Objectives

There should be a commitment to protecting and extending public footpaths.

Countryside Properties have addressed the matter of the Green Belt boundary in separate representations to the Core Strategy and Site Allocations DPD. Paragraph 2.8 of PPG 2 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

The reference to ensuring that the "minimum amount of Green Belt is allocated" completely ignores the requirement in PPG2 to set a long-term, permanent Green Belt boundary that will not need to be altered at the end of the Plan period.

Greenbelt and Countryside

Objectives

The proposed allocation of one of the sites WR1-4 does not meet any of these objectives as detailed in response to the Allocations document.

The Hall Road site meets all the criteria listed on page 28 for preserving the Green Belt.

Policy DM11.

Figure 3 on page 31 shows the Agricultural land classification for the district and the protection of agricultural land is loosely referred to in this Chapter . However there is no firm policy for the protection of such land which is a natural resource. The existing policy in the Local Development Plan at 8.16 states that the Council recognises that the best and most versatile agricultural land defined as Grades 1, 2 or 3a within the Agricultural Land Classification system is a valuable natural resource for the future. It is important that as a natural resource it is protected for the future.

This policy should be retained. The proposed wording in DM11 and DM13 is inadequate to ensure the safeguarding of agricultural land falling into the of Best and Most Versatile category

Green Tourism

At present Hall Road provides an attractive gateway to one of the most picturesque historic towns in South East Essex and the proposals for large scale development in Hall Road does not accord with the Green Tourism aims.
Environmental Issues

Policy DM 24

The policy is too weak to ensure the protection of valuable habitats. The policy should a requirement for developers to provide full environmental impact and protected species surveys to ensure adequate protection and such surveys must not be carried out during winter months.

The policy should also include a requirement that where a development abuts a protected hedgerow that an appropriate buffer zone is provided. An example of the need for this requirement is Ironwell Lane.

Greenbelt and Countryside

Objectives

The proposed allocation of one of the sites WR1-4 does not meet any of these objectives as detailed in response to the Allocations document.

The Hall Road site meets all the criteria listed on page 28 for preserving the Green Belt.

Policy DM11

Figure 3 on page 31 shows the Agricultural land classification for the district and the protection of agricultural land is loosely referred to in this Chapter. However there is no firm policy for the protection of such land which is a natural resource. The existing policy in the Local Development Plan at 8.16 states that the Council recognises that the best and most versatile agricultural land defined as Grades 1, 2 or 3a within the Agricultural Lane Classification system is a valuable natural resource for the future. It is important that as a natural resource it is protected for the future.

This policy should be retained. The proposed wording in DM11 and DM13 is inadequate to ensure the safeguarding of agricultural land falling into the of Best and Most Versatile category.

Green Tourism

At present Hall Road provides as attractive gateway to one of the mot picturesque historic towns in South East Essex and the proposals for large scale development in Hall Road does not accord with the Green Tourism aims.

Environmental Issues

Policy DM24

The policy is too weak to ensure the protection of valuable habitats. The policy should a requirement for developers to provide full environmental impact and protected species surveys to ensure adequate protection and such surveys must not be carried out during winter months.

The policy should also include a requirement that where a development abuts a protected hedgerow that an appropriate buffer zone is provided. An example of the need for this requirement is Ironwell Lane.

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.