community facilities, including the provision of primary health care, as appropriate, and housing of mixed size and tenure within the new and adjoining communities.
Is the items listed for integration like "public open space" existing, new or both ?

Q.86
P.11
This will require the appropriate integration of the means of access for pedestrians, cyclists, cars etc. and allowing sufficient functioning of the Council's recycling scheme. This will also require the integration of public open space, historic features, landscaping, public art and habitat creation, recreational facilities and educational provision, community facilities, including the provision of primary health care, as appropriate, and housing of mixed size and tenure within the new and adjoining communities.
What are the definitions of the item listed for integration? Where can these be found ?

Q.87
P.11
The provision of public open space within any proposed development should have regard to the findings of the Open Space Study.
What is the Open Space Study ? Whose is it ? What version , when was it published. Where can it be found ?

Q.88
P.11
The provision of public open space within any proposed development should have regard to the findings of the Open Space Study.
What were the findings ?

Q.89
P.11
As such, regard should be had to the landscape character areas, which define the different geographical regions with a recognisable pattern of landscape characteristics, which create a distinct sense of place.
What are the geographical regions ? What makes them different ? Where can I find the explanation?

Q.90
P.11
As such, regard should be had to the landscape character areas, which define the different geographical regions with a recognisable pattern of landscape characteristics, which create a distinct sense of place.
What are the landscape character areas ? Where can I find the details ?

Q.91
P.11
As such, regard should be had to the landscape character areas, which define the different geographical regions with a recognisable pattern of landscape characteristics, which create a distinct sense of place.
What is meant by a distinct sense of place ?

Q.92
P.11
We will also encourage the preparation of Village Design Statements and Parish Plans by local community groups
throughout the District which will provide developers with guidance on the local character of individual settlements and help ensure that developments are sensitive to the local area and designed in a way that would be acceptable to the local population.
Why would they only provide guidance to developers why not the council also ?
What is the definition of local area, 2miles from centre ?

Q.93
P.11
Village Design Statements will be expected to have been produced in consultation with the public to ensure that they reflect local opinions and must be endorsed by the Council before they can be used.
What body in the council must give their endorsement. Where is the procedure documented on how this is achieved ? What guideline have the council given on what can and can not be put in the Village Design and where are they ?

Q.94
P.11
Village Design Statements will be expected to have been produced in consultation with the public to ensure that they reflect local opinions and must be endorsed by the Council before they can be used.
Are their any Town design statements ? If so where are they ?

Q.95
P.11
It is also important to have regard to the findings of the District's Historic Environment Characterisation Project (2006). This will enable the sensitivity of landscapes and the characteristics of local places to be fully considered in the context of individual planning applications.
Where can the findings be seen /heard ? I presume the DHECP findings were published. What version of the document and what published date is to be used.
This document is 4 years old has any review been undertaken to see if it is still current, if so when and where are the results of that review published ?

Q.96
P.11
We are concerned about the potential impact of climate change and will therefore expect developers to implement appropriate initiatives to mitigate the impact of new developments.
Why is this just new developments, Are you going to allow a re-developer to put in a boiler that pumps out Co2 Emmissions ?

Q.97
P.11
We are concerned about the potential impact of climate change and will therefore expect developers to implement appropriate initiatives to mitigate the impact of new developments.
Have you consulted with the relevant government body and obtained a list of minimum requirements for eliminating impact of housing etc.,? Where can this be found ? If no do you not think you should have one so that developers are controlled ?

Q.98
P.11
The design and construction of buildings can directly affect the environment in terms of energy use and the generation of greenhouse gases and the subsequent impact on climate change through global warming.
It is my understanding that no proof exists about what is causing global warming or that this actually is happening, so does it not make sense to not use the words Global Warming. ? This gives the developers something to attack.

Q.99
P.11
This will also affect the consumption of non-renewable natural materials
Isn't "non-renewable natural materials" jargon. Where is the definition of this to be found ?

Q.100
P.11
The implementation of appropriate measures to reduce the consumption of energy and natural resources will help achieve the wider objective of securing more
sustainable forms of development within the District.
What are the appropriate measures, where are they listed ?


Q.101
P.11
We will therefore expect that all new buildings are well designed, fit-for-purpose, appropriate for the site and its setting and adaptable for long-term use.
What is the definition of well designed ? Where can it be found ?

Q.102
P.11
We will therefore expect that all new buildings are well designed, fit-for-purpose, appropriate for the site and its setting and adaptable for long-term use.
What is the definition of fit-for-purpose? Is this merely fit to live in ? Where can the definition be found ?

Q.103
P.11
We will therefore expect that all new buildings are well designed, fit-for-purpose, appropriate for the site and its setting and adaptable for long-term use.
How do you quantify that a new building is appropriate for the site ? Where can this be found ?

Q.104
P.11
We will therefore expect that all new buildings are well designed, fit-for-purpose, appropriate for the site and its setting and adaptable for long-term use.
What is meant by adaptable for long term use ?

Q.105
P.11
New buildings should achieve high environmental standards through energy and resource efficient sustainable design and make best use of sustainable construction techniques.
Where is it defined what High environmental standards are ? Where can they be seen /heard ?

Q.107
P.11
New buildings should achieve high environmental standards through energy and resource efficient sustainable design and make best use of sustainable construction techniques.
Isn't "energy sustainable design" jargon ? What is the definition of this ? Where can this be found ?

Q.108
P.11
New buildings should achieve high environmental standards through energy and resource efficient sustainable design and make best use of sustainable construction techniques.
Isn't "resource efficient sustainable design" jargon ? What is the definition of this ? Where can this be found ?

Q.109
P.11
New buildings should achieve high environmental standards through energy and resource efficient sustainable design and make best use of sustainable construction techniques.
What are "sustainable construction techniques" ? Where can a list be seen /heard ?

P.11/12/10
All dwellings must achieve required Code for Sustainable Homes and Lifetime Homes Standards and non-domestic buildings must aspire to achieve the appropriate BREEAM rating.
What is meant by achieving required Code ?
What is the gap / cross over between a dwelling and non-domestic buildings. If none why not say domestic buildings instead of dwellings or non dwelling for non-domestic buildings. Having different names causes confusion.

Q.110
P.12
Whilst aspiring for sustainable construction of new buildings, we also actively encourage the provision of well designed high quality places, which is pivotal for both major and small-scale developments.
Why is it pivotal for only major and small-scale developments / What other type of developments are there ?

Q.111
P.12
Whilst aspiring for sustainable construction of new buildings, we also actively encourage the provision of well designed high quality places, which is pivotal for both major and small-scale developments.
What is meant by well designed high quality places ?
Where can the definition be found ?

Q.112
P.12
Schemes should have a safe, inclusive layout with legible and well planned routes, blocks and spaces, integrated residential, commercial and community activity, safe public spaces and pedestrian routes without traffic conflict, secure private areas, attractive buildings and landscaped spaces.
What is the difference between a development and a scheme ? This is the first time scheme has been used so is a scheme covered the same as a development ?

Q.113
P.12
Schemes should have a safe, inclusive layout with legible and well planned routes, blocks and spaces, integrated residential, commercial and community activity, safe public spaces and pedestrian routes without traffic conflict, secure private areas, attractive buildings and landscaped spaces.
What is a safe, inclusive layout ? A layout of what ? Inclusive of what ? Do you mean to say:
Schemes must have a site plan that includes in a legible format ....... ?

