Rochford District Core Strategy Regulation 26 Draft

Comment

Representation ID: 88

Received: 13/06/2007

Respondent: Environment Agency

We feel that the document should specifically refer to flood risk locally, which is a key issue for the district. Reference to the Thames Gateway South Essex Strategic Flood Risk Assessment should be made within this section. This document is available to view online at http://floodrisk.tgessex.co.uk/general/index.asp Reference should also be made to the role that it will have in influencing development locations and the types of flood mitigation required across the district should be outlined.

Support

Representation ID: 89

Received: 13/06/2007

Respondent: Environment Agency

We would fully support the protection of the undeveloped coastline, for both biodiversity and flood risk management reasons.

The core strategy should also be seeking to enhance biodiversity through development, in accordance with PPS1 and PPS9. This will involve retaining existing natural features within any development and seeking opportunities to create new habitats and link in with existing adjacent habitats. The Essex Biodiversity Project has produced an informative guide called: 'Integrating Biodiversity into development...realising the benefits'. This is available on their website: www.essexbiodiversity.org.uk.

Comment

Representation ID: 90

Received: 13/06/2007

Respondent: Environment Agency

This section states that the housing requirement is likely to be met through allocations rather than rely on windfall sites. If windfall sites are permitted it must be ensured that proposed sites are tested against the relative sustainability criteria. In terms of flood risk, all sites must be subject to the PPS25 Sequential Test. This is best applied at the plan stage, which better allows for a consideration of alternatives. Therefore, if windfall sites were likely to be permitted we would recommend that appropriate general locations be identified within the development plan, and it should be demonstrated that the correct procedures in selecting these areas have been applied.

Paragraph 4.5.11 states that the council will prioritise the reuse of previously developed land. We agree with this approach, however brownfield sites may also be contaminated. At the individual site level, where contamination is suspected, it must be ensured that the procedure detailed in PPS23 is complied with.

Comment

Representation ID: 91

Received: 13/06/2007

Respondent: Environment Agency

As stated above, for all allocations it must be demonstrated that the PPS25 Sequential Test (and the Exception test where required) has been applied. Clearly the TGSE SFRA will have a key role in this process, and we are able to advise. In all respects, the approach taken must be robust and transparent.

The approach taken appears likely to be acceptable from a flood risk viewpoint. The top tier settlements all do contain areas of Flood Zone 3 (High Risk), but the majority is Flood Zone 1 (Low Risk). Of the second tier settlements, Canewdon is all FZ1, Hullbridge has a small part of FZ3, while Gt Wakering is approximately 40% FZ3. All appear capable of accommodating the required growth in FZ1, but this must be tested.

For sites in the other settlements, the PPS25 Sequential Test must still be applied.

Biodiversity is also correctly highlighted as a key issue. There will potentially be a large number of brownfield sites, which can also have significant biodiversity value, and this must be taken into consideration.

We support the approach taken in paragraph 4.6.2. It is essential that land affected by biodiversity issues or at risk of flooding is avoided when allocating sites for development.

Comment

Representation ID: 92

Received: 13/06/2007

Respondent: Environment Agency

As above, all potential sites should be tested against the sustainability criteria and the PPS25 Sequential Test. For this reason, we would prefer to see allocations, which will enable these processes to be more easily carried out.

At present the document does not consider pollution prevention. It will need to be ensured that all development does not pose a threat to the natural environment during construction stage or during occupation.

Comment

Representation ID: 93

Received: 13/06/2007

Respondent: Environment Agency

We feel that it is important to outline at an early stage what will be expected of development in the district, with high standards required. It should be made clear that compliance with sustainable construction targets will be sought in all developments.

Within Paragraph 4.9.6, we agree that all development should meet the requirements of the Code for Sustainable Homes. Sustainable construction should form an intrinsic part of the development. It should influence the layout of the development, allowing for appropriate orientation to maximise passive solar gain and provide space for habitat creation or amenity space. Sustainable Drainage Systems (SuDS) should be the first option for site drainage. Such systems also provide for habitat creation/amenity space, and a specific allowance within the layout of the site will need to be made for SuDS. Developers will clearly need to be aware of all these requirements prior to submitting an application.

Comment

Representation ID: 94

Received: 13/06/2007

Respondent: Environment Agency

Landscaping proposals should ensure that existing natural features are retained on site, and should seek to enhance biodiversity through the use of native species and by linking in with adjacent habitats. We would support the requirement for landscaping proposals to be detailed by the developer at an early stage so that they can be amended if required.

Comment

Representation ID: 95

Received: 13/06/2007

Respondent: Environment Agency

Water resources are a key issue for south Essex, which imports the majority of its water. Our representations to the East of England Plan highlighted the need for all new development to incorporate water efficiency measures. A saving of approximately 25% can be achieved through the use of relatively simple measures such as: spray taps, efficient appliances and low flush toilets. We would recommend the inclusion of a specific target for this key issue. We recommend this document encourage development to meet level three of the Code for Sustainable Homes as a minimum.

Waste is a further key issue for south Essex, with landfill space rapidly decreasing. This section could be broadened to 'Resource Efficiency', which should include waste reduction. Site waste management plans should be required to limit construction waste, while space for the storage of recyclable materials should be provided within developments.

Comment

Representation ID: 96

Received: 13/06/2007

Respondent: Environment Agency

These should include the facilitation of environmental enhancements and habitat maintenance. SuDS also require ongoing maintenance, so sums should be sought to contribute to this.