How have you assessed the environmental impacts?

para 1.1 future 'of' our district.
par 1.3 'Silent' is ambiguous and subjective. How long is silent... a day... a month... a year...? How long is it before a local plan is deemed to be silent and therefore, could be ignored?
footnote 2 p1 typo
para 1.13 This is subjective. I'm sure what is valued by myself may not necessarily be valued by the council. Needs to consider emotional needs of landscape and not those of someone walking around with a clipboard.
para 1.14 Who does the Planning Inspector work for?
para 1.21 What happens if that fund is insufficient to meet the baseline infrastructure requirements?
para 3.2 Is there a map available of these designated areas?
para 3.3 The area 'is' home...
para 3.3 Contradicts with the characteristics of our district that have just been described. How can a district with very low unemployment and deprivation levels be a target area for improvement and regeneration? Why is our district not an exception within South Essex?
para 3.12 What plans and which schools? These need to be included or referred to in the document if not already done so.
para 3.14 We should be trying to keep it that way. This statement contradicts with the desire to build 7.5K houses.
para 3.14 This is a positive. Nothing wrong with this.
para 3.15 What are these actions and are they considerate with the desire to build 7.5k houses in the district?
para 3.16 Seems to contradict with the desire to build 7.5 houses
Our Communities p14 Re point 3, building more 4/5 bed houses does not address the concern of affordability, the new builds along Hall Road being a case in point - This is not sustainable development
para 3.22 Agreed. The developments at Hall Road and Folly Lane have not helped this trend.
para 4.4 I consider this a dangerous approach to take. It suggests that housing needs are being put before all other needs. I get the idea of 'policy off' and the requirement to identify housing need but this cannot be done in isolation. All needs must be considered, as a whole, if this is to work.
para 4.4 Again, has to be affordable and sustainable. No point in building 4/5 bed properties for 500k as will not meet objectives and will just add to an ageing population.
Challenge before para 4.6 The challenge will be delivering business that can afford to pay wages that allow residents to live in the district. This comes back to affordable housing. Your figures show that most residents commute to London; that is where the higher wages are paid.
para 4.6 Typo : Need to need to.
para 4.6 It is also critical if 7.5k homes are going to be built. They go hand in hand. Can't have one without the other which is what we're starting to see at Hall Road and Folly Lane where additional infrastructure is not being provided.
Challenge before para 4.7 It has to be long term strategic thinking, not short term for a short term quick hit win. Pride and self gain have to be put to one side and everyone needs to buy in to the long term vision, including developers, builders and land owners. This cannot be about personal gain and profit. If this isn't sustainable and the infrastructure isn't in place, we will have a post war planning disaster on our hands, which future generations will be left to deal with, by which time it will be too late.
Challenge before 4.8 Depends on who the neighbours are, and how similar the issues and challenges they face, are to those of our district. I would always encourage communication, collaboration and idea sharing but it has to be meaningful and strategic and not just doing it for the sake of it.
para 4.9 What is a sub-regional housing market area?
para 4.10 What about utilities infrastructure (energy) and education?
para 4.13 What does this mean in real terms? Does the burden fall on our district to meet the shortfall e.g. 7.5 k becomes 8k?
para 4.15 Typo... 'its'
Our Draft Vision before para 5.10 I support the Vision. However, the Vision should refer to affordable homes.
Strategic Objective 7I would like to see more support for local start ups instead of being swamped by more super brands like Sainsburys and Costas, to the detriment of local businesses.
p29 Tell Us More: I'm supportive of all the objectives but it is a balancing act between them.
People have to work in London because that is where most of the jobs are and which pay the wages to pay for the cost of an average size house in our district.
Creating jobs in the region that can pay equivalent wages is always going to be a challenge unless housing becomes more affordable for future generations.
I'm supportive of more play spaces. These are disappearing or access to them being removed.
Building 7.5k houses is in contradiction with the environmental objectives to a degree.
Tell Us More SP1.1 Everyone involved in this process needs to be mindful that this isn't about profit. It cannot be solely about profit if it is to be sustainable.
It needs a complete change of mindset from developers, builders and architects that this isn't about personal gain but about the future of our district.
I struggle to see, that in the current economic climate, a global development corporation would buy in to this ethos.
Figure 9: What region is this for? Our district or the East of England?
What is the scale along the y axis?
para 6.6 Excessive market level housing will drive up the cost of affordable housing, to the point where what was once affordable housing, no longer is.
para 6.7 Type : in 'for' the form
Table 2 What size are the homes? 10 bedroom mansions or one bed flats?
para 6.10 Not sure I understand what this statement is saying. What happens if the 'need' and 'target' differ significantly?
para 6.12 Not a sustainable approach.
para 6.13 Feels like a get out clause so that affordable housing can be conveniently ignored.

Dear Sir/Madam,

Rochford Local Plan Issues and Options consultation

Thank you for providing the RSPB with the opportunity to comment on this consultation. We are very grateful for the short extension in time enabling us to provide the following response.

