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: 28322

Received: 27/02/2012

Respondent: Natural England

Representation Summary:

ROCHFORD DISTRICT DEVELOPMENT MANAGEMENT DPD: PREFERRED POLICY OPTIONS
Thank you for your letter dated 16 January 2012, consulting Natural England on the Rochford Development Management DPD: Preferred Policy Options.
As you know, 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.
Overall, we are satisfied that the above DPD adequately considers the impacts of proposed development on the natural environment. A recurring issue that drew our attention was the lack of set time frames for the short, medium and long term visions in each chapter. We recommend that the time periods for the short, medium and long term visions are defined at the outset of each chapter.
The following comments may be of assistance in drafting the pre-submission consultation document.
1. Introduction
Natural England has no specific comments relating to the Introduction section.
2. Housing, Character of Place and Residential Amenity
Natural England supports both the short and medium - long term visions for the district, particularly with regard to the provision of sufficient infrastructure, that the vast majority of the District's Green Belt remains undeveloped and the District's distinctive character is retained.
With regard to the Objectives, Natural England recommends that Objective 8 is amended to read: 'Ensure that new development respects and makes a positive contribution towards the built and natural environment.'
Paragraph 2.5 should identify how the Development Management DPD will seek to reduce the District's carbon emissions and address climate change through planning.

Natural England supports the provisions contained in paragraph 2.11 which aim to mitigate developmental effects on climate change. Natural England suggests that text is inserted to provide guidance on how new buildings are to be designed to adapt to the effects of climate change such as increased flood risk etc.
With regard to Draft Policy DM1 - Design of New Developments, we would suggest that the wording of the first two lines is amended to read 'The design of new developments should reflect the character of the locality to ensure a positive contribution to the surrounding natural and built environment and residential amenity.' Natural England supports points i-xii which set out what the design and layout of proposed development should take into consideration, specifically provision of greenspace and impact on the natural environment including sites of nature conservation importance. Natural England suggests that this section goes further to state that proposed development 'should make appropriate provision for the management of land for nature conservation and the enjoyment of areas of wildlife and geological interest.'
With regard to Infilling and Residential Amenity, Natural England considers it important to note the visual and recreational amenity value of gap sites when considering residential infilling.
With regard to Light Pollution, Natural England supports the statement that 'this type of pollution can have a detrimental effect on ecology and wildlife, obscure vision of the stars, and introduce a suburban feel into rural areas which can thus affect local character and cause stress and anxiety for those adversely affected.' Natural England also supports the three Environmental Zones which set out how applications for lighting proposals will be assessed. We suggest that in paragraph 2.37 (Environmental Zone 1) the text be altered to state that, in Environmental Zone 1, 'lighting proposals that neighbour or are near enough to significantly affect areas of nature conservation importance...will only be permitted in exceptional circumstances, where the applicant can sufficiently demonstrate that unavoidable effects will be minimised through mitigation measures.'
At paragraph 2.44, regarding telecommunications, it is stated that 'Adequate provision will be balanced against ensuring that there are no unacceptable effects on the natural and built environment...' Natural England suggests that the Council elaborates on what unacceptable effects are considered to be, i.e. are slight negative effects considered to be unacceptable or would the term 'unacceptable' be reserved for any significant negative effect?
Natural England supports the broad thrust of Draft Policy DM6 - Telecommunications. However, we suggest that, at paragraph ii, it is stressed that if sited in an undesirable location, telecommunications proposals will only be considered in exceptional circumstances where it has been demonstrated that there are no suitable alternative sites for the development of telecommunication systems.
3. The Green Belt and the Countryside
Natural England supports the vision for the Green Belt and Countryside in Rochford District, in the short, medium and long term. With regard to the objectives, it is advised that Objective 1 is amended to read 'Continue to protect and enhance biodiversity whilst protecting the openness and character of the District's Green Belt.'
With regard to paragraph 3.6, it is suggested that the Council clarifies the meaning of 'other nature conservation designations...' to provide an understanding that does not rely upon having to consult the SEA Baseline Information Profile.
Natural England broadly supports Draft Policy DM13 - Green Tourism. However, we suggest that point (iii) is amended to read '...the impact on important areas of nature conservation, including any potential
disturbance to nearby sites recognised for their importance for biodiversity or geodiversity importance...'
Regarding Agricultural, Forestry and Other Occupational Dwellings, it is recommended that the text in paragraph 3.43 is amended to read 'Careful consideration should be given to the siting of new dwellings to ensure that they meet the identified functional need, but are also well-related to existing buildings and the surrounding natural landscape.'
Natural England broadly supports Draft Policy DM21 - Extension of Domestic Gardens in the Green Belt provided that such extensions do not detrimentally affect the openness of the Green Belt or the conservation value or protection of natural areas of local wildlife value, or sites of national and international importance, as set out in point (vi) of the Policy.
Natural England suggests that further provisions are included in Draft Policy DM22 - Conservation Areas and the Green Belt to protect and enhance areas of biodiversity and geodiversity interest when defining what should be considered acceptable development.
4. Environmental Issues
With regard to the short term vision for Environmental Issues, it is suggested that the text at point 3 is amended to read 'Local, national and international sites of nature conservation importance are protected and enhanced to maintain their biodiversity, geodiveristy and wildlife value.'
At point 3 of the medium term vision, it is suggested that the term 'unnecessary development' is elaborated to include examples of development which would be considered as such, e.g. campsites.
Natural England supports Draft Policy DM24 - Trees and Woodland, specifically in relation to the provision that new woodland creation should be sought, where appropriate.
5. Transport
Natural England broadly supports the general thrust of this Chapter, particularly in its efforts to minimise the impact of traffic on rural character through the reduction of dependency on private cars.
6. Economic Development
Natural England has no specific observations or comments on this chapter.
7. Retail and Town Centres
Natural England would like to see a description of how open space and nature conservation are to be catered for in the urban areas of the District. We note the absence of any provision for recreational space in the town centre, which should be included in the Objectives section.