Q.113
P.12
Schemes should have a safe, inclusive layout with legible and well planned routes, blocks and spaces, integrated residential, commercial and community activity, safe public spaces and pedestrian routes without traffic conflict, secure private areas, attractive buildings and landscaped spaces.
Surely a scheme ? must demonstrate the impact on the district's resources, roads, power supply etc., I.e, what impact does a development of 500 hundred houses in Ashingdon have on the roads through other communities.

Q.114
P.12
All developments should consider the concept statements which will be prepared by the Local Planning Authority, where applicable. These will outline the appropriate design principles for a particular site in order to deliver the best possible social, economic and environmental benefits for the community.
What is meant by all developments ? Is this submissions for development ? why should and not must, ? Should means there is no rule that they have to be considered, so they will not.

Q.115
P.12
All developments should consider the concept statements which will be prepared by the Local Planning Authority, where applicable. These will outline the appropriate design principles for a particular site in order to deliver the best possible social, economic and environmental benefits for the community.
When will the creation of concept statements be applicable ?

Q.116
P.12
All developments should consider the concept statements which will be prepared by the Local Planning Authority, where applicable. These will outline the appropriate design principles for a particular site in order to deliver the best possible social, economic and environmental benefits for the community.
What about cost effectiveness to the community. What is the point of allowing a development if the community / district can not afford it ?

Q.117
P.12
The design of new developments should reflect the character of the locality to ensure a positive contribution to the surrounding built environment and residential amenity.
Is there only one amenity, surely this must be amenities ?

Q.118
P.12
i) Accessibility
Accessibility to what ? development, amenities, existing community etc.,

Q.119
P.12
ii) Boundary Treatment
Boundary of what ? District, community, development etc., ?

Q.120
P.12
Iii) Car Parking
Car Parking where ? Local Town, development, community public car parking, existing services etc.,

Q.121
P.12
iv) Density
Density of what ? Land, car fumes, etc.,

Q.122
P.12
vii) Landscaping
Landscaping of what ? Next doors garden, development, surrounding area, environment etc.,

Q.123
P.12
viii) Overlooking, privacy and visual amenity
What is visual amenity ? Please clarify

Q.124
P.12
x) Scale and form
What does this mean ? Please clarify

Q.125
P.12
xi) Concept statements; and
Surely this is concept statements pertaining to development.

Q.126
P.12
Xii) Village Design Statements and Parish Plans, where applicable.
As these have been already approved by the council why should they not always be considered and if they are not relevant so stated ? By not including the Parish the council is running the risk of having a non cohesive community. The council do not know the individual communities like the Parish Councils and Action Groups, they do not have the time to do so. These parties views must included.

Q.127
P.12
Why are the following not included :-

Q.128
P.12
Proposals should have regard to the detailed advice and guidance on the design and layout of new developments as set out in Supplementary Planning Document 2 -
Housing Design, as well as to guidance in the Essex Design Guide for Residential and Mixed Use Areas, and the Open Space Study for open space provision.
What is the point of this statement ? A proposer can always say he did have regard. And because it is not compulsory with tools to measure a proposal by it is worthless.
Why is there not one place where all the requirements are captured, why does there always have to be a connection with other documents ? Those documents will change over time and therefore a change control process has to exists to make the but if there is no compulsory statement

Q.129
P.13
DM1
Option: Add to / delete criteria listed in the policy.
For you not to prefer this option is reckless, dogmatic and lacking in foresight. To think that a group of people who have created this list is able to capture everything that a population can identify is extremely arrogant.
This is the preferred option of the public, maybe not with a planning office of RDC.

Q.130
P.13
DM1
Why is it not preferred ?: The Council believe that this is a comprehensive list of issues which should be considered when determining planning applications.
There is a difference in believing and knowing. Why discount change if you do not know the list is complete. ?
Why should and not must, if should what is the point of having a list ?

Q.131
P.13
The density of new developments is critical to the efficient and appropriate use of available land in accessible and sustainable locations. However, it is also important to create high quality environments with sufficient public open space, parking and other amenities to promote good quality of life for new and existing communities.
The density of new developments must be in keeping with the existing community to help create a cohesive community. If a new development or redevelopment is significantly more compact than that of an existing community it will create an us and them divide. So why not include existing community density ?

Q.132
P.13
Planning Policy Statement 3 (PPS3 - Housing) provides guidance on the provision of high quality, sustainable housing,
Whose document is PPS3 ? Which version and publication date ? Where can it be found ?

Q.133
P.13
Planning Policy Statement 3 (PPS3 - Housing) provides guidance on the provision of high quality, sustainable housing, with a mix of housing tenures which reflects local needs, ensuring the effective use of existing housing stock, and providing enough homes in appropriate locations through the effective and efficient use of land. It gives the Local Planning Authority flexibility in setting appropriate densities to specific localities, through encouraging a minimum density of 30 dwellings per hectare as a national minimum standard to ensure that available land is appropriately utilised.
PPS3 according to your statement only provides guidance and not rules so yes it will provide flexibility because nothing has to be complied with, so what is the point of adding this here ?
I am more interested in what the rules are, set by the LPA. Because the PPS3 is only guiding them they can be totally ignored ? The council must identify what must be complied with by the LPA and state that here as a list.

Q.134
P.13
Density can impact on the character and form of development, and as such, we will maintain a flexible approach towards the appropriate density of new developments to reflect the individual identities of each area.
I do not believe this is a satisfactory approach, there has to be a minimum and maximum benchmark otherwise you are saying anything can be built.

Q.135
P.13
It is recognised in the emerging Core Strategy, however
that some locations are more sustainable in terms of infrastructure and amenities, and can thus accommodate higher density development.
Where in the core strategy ? What locations ? How are they identified.

Q.136
P.13
We therefore do not seek to be overly prescriptive with regard to density but will encourage appropriate densities which reflect the character, scale and form of the locality to create cohesive, sustainable environments.
Why do you use words like prescriptive that are not known or used in everyday conversation. Know your audience for effective communication !
What are you saying, you do not want to lay down rules relating to density ?Say so.
If this is the case why are you writing a page on it ?
. I would argue that the density of a development will have an effect on the community and therefore must be governed by rules and regulations.

Q.137
P.13
The precise density for any individual site will be determined by its immediate context, on-site constraints, the type of development proposed and the need to provide an appropriate mix of dwellings to meet the community's needs.
Please define what community District's, Village/ Town, County etc.,
It was my understanding that the allocation set by the East of England were to address the shortage of housing for the population of U.K. And not specific to Rochford.
If it is Rochford, then were are the figures, analysis showing what the demand is etc., ?

Q.138
P.13
The precise density for any individual site will be determined by its immediate context, on-site constraints, the type of development proposed and the need to provide an appropriate mix of dwellings to meet the community's needs.
What is meant by "immediate context" ?

Q.139
P.13
The precise density for any individual site will be determined by its immediate context, on-site constraints, the type of development proposed and the need to provide an appropriate mix of dwellings to meet the community's needs.
What are the "types of development " ?

Q.140
P.13
The precise density for any individual site will be determined by its immediate context, on-site constraints, the type of development proposed and the need to provide an appropriate mix of dwellings to meet the community's needs.
The statement by using the words "precise density" means that the density will decided dependent upon an agreed measurement for :- immediate context, on-site constraints and type of development, so what are the agreed measurements.?