Habitats Regulations Assessment (HRA)

We recognise that a number of HRAs relating to previous development plans and strategies have been provided as part of the evidence base. Whilst informative, these are not up to date. However, we note and welcome your commitment to presenting a draft HRA at the next stage of the plan process (per paragraph 1.12) and we look forward to commenting on this document. If you require any assistance in its formation, we would be happy to assist.

Page 19, paragraph 4.7: Challenge - how do we work with our neighbours to meet the requirements of the Duty to Co-operate?

The RSPB welcomes that Rochford has committed to working on the Recreational Avoidance and Mitigation Strategy (RAMS) lead by Essex Place Services and Natural England along with all other District Authorities in the county. The effective funding, delivery and future monitoring of this strategy must ensure that recreational impacts from proposed new housing across the district will be managed to ensure that adverse effects on the network of European designated sites are avoided.
Reviewing the 2005 Green Grid Strategy will also serve to meet the Council's Duty to Co-operate.

Page 26, Drafting our Vision

We welcome the inclusion of the Wallasea Wild Coast project in the "Our Environment" section of the draft Vision. In order to be consistent with national planning policy to conserve and enhance biodiversity, we recommend that "where possible" is deleted from lines 6/7 of this section. To have an over-arching vision which aims to have enhanced the built, historic and natural environment provides the Council with a positive momentum. We consider that saying "where possible" may lead to stasis and is not in the spirit of what a vision should be.

Page 29, Strategic Priority 5

The RSPB broadly supports the four strategic objectives set out under this Priority. However, we recommend that mention of "recreational areas" within a strategic objective based around the natural environment would be more appropriately placed in Strategic Priority 4.

In so doing, we are not being dismissive of recreational areas as providing some ecological resource, but given that they are designed to attract people, such a high-level of expected disturbance would be likely to have a detrimental impact on any important species or habitats present.

Page 55, paragraph 6.83 - houseboats
We support the Council's approach to protect the network of designated sites that may be potentially affected by the inappropriate positioning of houseboats.

Page 125 - Biodiversity, Geology and Green Infrastructure

SP5.2 - How should we protect, manage and enhance our important habitats, nature conservation areas, geology and greenways?

We welcome the strong policy position that the Council sets out to protect and enhance sites and habitats.
Policy DM27 in the Development Management Plan (DMP) also recognises "species" and we ask that this is captured as part of this consultation as well. Question SP5.2 would read more appropriately if it was amended to read:
"..our important habitats and species, nature conservation areas.".
A firm principle of nature conservation is to first understand the distribution of any important species through effective, co-ordinated monitoring. Having species recognised from the outset will set the framework to achieving that aim.

By extension, the Council's Environmental Capacity Study (paragraph 6.31) recognises a number of priority species which occur within the district, e.g. Turtle Dove, Little Tern, Corn Bunting, Lapwing (see page 5 for more detail). The RSPB and other conservation organisations would be able to assist the Council in effectively mapping their distribution as part of the first step towards their protection and enhancement.

Page 127 - paragraph 10.27: options

The RSPB supports option A, which sets out to: "Retain or amend our current broad policy on sites of nature conservation importance".

The Council would be fully justified in adopting a policy that recognises the need "..to identify and seek to enhance local wildlife corridors and network s..".
An integrated landscape approach to improve ecological networks is fundamental in conserving our wildlife.

However, this approach will not be sufficient to achieve the recovery of all species, and in some cases, it will need to be complemented by specific tailored actions. As highlighted in Professor John Lawton's 2010 report Making Space for Nature, many habitats such as hedgerows, meadows, heathlands, woodlands, sand dunes, wetlands and flower rich field margins do not fall within protected sites. We welcome the Council's recognition of the need for such an approach (paragraph 10.25) and that the Green Grid Strategy (2005) is in need of reviewing. This review should look to encompass the entire council boundary and would lend itself to linking in to Wallasea and the aspirations set out in answer to question SP5.3 on page 4 below.

Recreational Avoidance and Mitigation Strategy (RAMS)

We recommend that it is specified in the pre-submission Local Plan that the frameworks and masterplans for any developments include clear and evidenced strategies to avoid increasing recreational pressure on internationally designated wildlife sites, in line with duties on the Council to conserve biodiversity which would accord with the RAMS.
We are pleased to see Councils' commitment to this county-wide strategic mitigation plan currently under development for recreational impacts of new housing developments on internationally-designated sites. Where a development is likely to give rise to a significant effect on an internationally designated site and it is possible to mitigate this effect, developers should be required to contribute to the RAMS, to ensure that mitigation is strategic rather than piecemeal, and give confidence that mitigation measures can be delivered. We recommend that these requirements are specified within an appropriate policy in the Local Plan.

