1. Introduction

I'm not going to make comments on individual policies because the whole document appears to have been very well thought out and expressed. It will give the planning committee the weapons it needs to stop unwelcome developments while encouraging synpathetic ones. But because of this I expect developers to try and eviscerate it, unfortunately.

Chelmsford City Council has no issues of soundness that it wishes to raise in respect of this document.

ROCHFORD DEVELOPMENT MANAGEMENT SUBMISSION DOCUMENT

Thank you for your letter dated 3 June 2013, consulting Natural England on the Rochford Development Management Submission document.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

General Comments

Overall we are satisfied that the above DPD adequately considers the impacts on the natural environment. We previously commented (on the Rochford District Development Management DPD Preferred Policy Options) on 27 February 2012 and note that whilst many important amendments have been made to this document following our advice, some of our previous recommendations were not
taken into account. We have referred to these again below but would recommend that this response is read in conjunction with our previous response (our reference 43442).

1. Introduction

Natural England has no specific comments relating to the Introduction section.

2. Housing, Character of Place and Residential Amenity

Natural England welcomes the short, medium and long term visions for the district and is broadly in agreement with the policies presented in this section, including those relating to the design of new developments, light pollution and telecommunications. However, we advise you to refer to our previous response regarding recommendations for changes in wording within Objective 7 (previously 8), Draft Policy DM1 and Paragraph 2.39, Environmental Zone 1 (in relation to lighting). We note our changes have been incorporated into the Telecommunications section.

It is important to ensure that the retention of the green belt is not at the expense of areas that support wildlife within the town, including locally designated wildlife areas (local wildlife sites/county wildlife sites), brownfield sites and undesignated areas that provide both habitat for wildlife and ecological continuity. Gardens and allotments are also important, both in terms of increasing the biodiversity value
associated with new developments and improving the health and wellbeing of residents. We advise that these points should be reflected within the medium/long range vision.

3. The Green Belt and Countryside

We welcome the short, medium and long term visions, particularly in terms of protecting the openness and character of the greenbelt, green tourism and new strategies for improving access to the countryside. However, we find that, whilst protection for areas of nature conservation is frequently referred to in this section, enhancement is not. We consider that the section should be updated to
reflect the need for protection and enhancement, for example in the following sections:

Objective 1 should read as follows:
'Continue to protect and enhance biodiversity whilst protecting the openness and character of the District's Green Belt'.

In the Green Tourism section (page 46), we would recommend that a paragraph is added detailing how funds raised by green tourism may be used to protect and enhance sites of ecological importance.

We also recommend that further provisions are included in Draft Policy DM23, Conservation Areas and the Green Belt, to protect and enhance areas of biodiversity and geodiversity interest when defining what should be considered acceptable development.

Also note our comments in the previous section regarding brownfield sites and ecological linkages.

4. Environmental Issues

We broadly agree with the vision, objectives and policies in this section, including Policy DM27, Species and Habitat Protection, Policy DM25 Trees and Woodlands and Policy DM26, Other important landscape features. In our view the policies in this section are all well considered and sufficiently comprehensive.

We recommend that Point 3 in the short term vision should read:
'Local, national and international sites of nature conservation importance are protected and enhanced.' It is noted that enhancement is included as a medium term aim, but enhancement should actually be reflected in current, as well as in future decision making.

The vision

Natural England advises you to add a bullet on improving ecological connections between local and national sites and the wider countryside, which should build in detail over the short, medium and long term visions. This is in view of the aims of the NPPF to improve the network of wildlife areas within the UK, in accordance with the findings of 'Making Space for Nature' (2012) and the Natural Environment
white paper (2012).

We trust that the comments above are helpful. For any correspondence or queries relating to this consultation response please do not hesitate to contact me using the details below. For all other correspondence, please contact the Natural England consultations email address at consultations@naturalengland.org.uk

For the avoidance of doubt on Rochford District Council's stance with regard to planning obligations and standard charges the Document should make reference to Policy CLT1 of the Core Strategy and the separate Planning Obligations and Standard Charges Document. This could be achieved through a minor alteration to the text within Table 1 of the Document.

The references to climate change in the Document are welcomed, particularly those in paragraphs 2.5, 2.11 and 2.12 of the Document. However, the risk from climate change should be embedded and considered elsewhere in the Document, for instance,
* Paragraph 1.4, point 4 - by addition of the words, 'and also considers measures to address the impacts from a changing climate.'

Introduction: Paragraph 1.29 - the Evidence Base includes no reference to any research or reports on climate change. The following should be added,
* A Summary of Climate Change Risks for the East of England -To coincide with the publication of the UK Climate Change Risk Assessment (CCRA) 2012 by Sustainability East - http://www.sustainabilityeast.org.uk/index.php?option=com_content&view=article&id=128:uk-climate-change-risk-assessment&catid=5:latest-news&Itemid=9
* UK Climate Change Risk Assessment - Built Environment http://randd.defra.gov.uk/Document.aspx?Document=CCRASummaryBuiltEnvironment.pdf and full Built Environment report: http://randd.defra.gov.uk/Document.aspx?Document=CCRAfortheBuiltEnvironmentSector.pdf (Information on NAP: http://www.defra.gov.uk/environment/climate/government/nap/ )
* Planning and Climate Change Coalition (2012) planning for climate change -guidance for local authorities, TCPA - http://www.tcpa.org.uk/data/files/PCC_Guide_April_2012.pdf
* Climate Ready Programme for Built Environment http://www.environment-agency.gov.uk/research/policy/132333.aspx
* Shaw, R., Colley, M. and Connell, R (2007) Climate change adaptation by design: a guide for sustainable communities. TCPA, London - http://www.tcpa.org.uk/pages/climate-change-adaptation-by-design.html
* North West Green Infrastructure Valuation Toolkit - http://www.greeninfrastructurenw.co.uk/html/index.php?page=index
* Henderson, K. (2009) The Case for Climate Change Adaptation, TCPA - http://www.tcpa.org.uk/data/files/GXP1adaptation.pdf

In order to meet the requirements of the National Planning Policy Framework and to more clearly support Rochford District Council's objectives for the historic environment additional text should be included in the Document, to read,

* Page 3 section 4: 'This chapter sets out detailed policies for historic and natural environment, air quality and houseboats'.

The references in the Document to support the ageing population are supported. Attached is the Essex County Council draft strategy 'Housing for People with Additional Needs Strategy 2013-2016' which could usefully be added to the Evidence Base at Paragraph 1.29.

Essex County Council, as the Mineral and Waste Planning Authority, welcomes and fully supports the reference to the Minerals and Waste Local Plans (Paragraph 1.12) and the Document's thorough identification of waste storage and management provision for new development. However, in view of the known minerals resources existing in the District reference should be made to the Mineral Safeguarding Areas and Mineral Consultation Areas identified through Policy S8 (Safeguarding mineral resources and mineral reserves) in the Replacement Minerals Local Plan, January 2013. To ensure compatibility and consistency between the Development Management Document and the Minerals Local Plan a sentence should be added to Paragraph 1.12, to read,
'Parts of Rochford District lie within a Minerals Safeguarding Area and therefore consultation on the proposed development of the site with Essex County Council is required'