Q.141
P.14
DM2
Option: Prescriptive density.
You are selective in what the density relates to in why it is not preferred I.e, District so maybe this must say Prescriptive density for the District.
Most of your discussion in this section has been focused on communities and site/ locations so why not prescriptive density for them ?

Q.142
P.14
DM2
Option:Higher minimum density to help deliver greater quantums of housing.
Isn't Quantums jargon ? What does it mean ?

Q.143
P.14
Infilling can be defined as filling the small gaps between existing groups of dwellings with new development.
At last a definition ! Shame it uses small gaps which is not defined ? What defines a small gap. If you create a classification like infilling then you must make precise and clear definitions.
Can you also clarify whether majority of infilling sites are on Green Belt land ?

Q.144
P.14
We consider the limited infilling of existing settlements to be acceptable where the development conforms to the existing street pattern and density of the immediate locality.
Are you saying " There are a limited number of infilling opportunities between existing settlements and you find it acceptable to use these where the development ...... ?

Q.145
P.14
We consider the limited infilling of existing settlements to be acceptable where the development conforms to the existing street pattern and density of the immediate locality.
Why are infilling developments different to new developments ?
Why do they not have to comply with regulations, considerations of new developments ?
Are existing street pattern and density of immediate location the only criteria considered ? There must be a lot more like those identified in DM1 preferred Option. Why are they not relevant ?

Q.146
P.14
We will also permit an appropriate level of residential intensification within town centre areas where permitted densities are higher due to their sustainable locations, which will help safeguard Green Belt land in the District.
What is an appropriate level ?

Q.147
P.14
However, the appropriateness of infilling in residential areas will be determined on a case by case basis primarily having regard to residential intensification, 'town cramming' and the impact on the character of the streetscene.
Isn't "town cramming" jargon ? What does it mean ?

Q.148
P.14
However, the appropriateness of infilling in residential areas will be determined on a case by case basis primarily having regard to residential intensification, 'town cramming' and the impact on the character of the streetscene.
See question 75.

Q.149
P.14
However, the appropriateness of infilling in residential areas will be determined on a case by case basis primarily having regard to residential intensification, 'town cramming' and the impact on the character of the streetscene.
You state "primarily having regard to residential intensification", so what other things will be used ?

Q.150
P.14
A restrictive approach is appropriate as infilling and residential intensification can have a negative impact on the amenity and character of settlements, and lead to increased traffic generation, and 'town cramming'.
See question 147

Q.151
P.14
A restrictive approach is appropriate as infilling and residential intensification can have a negative impact on the amenity and character of settlements, and lead to increased traffic generation, and 'town cramming'.
What about Village cramming ? The same as town cramming except for a smaller community classified as a village.

Q.152
P.14
A restrictive approach is appropriate as infilling and residential intensification can have a negative impact on the amenity and character of settlements, and lead to increased traffic generation, and 'town cramming'.
Any development on the scale captured in the Core Strategy will naturally lead to increased traffic generation. Main roads in and around towns were built to withstand heavy traffic whilst roads through villages were not. Therefore a town must be able to cope with the increase better than that of villages. Having said this there is nothing in this document that reflects that the development of new houses etc., needs to be reviewed at district and county level, perhaps the answer to the increase in traffic is town and village bye passes or more relevant improving the A127 ?

Q.153
P.15
DM3
Why are infilling, residential intensification and "backland" developments different to new developments ?
Why do they not have to comply with regulations, considerations of new developments ?
Are the criteria shown specific to these types of development ? If not please use the same term to create commonality and association.

Q.154
P.15
DM3
ii). the number and type of dwellings being proposed are appropriate to the locality;
What specific criteria do you use to decide whether something is appropriate ?

Q.155
P.15
DM3
iii). the contribution to housing need, taking into account the advice and guidance of the Housing Strategy Team;
Whose Housing and strategy Team ?

Q.156
P.15
DM3
an assessment of the proposal's impact on residential amenity;
Who will perform and deliver the assessment and using what specific criteria ?

Q.157
P.15
DM
vi). the loss of private amenity space for neighbouring dwellings;
vii). the adequate provision of private amenity space for the proposed dwelling as set out in Supplementary Planning Document 2: Housing Design; and
Wouldn't vii) cover vi) ?

Q.158
P.16
The habitable floorspace of a dwelling is considered by the Council as encompassing the floor area covered by any bedrooms, living rooms, dining rooms, kitchens and spare rooms which are used for these purposes.
Is there an existing definition of Habitable floorspace by Government bodies, Organizations or Essex County Council that can dictate to RDC about floorspace requirements, if so then that is what must be used. That way compliance is easy, if the measurement is not the same recalculation will have to be done each time. ?

Q.159
P.16
Dwellings, whether comprising housing or flats, which are market or affordable, should be of an appropriate size and layout to provide suitable and comfortable accommodation for modern living.
Who makes the decision whether something is of an appropriate size and layout ? What criteria do they use to make that decision ?

Q.160
P.16
Dwellings, whether comprising housing or flats, which are market or affordable, should be of an appropriate size and layout to provide suitable and comfortable accommodation for modern living.
What is modern living ? Why is this stated, what clarification does it bring to the statement ?

Q.161
P.16
Dwelling size must be proportionate and sufficient to meet the needs of the potential number of inhabitants and all habitable rooms must have an adequate size, height, and shape, with plentiful natural lighting and ventilation.
From whom does the potential number of inhabitants come from ?

Q.162
P.16
Dwelling size must be proportionate and sufficient to meet the needs of the potential number of inhabitants and all habitable rooms must have an adequate size, height, and shape, with plentiful natural lighting and ventilation.
What defines adequate size, floorspace, cubic metres, total wall space etc.,?


Q.163
P.16
Dwelling size must be proportionate and sufficient to meet the needs of the potential number of inhabitants and all habitable rooms must have an adequate size, height, and shape, with plentiful natural lighting and ventilation.
What defines adequate height, height above tallest family members head, % of floorspace etc., ?

Q.164
P.16
Dwelling size must be proportionate and sufficient to meet the needs of the potential number of inhabitants and all habitable rooms must have an adequate size, height, and shape, with plentiful natural lighting and ventilation.
What defines plentiful natural light, an light meter reading in middle of room, Size of windows in relation to room size etc., ?

Q.165
P.16
An adequate dwelling size can also increase the adaptability and flexibility of the District's housing stock, accommodate features of the Lifetimes Homes Standard and give greater choice, whilst supporting the needs of the population.
What version of the Lifetime Homes Standard ?

Q.166
P.16
An adequate dwelling size can also increase the adaptability and flexibility of the District's housing stock, accommodate features of the Lifetimes Homes Standard and give greater choice, whilst supporting the needs of the population.
What features, identify and cross reference if they are to be incorporated ?

Q.167
P.16
The internal floor area of a dwelling should comply with the minimum guidance standards set by the Homes and Communities Agency2
What is the purpose of this statement if you use the word should. There will be no commitment from a developer unless this states must instead of should. Nice to see a cross reference in a footnote.

Q.168
P.16
The Agency use Housing Quality Indicators (HQIs) to measure the quality of housing schemes funded through the National Affordable Housing Programme, however,
these indicators score the internal dwelling area by bedspace rather than number of bedrooms, which from a development management perspective is considered to be impractical to implement.
So does that mean you will not use them ?
What is the impact of not using them ? Will the council still obtaining funding for affordable housing ?
Why can HQI's not be used?