In order to understand whether measures to protect sensitive sites are being effective, there needs to have been a baseline of monitoring conducted to understand the extent and type of pressure these sites face.
Information from this monitoring can then be used to inform the RAMS, which from experience elsewhere in the UK, we know will require paid wardens/rangers to be employed to raise awareness of the importance of coastal sites and promote positive behaviours amongst local communities and visitors alike.
The RSPB would welcome working with the Council and other parties, e.g. Essex Wildlife Trust, in helping to maximise the over-arching benefits to biodiversity, residents and visitors alike of such a strategy.

Nature-friendly developments and Greenspace

Alongside the RAMS, we consider that the key means to avoid increasing pressure on designated sites will be through provision of high quality green space close to people's homes and at a scale that is appropriate to the level of planned growth. This should be wildlife rich green space, again in line with the Council's biodiversity duties. Furthermore, access to such spaces will have wider societal benefits by contributing to the health and wellbeing of residents, e.g. dog-walking, jogging or wildlife-watching.
All developments should be nature friendly, with homes for nature integrated with homes for people during the design phase. With the planned scale of development there will be many opportunities to bring nature closer to people at the local scale. An example of how to develop nature-friendly homes is the Kingsbrook Barratt Homes development at Aylesbury, Oxfordshire where RSPB has worked in partnership with Barratt Homes PLC to design housing that benefits people and nature (https://protecteu.mimecast.com/s/2767BHYRg0LUZ).
Further details on our experience working with Barratt Homes PLC and Aylesbury Vale District Council to set a positive example of nature-friendly and wildlife rich development, which we would like to see as the new common standard is provided in Annex 1.
Offering the opportunity for increased connection to nature within the development, through accessible and wildlife-rich green space and wildlife friendly gardens benefits both the natural environment and maximises the health and well-being benefits for residents. The benefits of nature on people's mental health are widely reported within scientific literature (Healthy lives, healthy people: our strategy for public health in England' - Dept Health White Paper, November 2010; paragraph 3.36); however, recently it has become apparent that the quality of the natural environment may be more important than the quantity of it. People are twice as likely to report low psychological distress when living close to quality green space compared with those living near low quality green space.

Therefore, it is important not only to plan for easy access to green spaces in our living environment but also to improve the quality of these green spaces - incorporating greater levels of biodiversity in our green spaces could be one way to achieve this. Natural England have established methods to calculate how much green space will be required in relation to the level of recreational need, known as the Accessible Natural Greenspace Standard (https://protecteu.mimecast.com/s/6RgRBU7edE0IV). We recommend these methods provide the basis of calculating necessary greenspace for new developments.
The RSPB would be grateful for the opportunity to provide further advice on these matters during preparation of the pre-submission version of the Local Plan.
One of the main pressures identified on designated sites is dogs' off-lead. New developments should therefore be managed with dog-walkers in mind and have accessible green space within easy walking distance. The average dog-walk is 2.7km and a dog-owner will only walk around 4-500m to begin exercising their dog, otherwise they are likely to drive to a site to do so. This in itself, adds unnecessary traffic to roads and will increase air pollution and heighten the risk of sensitive sites being disturbed.
Hampshire County Council have produced a guidance document called Planning for dog ownership in new developments: reducing conflict - adding value. Access and greenspace design guidance for planners and developers (March 2013)2 which provides greater detail.

Page 128 - paragraph 10.28: options
The RSPB supports option G, but critically this must retain the principles outlined in Development Management Plan policies DM25-27 together with a commitment to conserving and enhancing habitats and species and working to deliver this on a landscape-scale. The Local Wildlife Sites review should form the basis for robust protection of LoWS as an integral component of such a policy.

Page 128 - paragraph 10.29: options
We support Option A to retain the current policy on Greenways. This has particular relevance to Wallasea. The Green Grid Strategy (Figure 11) identifies a Greenway linking Rochford to Wallasea.

Page 129 - Wallasea Island and the RSPB's Wild Coast Project
SP5.3 - How do we continue to support the RSPB's development of Wallasea Island as an important nature conservation project and visitor destination in the future?

The RSPB broadly supports option A. For the last two years, we have been working closely with the Council on the functioning of the site as a whole and on the provision of improved visitor facilities in particular. We want to continue to work closely with Council to deliver a site that delivers tourism benefits and income generation both on site and in the wider community. We are confident that together we can deliver these benefits in a sustainable and cost effective fashion. Other key issues that we are keen to explore/instigate if possible are sustainable transport links to Wallasea from Rochford and Southend - including via cycle routes, sustainable links across the river to/from Burnham-on-Crouch and joint promotion of the site. It is important that the stated intention of the Core Strategy policy URV2 that any development around the marina "will be supported, provided any adverse ecological impacts are avoided or mitigated for" is retained. This would accord with the mitigation hierarchy endorsed by the Royal Town Planning Institute (RTPI) and the Chartered Institute of Ecology and Environmental Management (CIEEM).

*Further general advice provided in attachment*