Development Management DPD Preferred Policy Options Document

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Comment

Development Management DPD Preferred Policy Options Document

The Role of the Development Management Development Plan Document

Representation ID: 28296

Received: 17/02/2012

Respondent: Essex County Council

Representation Summary:

The Development Management DPD elaborates the Core Strategy policies with both documents needing to be read in conjunction with each other. It would be useful if a cross referenced list or a diagram could be included to provide a more efficient easy reference of all the policy information which will inform decisions. This would help users not familiar with accessing the documents on a regular basis, especially those planning small scale developments.

Full text:

A. General

The Development Management DPD elaborates the Core Strategy policies with both documents needing to be read in conjunction with each other. It would be useful if a cross referenced list or a diagram could be included to provide a more efficient easy reference of all the policy information which will inform decisions. This would help users not familiar with accessing the documents on a regular basis, especially those planning small scale developments.

B. School Development

1. Core Strategy Policy CLT2 ("Primary Education, Early Years and Childcare Facilities") and Policy CT3 ("Secondary Education") address the need for new educational infrastructure associated with new residential development. However, there could well be situations where existing schools need to expand to respond to local circumstances or changing forecasts. Planning applications would then need to be considered against the development management policies within the LDF and in this respect the Development Management DPD consultation document does not assist development at existing educational facilities.

A specific Development Management Policy should be introduced that provides policy support to the expansion of existing schools to meet educational needs. There is occasionally a need to use existing playing fields when expanding existing schools and in this respect the policy should explicitly acknowledge this possibility. The addition of a specific policy would accord with the Government's positive support for education development within the August Policy Statement "Planning for Schools".

The consultation DPD was not accompanied by a detailed Proposals Map to identify the application of its policies. Nevertheless, school sites should be identified as such on the Proposals Map so that appropriate educational development is not restricted, for instance, by a Green Belt designation within which school expansion would be deemed "inappropriate development" in policy terms.

2. Page 8: The School Organisation Plan has been renamed 'Commissioning School Places in Essex' and the current edition is 2011-16.

3. Page 66: the provision of safe direct walking and cycling routes to schools should be included in the vision.

C. BREEAM Assessments

Whilst support is provided to sustainable construction it is noted that the Plan identifies (page 56) a medium term vision that non-residential developments should meet the BREEAM rating of 'Very Good' as a minimum. Essex County Council, with considerable experience in BREEAM assessments, is of the view that more efficient results can be achieved without recourse to BREEAM. The County Council would welcome the opportunity to discuss an appropriate policy approach to sustainable construction with the District Council in place of adherence to BREEAM accreditation.

D. Historic Environment

The recognition of the whole of the historic environment within the Preferred Policy Options Document and most of the relevant draft policies is welcomed. The benefits gained from consulting the Rochford Historic Environment Characterisation project when considering the management and enhancement of the districts environmental quality is well recognised by Section 2, sub section 2.9

The wording for historic environment issues used in the relevant draft polices are supported in respect of,

Draft Policy DM1 (vii)
Draft Policy DM10 (i)
Draft Policy DM11 (i)
Draft Policy DM13 (v)
Draft Policy DM14 (vi)
Draft Policy DM15 (iv)
Draft Policy DM21 (v)
Draft Policy DM23
Draft Policy DM25
Draft Policy DM28

There are three draft polices which would benefit from amendment to address historic environment issues,

a) Draft Policy DM3: Infilling and Intensification, Proposals for infilling, residential intensification or 'backland' development - given that this type of development may occur within historic centres within towns or villages, the policy should include an additional bullet to read,
Any development would not be detrimental to landscape character or the historic environment

b) Draft Policy DM6: Telecommunications - the first sentence of Bullet ii) should be extended by addition of the words 'or historic environment' to clarify and confirm the policy status of the description of 'an undesirable location' set out in parentheses earlier in the sentence.

c) Draft Policy DM12 Conversion of Existing Agricultural and Rural Buildings in the Green Belt - Bullet vi) should also include reference to local listed farm buildings, to read,
vi) where the conversion of listed and local listed agricultural and rural buildings is proposed it should,
(a) not negatively impact on the quality of the listed structure; and
(b) not affect the integrity of the existing structure. A structural engineers report should accompany any application for conversion of a Listed Building

Addition of this reference would make Policy DM12 consistent with Policy DM7 Local List which states 'alterations to buildings included on the Local List must complement the individual character of the building or group of buildings and retain important features or characteristics which make the building(s) worthy of local listing'.


Library Service

The ECC Library Service currently operates from several sites within Rochford District - in Rayleigh, Rochford, Hullbridge and Great Wakering. Service provision of Libraries is based on current population. Any major housing development would be of significant interest in terms of new/additional library provision/services as per ECC's Developer Contribution criteria

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