Q.169
P.16
The Agency use Housing Quality Indicators (HQIs) to measure the quality of housing schemes funded through the National Affordable Housing Programme, however,
these indicators score the internal dwelling area by bedspace rather than number of bedrooms, which from a development management perspective is considered to be impractical to implement.
What is the National Affordable Housing Programme ? How does it relate to yourselves and Homes and Communities Agency ?

Q.170
P.16
As such other standards have been sought, by number of bedrooms, which would meet the Homes and Communities Agency's requirements. In 2007,
English Partnerships (which is now part of the Homes and Communities Agency) produced a quality standards document3 which identified minimum internal floor areas according to the number of bedrooms and occupancy.
Who are the Homes and Communities Agency ? What relationship do they have to :-
Rochford District Council,

Q.170
P.16
As such other standards have been sought, by number of bedrooms, which would meet the Homes and Communities Agency's requirements. In 2007,
English Partnerships (which is now part of the Homes and Communities Agency) produced a quality standards document3 which identified minimum internal floor areas according to the number of bedrooms and occupancy.
So are you saying that HCA will accept as part of your submission that a HQI for bedspace can be replaced by number of bedrooms ? Looking at the HQI calculator, you have to provide no of beds and types which for me is important. e.g. You could allow a 3 bedroom property but all three bedrooms can only hold a single bed which is no good for a married couple with two children. So without the bedspace requirement you can not prove the property is "adaptable and flexible".
If you want to use on the number of bedrooms I feel you are not proving that the property is adaptable and flexible.?

Q.171
P.16
As such other standards have been sought, by number of bedrooms, which would meet the Homes and Communities Agency's requirements. In 2007,
English Partnerships (which is now part of the Homes and Communities Agency) produced a quality standards document3 which identified minimum internal floor areas according to the number of bedrooms and occupancy.
If the English partnership produced a document back in 2007 and they are now part of the HCA this does not mean that the HCA have adopted their standards. If the HCA have adopted their standards would they not add / amend the HQI's accordingly ?

Q.172
P.16
Table 1
What is the point of Table 1

Q.173
P.16
It is possible, not to mention desirable in respect of implementation, to translate standards relative to bedspaces into standards relative to number of bedrooms.
I'm sorry maybe its the punctuation, but I am not clear what is being said, is it :- It is possible to convert the standards of English Partnership and HCA into each other.
If this is the case you are not demonstrating clearly how this is achieved or whether you have the approval of the conversion by the HCA ?

Q.174
P.16
Both market and affordable housing should aspire to meet minimum approved standards for internal floor area. Each dwelling should comply with the minimum acceptable floorspace standards as defined below in Table 2.
Why aspire ?
Whose minimum approved standards: RDC , HCA etc.,
Why should and not must ?

Q.175
P.16
Table 2
Minimum Internal Floor Area. Can you please clarify if this is a bedroom size, total floor space of the development etc., ?

Q.175
P.16
In addition to the minimum floorpsace standards above, all habitable rooms should have a minimum floor to ceiling height of 2.5 metres4 (8.2 feet) and be of an appropriate width to accommodate their proposed uses/function.
What are the proposed uses/function ? Is there defined categories ?
Why do you define the height and not the width ?
What is an appropriate width for each function / use ?
Why should and not must ?

Q.176
P.16
All non-habitable rooms should have adequate size, height and shape, with sufficient natural lighting, and be ventilated directly by external air via a window.
Could you provide an example of a non-habitable room ?
Could a cellar be one ? How do you define adequate size, height and shape. Adequate for what ?

Q.177
P.16
Therefore we will not only have regard to whether the minimum standard has been applied to all dwellings within the development, but will also determine if the internal layout is appropriate and fit for purpose.
Whose minimum standards ?
Where are they captured ?
How will you determine if internal layout is fit for purpose ?#
How will you determine if internal layout is appropriate ?

Q.178
P.16
DM4
What is definition of modern living ? What other types of living are there ?

Q.179
P.17
It is important that the Local Planning Authority ensures not only an appropriate quantity of dwellings, but also that dwellings are of a sufficient quality.
How can you ensure something when you are not making things mandatory with the use of the word should instead of must ?

Q.180
Why is there very little about the standards required of redevelopment. Why is everything about new development ?

Q.181
P.19
Light pollution can take several forms including:
? Sky glow - the glow seen above urban areas caused by stray artificial light being
scattered by dust particles and water droplets in the sky.
? Glare - the uncomfortable brightness of a light source when viewed against a darker
background.
? Light trespass - light spilling beyond an area intended to be lit.
Is this a comprehensive list if not you should state , for example.
Why don't you use the same as that documented on the environmental protection organization refer :
http://www.environmental-protection.org.uk/neighbourhood-nuisance/light-pollution/#wa762
What is light pollution?
Light pollution is probably best described as artificial light that is allowed to illuminate, or intrude upon, areas not intended to be lit.
Intrusive Light
This is the intrusion of over bright or poorly directed lights onto neighbouring property, which affect the neighbours' right to enjoy their own property. A typical example would be an inconsiderately directed security light shining into a bedroom window.

Skyglow

Skyglow is the orange glow seen over towns and roads from upward light. This is a serious problem for astronomers as the artificial brightness of the sky overpowers distant stars, especially those low in the night sky. It is becoming more and more difficult to find areas where our view of the night sky is unaffected by illumination. The light from distant stars can take hundreds, even thousands, of years to reach our eyes - so it is a pity to lose it on the last moment of its journey!

Poor Lighting

Inconsiderate or incorrectly set lighting can have other effects:
* It produces glare which occurs when the over brightness of a light source against a dark background interferes with a person's ability to view an area or object, i.e. glare can conceal rather than reveal.
* It can detract from the architectural appearance of a building and even hide complex or attractive features.
* It can impact on the ecology and wildlife of an area, and affect the behavioural patterns of mammals, birds, insects and fish.
The wasting of light is a waste of the energy which powers the light and is therefore a waste of resources and money.


Q.182
P.19
There is a need to minimise the adverse impacts of illumination by avoiding unnecessary
lighting, ensuring the level of lighting in new developments (including roads) is the minimum
necessary for public safety, is energy efficient and respects the character of the locality. In
some cases, full horizontal cut-off (the prevention of light spillage into adjoining areas) and
other forms of containment of the light source may be required to prevent spillage and glare.
Why don't you use the same wording as listed on the environmental protection organization website:-
refer
http://www.environmental-protection.org.uk/neighbourhood-nuisance/light-pollution/#wa762
How to prevent light pollution
Before going to the expense and effort of installing lighting a few simple questions should be asked:
* Is lighting necessary?
* Could safety or security be achieved by other measures, such as segregation or screening of an area?
* Do the lights have to be on all night? For example, over advertising hoardings; the exterior of buildings or empty car parks.
* If lighting is the best option then only the right amount of light for the task should be installed. Lighting will then only become a problem if it is poorly designed or incorrectly installed.
If lighting is necessary, a number of measures can be taken to avoid causing a nuisance:
* For domestic security lights a 150W lamp is adequate. High power (300/500W) lamps create too much glare reducing security. For an all-night porch light a 9W lamp is more than adequate in most situations.
* Make sure that lights are correctly adjusted so that they only illuminate the surface intended and do not throw light onto neighbouring property. Security lights should be correctly adjusted so that they only pick up the movement of persons in the area intended and not beyond.
* To reduce the effects of glare main beam angles of all lights should be below 70 degrees.
* Direct light downwards. If uplighting has to be used then install shields or baffles above the lamp to reduce the amount of wasted upward light.
Do not install equipment which spreads light above the horizontal

Q.183
P.19
Details of any lighting scheme required as part of any new development must be submitted as part of the planning application.
So is the lighting requirements not relevant to redevelopments ? If not surely this is a missed opportunity to improve existing poor lighting ?

