4. Environmental Issues

Paragraph 4.14-4.15, Policy DM25

Above paragraphs infer trees lost to development must be replaced by same of equivalent value. In practice this doesn't occur, for example at Etheldore Avenue development oaks with Tree Preservation Orders were replaced by minute samplings - 'sticks'. Replacement of lost woodland to development in the "same landscape area", logically is unlikely to occur.

Paragraph 4.17 to 4.18, Policy DM26

It's difficult to give credence to proposals to protect hedgerows that meet the 1997 Regulations criteria, nor imposition of conditions, when developers are known to apply secretly to Rochford LPA for right to remove entirely hedgerows protected by conditions, without even reference to the owners thereof, only real justification being need to grab more land for garages, outhouses etc.

Conditions regarding crested newts, slow worms etc have not work in past developments. Translocation does not work. Compensatory habitat for, eg badgers, would have to be a substantial distance away, not normally available in residential settlements.

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.

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).

Rayleigh Town Council has no significant reason to object to the content of each of the items incorporated in section 4 Environment Issues

All policies supported

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

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

The National Planning Policy Framework (Section 10, paragraph 94), the 40-100 year lifespan of development and the fact that climate change predictions are locked in for the next 30-40 years means that all opportunities should be taken to incorporate adaptive capacity from the beginning of the development. The references to the Code for Sustainable Homes and BREEAM are noted but these standards need to be supported by adaptation measures such as climate proofing through the use of green infrastructure assets. Specific measures associated with enhancing the natural environment/biodiversity adaptation to climate change can be expected to generate social, economic and cultural co-benefits as well as reduce the negative effects of climate change. Accordingly, the Document should include a requirement that all developments should address climate change through appropriate use of adaptation, mitigation and renewables. Ideally, this should be through addition of a new Policy to read,

'Policy - Addressing Climate Change
New or redevelopment will be considered acceptable, provided that:

I. It has considered climate change adaptation measures and technology from the outset including reduction of emissions, renewable and low carbon, passive design, and through green infrastructure techniques where appropriate.
II. That vulnerability to climate change impacts is minimised and that such development does not increase vulnerability to climate change impacts.
III. The potential effects of climate change on the development is taken into consideration, such as:
a. Water conservation and drainage
b. Need for summer cooling
c. Risk of subsidence
d. Flood risk from fluvial and surface water
IV. Associated activities adhere to local, regional and national targets for reducing carbon emissions.
V. Consideration of on-site small scale renewable or low-carbon technology where appropriate such as solar panels, geothermal heat pumps, small-scale wind turbine, photovoltaic cells, Combined Heat and Power etc.
VI. Measures to connect to off-site, decentralised energy networks (e.g. District Heating) either at commissioning or in the future are considered.'

To assist review development proposals for appropriate climate change measures, the District Council could use a checklist similar to that developed by Hertfordshire County Council by asking 'Has the building or development been designed to be resilient to the expected impacts of climate change (including flood risk) during the expected lifetime of the building(s)?'. An example of Hertfordshire Building Futures Adaptation Checklist can be found here:
http://www.hertslink.org/buildingfutures/16557273/16766291/

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,
* Chapter 3, Objectives, page 34 - insert an additional objective to read, 'Plan positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure and will identify opportunities to incorporate adaptation measures that will address risks associated with climate change'.

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,
* Chapter 4, Vision, page 61 - insert additional text into the Vision to read,
o Short term - 'Consideration to be taken into account of the risks to new developments and refurbishments form extreme weather as experienced now to help communities to adapt over the long term.'
o Long term - 'Climate change adaptation measures and technology to be considered from the outset in any development proposal including reduction of emissions, renewable and low carbon technologies, passive design, and through the application of green infrastructure techniques where appropriate.'

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,
* Chapter 4, Objectives, page 62 - insert an additional objective to read, 'Ensure that the vulnerability to climate change impacts is minimised by the development proposal and that such development will not increase the vulnerability from climate change impacts.'

The Document should note in Paragraph 4.3 that since adoption of the Core Strategy the eastern part of the District has been included in the Greater Thames Marshes Nature Improvement Area.