DM13 Green Tourism - Preferred Option

Natural England is generally supportive of Policy DM13. However, the council may wish to consider the possible effects of additional generated traffic on the highway network and effects on the capacity of other infrastructure, especially sewerage and power supply, as per Policies DM10, DM11 and DM12. Increased numbers of persons living or working at rural locations may exceed the capacity of existing sewage treatment systems, thus resulting in pollution or a need for upgrading. Increased power demands may require upgrading of local transformers and supply cables. Such upgrades may themselves have significant landscape or ecological impacts.

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.

The Green Belt and Countryside

DM10 Existing Businesses in the Green Belt
We support the preferred option

DM11 Rural Diversification
We support the preferred option

DM12 Conversion of Existing Agricultural Buildings in the Green Belt
Whilst you refer to PPS4 and PPG2, current policy seems to ignore PPG7. Policy PPG7 does not rule out the conversion of agricultural premises for business or residential use. Therefore, to encourage skills and growth in the rural economy, we support a less restrictive approach as above. We see this as being potentially good for the local economy both in terms of new business and providing local work for construction and building supplies.

With regard to listed buildings, each case should be judged on its merits.

Tourism Opportunities in the Green Belt

DM13 Green Tourism

Your paragraph which states "appropriate locations should not result in agglomeration of similar facilities" could result in uneconomically viable and restricted businesses. If the authority is serious about encouraging Green Tourism, it must let the market decide. As an example, Southend Sea Front is known for Hotels and B&B accommodation. This grouping ensures its economic viability. Restrictive policy constrains it.

This policy should be less restrictive

Transport

DM25 Parking Standards
In order to attract and keep business in the district, we should relax the maximum car parking standards for key trip destinations. By enforcing this restriction we are directing shoppers out of the district. Example: Fossetts Way, TESCOS, Rayleigh Weir and Lakeside. The public will go where there is car parking. This policy is driving out business development to neighborouring districts, increases car use and congestion.

On page 57 there is mention of the RDC Transport Strategy Supplementary Planning Document. This document has not been issued as a consultation or in draft form. What is the timetable for this?

Economic Development

DM26 Traffic Management
There is no policy to support the increase in traffic generated by the proposed, planned developments. Example: Coombes Farm, Airport Expansion, West Rochford, Ashingdon Road, Christmas Tree Farm and Stambridge Mills. We should at least have a contingency plan in the event of gridlock.

DM27 Employment Land
This appears to be yet another restriction, driving people out of the area for retail activity. (See DM25 above.)

Cases should be judged according to their merits.

Retail & Town Centres

DM29 Town Centre Shopping Frontages
The 75% rule (Guidance) for retail outlets in town centres should be enforced.

The authority should not be in the business of micro managing the market. Shoppers like choice, any vibrant, retail centre will provide choice which is often clustered.

DM30 Upper Floor Locations in Town Centres
Agree preferred option

DM31 Village & Neighbourhood Shops
We agree that "retail use is important to ensure the vitality and vibrancy of any shopping frontage and to meet the needs of local communities".

DM32 Advertisements and
DM33 Advertisements affecting Conservation Areas and Listed Buildings
The authority need to have effective guidelines rather than the subjective judgements which are not user friendly and singularly unhelpful.

Development Management

It is pleasing to see that the Historic Environment is included within this document; however, it does need to be appropriately integrated within the policies.

Under Housing, Character of Place and Residential Amenity it states that 'This chapter elaborates on the core strategic issues by providing policies on specific housing issues and the protection of the historic environment. This section does discuss designated sites, listed buildings etc but fails to include the wider historic environment including archaeological sites and the historic environment. It is therefore recommended that under DM1 Design of New Developments - Preferred Option section vi should be changed to 'impact on the historic environment including designated sites, Conservation Areas and Listed Building archaeological sites and the historic landscape.'

Under Tourism Opportunities in the Green Belt and Counctryside the historic environment is not mentioned. The Historic Environment is as important as the impact on the natural environment by the tourism opportunities. It is recommended that an additional point I added to DM13 Green Tourism - Preferred Option which states the impact on the historic environment.

Under Environment the vision fails to include any reference to the historic environment, however the objectives clearly state 'Protect and enhance sites of local, national and international importance and protect the District's historical and archaeological sites'. It is recommended that under the third bullet point in the 5 year vision the words Historic Environment should be added so that it reads 'Local, national and international sites of nature conservation and historic environment importance are protected'.

For the 2017 section a further bullet point should be added stating 'the local, national and international sites of historic environment importance are being increasingly protected, promoted and enhanced'.