Q.184
P.20
Where environmental improvements are to be encouraged, especially in the District's Conservation Areas, and other town and village centres,
What is meant by other town and village centres.? There has been no mention in this sentence about any town or village ?

Q.185
P.20
The siting of substantial masts, which are essential to the operations of the various mobile phone companies, must be carried out with great care to ensure that sensitive areas do not suffer a loss of residential or visual amenity.
Please define substantial masts ?

Q.186
P.20
The siting of substantial masts, which are essential to the operations of the various mobile phone companies, must be carried out with great care to ensure that sensitive areas do not suffer a loss of residential or visual amenity.
Please define sensitive areas ?

Q.187
P.20
The siting of substantial masts, which are essential to the operations of the various mobile phone companies, must be carried out with great care to ensure that sensitive areas do not suffer a loss of residential or visual amenity.
Please define loss of residential or visual amenity ?

Q.188
P.20
Regard must be had however, to the limitations imposed by the nature of the telecommunications network and the technology that can constrain operators' choice of sites.
Surely the decision should be with the community. If the community do not want improved telecommunications over what they have today, they should be able to say no to masts.
There must be a question on whether the improvement is needed by the community. The telecommunications companies must provide proof that the majority of residents have requested the improvement. If the telecommunications improvement is required to support emergency services then this must be factored into the evaluation.

Q.189
P.20
Where the erection of a mast requires planning permission, their siting should be avoided in the sensitive areas of the District, as appropriate. These areas include Sites of Special Scientific Interest (SSSIs), the Coastal Protection Belt, Conservation Areas, Ancient Woodland, Special Areas of Conservation (SACs), Special Landscape Areas (SLAs) and the Upper Roach Valley.
Why should and not must ?
Perhaps the most important place where a mast should not be erected is in the middle of a village community, near a school, public meeting place etc.,

Q.190
P.20
Furthermore, there is a clear need to ensure communication between the different companies to avoid the need for the erection of duplicate masts.
I presume you mean Telecommunication companies ? Why not state that to provide clarity. ?

Q.191
P.21
if sited in an undesirable location (including Sites of Special Scientific Interest (SSSIs), the Coastal Protection Belt, Conservation Areas, Ancient Woodland,
Special Areas of Conservation (SACs), Special Landscape Areas (SLAs) and the Upper Roach Valley), it has been clearly demonstrated that there are no suitable alternative sites for the development of telecommunications systems available in the locality, the development is essential, it is to the benefit of the local community and it would not have a negative impact on local landscape character. Such evidence should accompany any application made and should be to the Council's satisfaction;
Please refer to questions 185-190.
I would replace "it is to the benefit of the local community" with "it is to the benefit and is requested by the local community" That way there will be no opposition and the community will feel happier and content.?
I would also amend "to the Council's satisfaction" to be "to the Council's and local community's satisfaction. "
Why can the community not have a say through their Parish Council and Council recognised Action Groups

Q.192
P.21
When considering applications for telecommunications development, we will have regard to the operational requirements of telecommunications networks and the technical limitations of the technology.
I do not believe the council will have the amount of detailed knowledge about the telecommunications development to make a sound judgement on operational requirements and technical limitations of the technology so I believe they must consult a specialist in that field that is not connected to any telecommunications company who has or potentially will make presentation for development. Do you agree ? This is an alternative that you appear not to have seen ?
The cost of this consultation should be handed over to the proposer to pay.

Q.193
Could you tell me what provisions you have made to accommodate a person who is blind and without a computer to respond to your documents in private ?

Q.194
Could you also tell me what provisions you have made to accommodate a person who has lost the use of their hands to respond to your documents in private ?

Q.195
This document focuses primarily on New developments.
Why not also redevelopments ?
Why are redevelopments not the same as new developments with regard to Design, Density,Infilling, Habitable Floorspace etc., ?

Q.196
Who has prepared this document. ?
Who has proof read it ?
Who has reviewed it so far ?
What version is this ?
What has changed as a result of the proof reading and review?

Q.197
Insurance companies like Avivia are constantly re-assessing the risks on houses around the country. Only recently I have been informed they published some maps showing the flood risk of surface water. It is these types of surveys that determine the risk levels and these are then reflected in the premiums of the householders. Do you not think it prudent to include into your Management process that you must also involve their surveys and their experts in evaluating the risks on any development over 50 houses and so ? If the Insurance companies consider a site a risk this means affordable housing or not the premiums will be higher than elsewhere, which will impact the residents in existing and new additions to a community.
If you do not agree could you please explain why?

Q.198
It would make life simpler for me as a reader if you had a single point in this document listing all publications that have been used in making it and where they can be found, could you arrange for that please ?

Response of Essex County Council

Essex County Council supports the production of a Development Management DPD by Rochford District Council. By setting out detailed planning policies for the management of development the DPD will positively assist realisation of the District's Core Strategy. In this respect the linking of the DPD directly to the Vision and the four main corporate objectives for the District is welcomed.

The scope and coverage of the proposed Development Management policies is broadly supported but could benefit from some detailed textual changes to the Policies and their supporting text (as set out below) to reflect,

* the creation of safe direct walking and cycling routes to schools and other community facilities by inclusion of an additional section of supporting text together with an additional policy. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section;
* the acknowledgment of the value and role of the Historic Environment by the Document should be more appropriately integrated within proposed Policy DM1 and Policy DM13 and the objectives for Environmental Issues;
* the proactive role that the District Council and partners are taking to the Green Belt, for example the positive approach that will result from improving access to the Upper Roach Valley and to Wallasea Island. Also, Renaissance Southend and Southend-on-Sea Borough Council, with partners including the County Council and the District Council, are actively promoting Stonebridge Park as a sub-regional greenspace project. The project would create major greenspaces and access improvements, including restoration of some existing and old landfills and utilizing the old haul roads for cycling and bridleways. This represents a major partnership opportunity for Rochford to create a substantial sub-regional park in the District. Further, the supporting text should refer to the recently announced initiative for a Coastal Path, to run the length of the English Coast, being led by Natural England, which presents a considerable opportunity for Rochford to create a major green attraction along the District's extensive coastline. Additional supporting text for Policy DM13 and to the vision and objectives for the Green Belt and Countryside is suggested;
* creation of an attractive and pleasant environment can support an improved retail offer and thereby assist enhancement of use of town centres by addition to the objectives for Retail and Town Centres;.
* the potential access issues raised by some forms of advertising, for instance advertising boards, (insofar as they can be subject to development management policies) by addition to Policy DM32 and Policy DM33 and their supporting text;
* the full scope of Essex County Council's 'Parking Standards: Design and Good Practice (2009)' by additions to the supporting text for Policy DM25;
* additional relevant sub-regional and county strategy documents.

In addition, Figure 1 is useful in setting out the types of documents which will comprise the Development Plan for Rochford. However, for completeness and for the benefit of users of the Development Plan it would be useful if all Development Plan Documents and Supplementary Planning Documents were listed by name. A brief description of their purpose and content would aid understanding of their relevance in consideration of particular planning proposals, topics and issues.

Suggested detailed textual changes to the Policies and their supporting text are,

A. Figure 1 - Additional description of Figure 1 to aid understanding of the relevance documents within the Local Development Framework in consideration of particular planning proposals, topics and issues;

B. Relationship to other strategies - additional relevant strategies to be referenced,
* Sub-regional strategies - 'Thames Gateway Parklands Vision 2008'
* County strategies -
o Developers' Guide to Infrastructure Contributions.
o Parking Standards Design and Good Practice
o Highways and Transport Development Management Policies

C. Policy DM1 Design of New Developments - amend criteria i), ii) and vi) to read,
i) accessibility by all forms of transport;
ii) boundary treatment and landscaping within the development;
vi) impact on the historic environment including designated sites, Conservation Areas, Listed Buildings, archaeological sites and the historic landscape;

The supporting text for Policy DM1 should be augmented to emphasise the role of the wider historic environment, including archaeological sites and historic landscapes.

D. Green Belt and Countryside
* The vision should be expanded by addition of the following,
o In five years - add three additional bullets to read,
- 'New Strategies for the Upper Roach countryside area and Stonebridge Park, around Great Wakering'
- 'New Visitor Facilities at RSPB Wallasea Island'
- 'A plan is developed of the line of the Coastal Path, showing how it runs through Rochford, connecting Burnham-on Crouch to Southend'
o By 2017 - add an additional bullet to read,
- 'Completion of the Coastal Path connecting Burnham-on Crouch to Southend'
o By 2025 - add two additional bullets to read,
- 'If appropriate, new Visitor facilities at Stonebridge Park and the Upper Crouch'
- 'Rochford is recognised as a tourist destination, with good access to the rivers and waterways and many visitors to the nationally recognised wetlands at Wallasea, the sub regional greenspaces located at the Upper Crouch and Stonebridge Park, and the Coastal Path'

* The Objectives should be expanded by addition of two additional objectives,
o 'Ensure the Green Belt includes positive appropriate activities such as countryside recreation, education, nature study etc'
o 'Aid the delivery of greenspaces identified in the Thames Gateway Green Grid Strategy and the Parklands Vision, alongside Essex County Council and neighbouring authorities'

* A further criterion should be added to the first paragraph of Policy DM13 (Green Tourism) to read 'the impact on the historic environment'.

* The supporting text to Policy DM13 (Green Tourism) should be expanded by addition of,
o A paragraph to read, 'Green Tourism should benefit the residents of Rochford and South Essex. Opening up the countryside of the Upper Roach Valley, Wallasea Island and the proposed Stonebridge Park will enable visitors increased access to the countryside, education facilities, improved health, new jobs and opportunities in new facilities and existing businesses. Furthermore it would elevate Rochford's reputation as a tourist destination.'
o text to note that the impact of tourism opportunities on the historic environment is as important as that on the natural environment.

E. Environmental Issues - the vision should be expanded by,
o in 5 years - add the words 'and historic environment' to the third bullet so that it reads 'Local, national and international sites of nature conservation and historic environment importance are protected.'
o By 2017 - add an additional bullet to read 'the local, national and international sites of historic environment importance are being increasingly protected, promoted and enhanced'.

F. Transport - the supporting text should be expanded to note,
* Essex County Council is the local highway authority and has a set of Development Management policies for the highways and transport aspects of development.
* the supporting text to Policy DM25 should note that Essex County Council's 'Parking Standards: Design and Good Practice (2009)' includes guidance related not only to private cars but also to 'Blue Badge' users, cyclists, motorcyclists and commercial vehicles.

G. Retail and Town Centres - include an additional objective to read, 'Improve the public realm of the Town Centres and village and neighbourhood centres by implementing landscape and access schemes which include street trees to provide urban greening'

H. Advertisements in the District
* In Policy DM32 - the first sentence should be amended by insertion of the words 'access and' to read, 'The design and siting of advertisements throughout the District must have regard to access and the visual impact of the building(s)...'
* In Policy DM33 - the second sentence should be amended by insertion of the words 'not cause an access problem,' to read '... and should be sensitive to the character of the area, visually unobtrusive, not cause an access problem, well designed and well located.'
* The first paragraph of the supporting text should be amended by insertion of the word 'access' to read '...is not detrimental to the access, appearance or value of a particular streetscape or buildings(s).'
* Additional supporting text should note that some forms of advertising, for instance, advertising boards can cause uncontrolled clutter which tends to restrict and obstruct access and provide tripping obstacles for people who are blind or partially sighted.

I. Safe Walking and Cycling Routes
The Document would benefit from an additional section of supporting text together with an additional policy that specifically addresses the creation of safe direct walking and cycling routes to schools and other community facilities. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

Response of Essex County Council

Essex County Council supports the production of a Development Management DPD by Rochford District Council. By setting out detailed planning policies for the management of development the DPD will positively assist realisation of the District's Core Strategy. In this respect the linking of the DPD directly to the Vision and the four main corporate objectives for the District is welcomed.

The scope and coverage of the proposed Development Management policies is broadly supported but could benefit from some detailed textual changes to the Policies and their supporting text (as set out below) to reflect,

* the creation of safe direct walking and cycling routes to schools and other community facilities by inclusion of an additional section of supporting text together with an additional policy. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section;
* the acknowledgment of the value and role of the Historic Environment by the Document should be more appropriately integrated within proposed Policy DM1 and Policy DM13 and the objectives for Environmental Issues;
* the proactive role that the District Council and partners are taking to the Green Belt, for example the positive approach that will result from improving access to the Upper Roach Valley and to Wallasea Island. Also, Renaissance Southend and Southend-on-Sea Borough Council, with partners including the County Council and the District Council, are actively promoting Stonebridge Park as a sub-regional greenspace project. The project would create major greenspaces and access improvements, including restoration of some existing and old landfills and utilizing the old haul roads for cycling and bridleways. This represents a major partnership opportunity for Rochford to create a substantial sub-regional park in the District. Further, the supporting text should refer to the recently announced initiative for a Coastal Path, to run the length of the English Coast, being led by Natural England, which presents a considerable opportunity for Rochford to create a major green attraction along the District's extensive coastline. Additional supporting text for Policy DM13 and to the vision and objectives for the Green Belt and Countryside is suggested;
* creation of an attractive and pleasant environment can support an improved retail offer and thereby assist enhancement of use of town centres by addition to the objectives for Retail and Town Centres;.
* the potential access issues raised by some forms of advertising, for instance advertising boards, (insofar as they can be subject to development management policies) by addition to Policy DM32 and Policy DM33 and their supporting text;
* the full scope of Essex County Council's 'Parking Standards: Design and Good Practice (2009)' by additions to the supporting text for Policy DM25;
* additional relevant sub-regional and county strategy documents.

In addition, Figure 1 is useful in setting out the types of documents which will comprise the Development Plan for Rochford. However, for completeness and for the benefit of users of the Development Plan it would be useful if all Development Plan Documents and Supplementary Planning Documents were listed by name. A brief description of their purpose and content would aid understanding of their relevance in consideration of particular planning proposals, topics and issues.

Suggested detailed textual changes to the Policies and their supporting text are,

A. Figure 1 - Additional description of Figure 1 to aid understanding of the relevance documents within the Local Development Framework in consideration of particular planning proposals, topics and issues;

B. Relationship to other strategies - additional relevant strategies to be referenced,
* Sub-regional strategies - 'Thames Gateway Parklands Vision 2008'
* County strategies -
o Developers' Guide to Infrastructure Contributions.
o Parking Standards Design and Good Practice
o Highways and Transport Development Management Policies

C. Policy DM1 Design of New Developments - amend criteria i), ii) and vi) to read,
i) accessibility by all forms of transport;
ii) boundary treatment and landscaping within the development;
vi) impact on the historic environment including designated sites, Conservation Areas, Listed Buildings, archaeological sites and the historic landscape;

The supporting text for Policy DM1 should be augmented to emphasise the role of the wider historic environment, including archaeological sites and historic landscapes.

D. Green Belt and Countryside
* The vision should be expanded by addition of the following,
o In five years - add three additional bullets to read,
- 'New Strategies for the Upper Roach countryside area and Stonebridge Park, around Great Wakering'
- 'New Visitor Facilities at RSPB Wallasea Island'
- 'A plan is developed of the line of the Coastal Path, showing how it runs through Rochford, connecting Burnham-on Crouch to Southend'
o By 2017 - add an additional bullet to read,
- 'Completion of the Coastal Path connecting Burnham-on Crouch to Southend'
o By 2025 - add two additional bullets to read,
- 'If appropriate, new Visitor facilities at Stonebridge Park and the Upper Crouch'
- 'Rochford is recognised as a tourist destination, with good access to the rivers and waterways and many visitors to the nationally recognised wetlands at Wallasea, the sub regional greenspaces located at the Upper Crouch and Stonebridge Park, and the Coastal Path'

* The Objectives should be expanded by addition of two additional objectives,
o 'Ensure the Green Belt includes positive appropriate activities such as countryside recreation, education, nature study etc'
o 'Aid the delivery of greenspaces identified in the Thames Gateway Green Grid Strategy and the Parklands Vision, alongside Essex County Council and neighbouring authorities'

* A further criterion should be added to the first paragraph of Policy DM13 (Green Tourism) to read 'the impact on the historic environment'.

* The supporting text to Policy DM13 (Green Tourism) should be expanded by addition of,
o A paragraph to read, 'Green Tourism should benefit the residents of Rochford and South Essex. Opening up the countryside of the Upper Roach Valley, Wallasea Island and the proposed Stonebridge Park will enable visitors increased access to the countryside, education facilities, improved health, new jobs and opportunities in new facilities and existing businesses. Furthermore it would elevate Rochford's reputation as a tourist destination.'
o text to note that the impact of tourism opportunities on the historic environment is as important as that on the natural environment.

E. Environmental Issues - the vision should be expanded by,
o in 5 years - add the words 'and historic environment' to the third bullet so that it reads 'Local, national and international sites of nature conservation and historic environment importance are protected.'
o By 2017 - add an additional bullet to read 'the local, national and international sites of historic environment importance are being increasingly protected, promoted and enhanced'.

F. Transport - the supporting text should be expanded to note,
* Essex County Council is the local highway authority and has a set of Development Management policies for the highways and transport aspects of development.
* the supporting text to Policy DM25 should note that Essex County Council's 'Parking Standards: Design and Good Practice (2009)' includes guidance related not only to private cars but also to 'Blue Badge' users, cyclists, motorcyclists and commercial vehicles.

G. Retail and Town Centres - include an additional objective to read, 'Improve the public realm of the Town Centres and village and neighbourhood centres by implementing landscape and access schemes which include street trees to provide urban greening'

H. Advertisements in the District
* In Policy DM32 - the first sentence should be amended by insertion of the words 'access and' to read, 'The design and siting of advertisements throughout the District must have regard to access and the visual impact of the building(s)...'
* In Policy DM33 - the second sentence should be amended by insertion of the words 'not cause an access problem,' to read '... and should be sensitive to the character of the area, visually unobtrusive, not cause an access problem, well designed and well located.'
* The first paragraph of the supporting text should be amended by insertion of the word 'access' to read '...is not detrimental to the access, appearance or value of a particular streetscape or buildings(s).'
* Additional supporting text should note that some forms of advertising, for instance, advertising boards can cause uncontrolled clutter which tends to restrict and obstruct access and provide tripping obstacles for people who are blind or partially sighted.

I. Safe Walking and Cycling Routes
The Document would benefit from an additional section of supporting text together with an additional policy that specifically addresses the creation of safe direct walking and cycling routes to schools and other community facilities. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

1. Introduction

1.1 On 17 March 2010 Rochford District Council wrote to the East of England Regional Assembly to notify them of publication of its Development Management Development Plan Document (DPD) Discussion and Consultation Document under Regulation 25 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008.

1.2 The purpose of this DPD is to augment the Rochford Core Strategy by setting out a number of additional (preferred option) policies against which planning applications will be determined. These policies are grouped under six headings: Housing, Character of Place & Residential Amentity; The Green Belt and Countryside; Environmental Issues; Transport; Economic Development; and Retail & Town Centres. The Council anticipates that a final version of the document will be submitted to the Secretary of State for approval in early 2011.

1.3 With the enactment of the Local Government, Economic Development and Construction Act 2009 and the Consequential Amendments (SI 2010/602), local planning authorities outside London do not have to make a request seeking the opinion from the Regional Planning Body. Instead, the local planning authority must consult with the Responsible Regional Authority. When acting jointly with the Regional Development Agency (EEDA), The East of England Local Government Association is one of the Responsible Regional Authorities (RRAs) charged with keeping the regional strategy under review. Government guidance (CLG (2010) Policy Statement on Regional Strategies) also directs the RRAs to actively engage with local authorities to promote the implementation of the Regional Strategy.

1.4 The East of The East of England Regional Assembly was dissolved on 31 March 2010 and the requirement to seek its opinion was removed. With the transition to the new regulatory framework, consultations made to the Assembly are being taken forward by the East of England Local Government Association.

1.5 The closing date for commenting on this DPD is 30 April 2010. Further details can be found at:
http://www.rochford.gov.uk/planning/policy/local_development_framework/development_management_develop.aspx

2. Background

2.1 The district of Rochford covers an area of 168 sq. km's (65 sq. miles). Situated on a peninsula between the River Thames and River Crouch, it is bounded to the east by the North Sea, shares marine boundaries with Maldon and Chelmsford, and land boundaries with Basildon, Castle Point and Southend. The A127 and A130 provide road links to the M25, and rail services operate into London Liverpool Street. London Southend Airport is located along the southern boundary with the borough of Southend-on-Sea.

2.2 The district has a noticeable east-west divide, with the majority of its residents living in the west in the three main urban areas of Rochford, Rayleigh and Hockley. A significant proportion of the workforce, estimated at 68%, works beyond the district boundary, with Southend exerting a particularly strong influence. Approximately 75% of the district is designated as Metropolitan Green Belt.

3. Planning Guidance

3.1 Regional planning guidance for Rochford is set out in the East of England Plan (May 2008) and the remaining saved policies of the Essex & Southend-on-Sea Structure Plan. The former requires Rochford to deliver a minimum 4,600 new homes and contribute 3,000 new jobs (as part of a wider Essex Thames Gateway policy area target of 55,000 new jobs) during the plan period 2001 - 2021.

3.2 Rochford's Core Strategy was submitted to the Secretary of State for approval in January 2010. An Examination in Public is due to commence in May 2010. The Core Strategy, which sets out the strategic spatial planning framework for the district to 2025, was found to be in general conformity with the East of England Plan following discussion of a report presented to the Regional Assembly's Standing Committee in October 2009.

4. Comments

4.1 Rochford District Council's Development Management DPD Discussion and Consultation document provides detailed guidance on a range of specific policy issues. The Preferred Option is supported in all cases.

5. Recommendation

5.1 It is recommended that the comments in this report constitute the East of England LGA's formal response to this consultation.

Question - Does the area covered by this DPD lie within the East of England region?
Answer - Yes

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

Question - Does the area covered by this DPD include a Key Centre for Development and Change, or other location of strategic or regional significance?
Answer - Yes
Comments - London Southend Airport lies at the districts southern boundary and falls within the Essex Thames Gateway Policy Area.

Question - Is there a clear push for sustainable development?
Regional Policy Ref - SS1
DPD Policy Ref - All

Question - Does policy seek to maximise the use of previously developed (brownfield) land?
Regional Policy Ref - SS2
DPD Policy Ref - DM3

Question - Is there are clear pattern of development for Key Centres, urban or rural areas?
Regional Policy Ref - SS3, SS4, SS6
DPD Policy Ref - Various

Question - Are there any Green Belt policies?
Regional Policy Ref - SS7, ETG1
DPD Policy Ref - DM10 to DM23

Question - Does policy support wider regional employment objectives? Is employment land protected?
Regional Policy Ref - E2 - E34
DPD Policy Ref - DM10, DM27

Question - Does policy seek to change or influence travel behaviour?
Regional Policy Ref - T2, T9, T13, T14
DPD Policy Ref - DM25, DM26

Question - Does policy address tourism, cultural or leisure issues?
Regional Policy Ref - E6, C1 - C2
DPD Policy Ref - DM13 to DM15

Question - Do policies address green infrastructure, landscape, or other biodiversity issues?
Regional Policy Ref - ENV1 - 3, ENV5
DPD Policy Ref - DM1, DM13, DM23, DM24

Question - Does policy promote soil conservation? Are farm diversity issues addressed?
Regional Policy Ref - ENV4
DPD Policy Ref - DM11, DM13, DM21

Question - Is conservation/enhancement of the historic environment addressed?
Regional Policy Ref - ENV6
DPD Policy Ref - DM1, DM7 to DM9, DM12, DM22, DM32 - 33

Question - Does policy seek to deliver high quality/sustainability in the built environment?
Regional Policy Ref - ENV7
DPD Policy Ref - DM1 to DM6
Comment - Policy DM4 (Floorspace for new development) support the East of England Housing Statement 2010-2014.

Question - Have waste management issues been addressed?
Regional Policy Ref - WM1 - WM8
DPD Policy Ref - DM1

Question - Does the DPD support the implementation of policies in the East of England Plan?
Answer - Yes
Comments - Rochford District Council's Development Management DPD Discussion and Consultation document provides detailed guidance on a range of specific policy issues. The Preferred Option is supported in all cases.

Essex County Fire & Rescue Service, Community Safety & the Rochford District Council Development Management Development Plan Document

Fire & Rescue Services Legislation & Community Safety

Essex County Fire & Rescue Service have a statutory responsibility under Part 2 (Core Functions) (S.7) (1) of the Fire & Rescue Services Act (2004) to make provision for the purposes of:-

(a) Extinguishing fires; and
(b) Protecting life and property in the event of fires in its area.

Furthermore, Part 2 (S.7) (2) provides that 'in making provision under subsection (1) a Fire and Rescue authority must in particular':-

(a) Secure the provision of the personnel, services and equipment necessary to efficiently meet all normal requirements;
(b) Secure the provision of training for personnel; and
(c) Make arrangements for dealing with calls for help and for summoning personnel;

Community Safety Legislation & the Planning System

The Government's Sustainable Development and Sustainable Communities Agenda's to be delivered via the spatial planning system identify issues of community safety as important factors in the creation of safe environments and sustainable, inclusive communities.

Planning Policy Statement 1 (2005) describes the Government's overarching objectives for the planning system and sets out how planning should play a key role in delivering safe, secure, sustainable communities.

Section 17 of the Crime & Disorder Act (1998) requires both local authorities & Fire Service's to consider community safety in the exercise of all their duties and activities.

The Police and Justice Act (2006) (a review of the 1998 Crime & Disorder Act) raised the profile of S.17 as the principal vehicle for mainstreaming community safety in responsible authorities.

Planning Obligations Legislation

S.106 of the Town & Country Planning Act (1990) states in part that:

(1)'A local planning authority may enter into an agreement with any person interested in land in their area for the purpose of restricting or regulating the development or use of the land, either permanently or during such period as may be prescribed by the agreement.

(2) 'Any such agreement may contain such incidental and consequential provisions (including financial ones) as appear to the local planning authority to be necessary or expedient for the purposes of the agreement'.Section 46 of the Planning and Compulsory Purchase Act (2004) provides for the levying of planning contributions.

Circular 05/2005 sets out the current national policy advice relating specifically to planning obligations. It makes clear that it is appropriate to seek financial or other support to mitigate the impact of a development.

The Circular has now been consolidated and placed in the Community Infrastructure Levy Regulations - giving them statutory status, rather than government policy as before.

The consolidated tests are set out at regulation 122, these are set out below and apply to all planning obligations made from 6th April 2010:-

a) Necessary to make the development acceptable in planning terms;
b) Directly related to the development; and
c) Fairly & reasonably related in scale & kind to the development.

Essex County Fire & Rescue Services & the Rochford Local Planning Process

In light of the above therefore, Essex County Fire & Rescue Service have certain expectations of Rochford Borough Council in the operation of their planning activities, these are as follows:

1. Requirement for the relevant inclusion of planning conditions requiring compliance with applicable design criteria to mitigate risk of fire. These include:

Risk based assessments to be undertaken from the design stage for all community buildings or buildings of multiple occupation and agreed with ECFRS prior to construction.

All proposed new schools actively employ the BB100 school design guide, employ the risk assessments and agree to adhere to the recommendations.

Residential sprinkler systems to be installed for any high risk residential buildings, such as care housing, supported housing, RSL (Registered Social Landlord Stock) or other buildings of multiple occupation accordingly.

2. Section 106 developer contributions / planning obligations to be provided for the provision of additional / expanded infrastructure required to meet the increase in demand based upon assessments consisting of:-

a) Standard charging regime or Community Infrastructure Levy - based upon an assessment of existing ECFRS capital infrastructure and the ability of such to meet increase in demand and risk due specifically to growth in all elements of the built environment, should we approach you in due course regarding standard charges / the CIL; and

b) Specific planning contribution requirements for sui-generis developments not capable of being adequately assessed based upon a Standard Charging Regime approach, should it become necessary to the impact of a proposal.

c) Planning obligations practice pertaining to the provision of fire hydrant access to potable water sources as set out by BS:9999:2008 if such an arrangement is not already in place in all instances.

NB: Any subsequent iterations or updates to either BB100 or BS:9999:2008 should be adhered to accordingly.

We hope these comments are mutually beneficial to all parties concerned. Comments expressed in this document are made to the best of our professional ability. Should any party have any queries as to the content or implications, please do not hesitate to contact us on the details contained on the documents accompanying letterhead.