Full text:

ROCHFORD DISTRICT DEVELOPMENT MANAGEMENT DPD: PREFERRED POLICY OPTIONS
Thank you for your letter dated 16 January 2012, consulting Natural England on the Rochford Development Management DPD: Preferred Policy Options.
As you know, 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.
Overall, we are satisfied that the above DPD adequately considers the impacts of proposed development on the natural environment. A recurring issue that drew our attention was the lack of set time frames for the short, medium and long term visions in each chapter. We recommend that the time periods for the short, medium and long term visions are defined at the outset of each chapter.
The following comments may be of assistance in drafting the pre-submission consultation document.
1. Introduction
Natural England has no specific comments relating to the Introduction section.
2. Housing, Character of Place and Residential Amenity
Natural England supports both the short and medium - long term visions for the district, particularly with regard to the provision of sufficient infrastructure, that the vast majority of the District's Green Belt remains undeveloped and the District's distinctive character is retained.
With regard to the Objectives, Natural England recommends that Objective 8 is amended to read: 'Ensure that new development respects and makes a positive contribution towards the built and natural environment.'
Paragraph 2.5 should identify how the Development Management DPD will seek to reduce the District's carbon emissions and address climate change through planning.

Natural England supports the provisions contained in paragraph 2.11 which aim to mitigate developmental effects on climate change. Natural England suggests that text is inserted to provide guidance on how new buildings are to be designed to adapt to the effects of climate change such as increased flood risk etc.
With regard to Draft Policy DM1 - Design of New Developments, we would suggest that the wording of the first two lines is amended to read 'The design of new developments should reflect the character of the locality to ensure a positive contribution to the surrounding natural and built environment and residential amenity.' Natural England supports points i-xii which set out what the design and layout of proposed development should take into consideration, specifically provision of greenspace and impact on the natural environment including sites of nature conservation importance. Natural England suggests that this section goes further to state that proposed development 'should make appropriate provision for the management of land for nature conservation and the enjoyment of areas of wildlife and geological interest.'
With regard to Infilling and Residential Amenity, Natural England considers it important to note the visual and recreational amenity value of gap sites when considering residential infilling.
With regard to Light Pollution, Natural England supports the statement that 'this type of pollution can have a detrimental effect on ecology and wildlife, obscure vision of the stars, and introduce a suburban feel into rural areas which can thus affect local character and cause stress and anxiety for those adversely affected.' Natural England also supports the three Environmental Zones which set out how applications for lighting proposals will be assessed. We suggest that in paragraph 2.37 (Environmental Zone 1) the text be altered to state that, in Environmental Zone 1, 'lighting proposals that neighbour or are near enough to significantly affect areas of nature conservation importance...will only be permitted in exceptional circumstances, where the applicant can sufficiently demonstrate that unavoidable effects will be minimised through mitigation measures.'
At paragraph 2.44, regarding telecommunications, it is stated that 'Adequate provision will be balanced against ensuring that there are no unacceptable effects on the natural and built environment...' Natural England suggests that the Council elaborates on what unacceptable effects are considered to be, i.e. are slight negative effects considered to be unacceptable or would the term 'unacceptable' be reserved for any significant negative effect?
Natural England supports the broad thrust of Draft Policy DM6 - Telecommunications. However, we suggest that, at paragraph ii, it is stressed that if sited in an undesirable location, telecommunications proposals will only be considered in exceptional circumstances where it has been demonstrated that there are no suitable alternative sites for the development of telecommunication systems.
3. The Green Belt and the Countryside
Natural England supports the vision for the Green Belt and Countryside in Rochford District, in the short, medium and long term. With regard to the objectives, it is advised that Objective 1 is amended to read 'Continue to protect and enhance biodiversity whilst protecting the openness and character of the District's Green Belt.'
With regard to paragraph 3.6, it is suggested that the Council clarifies the meaning of 'other nature conservation designations...' to provide an understanding that does not rely upon having to consult the SEA Baseline Information Profile.
Natural England broadly supports Draft Policy DM13 - Green Tourism. However, we suggest that point (iii) is amended to read '...the impact on important areas of nature conservation, including any potential
disturbance to nearby sites recognised for their importance for biodiversity or geodiversity importance...'
Regarding Agricultural, Forestry and Other Occupational Dwellings, it is recommended that the text in paragraph 3.43 is amended to read 'Careful consideration should be given to the siting of new dwellings to ensure that they meet the identified functional need, but are also well-related to existing buildings and the surrounding natural landscape.'
Natural England broadly supports Draft Policy DM21 - Extension of Domestic Gardens in the Green Belt provided that such extensions do not detrimentally affect the openness of the Green Belt or the conservation value or protection of natural areas of local wildlife value, or sites of national and international importance, as set out in point (vi) of the Policy.
Natural England suggests that further provisions are included in Draft Policy DM22 - Conservation Areas and the Green Belt to protect and enhance areas of biodiversity and geodiversity interest when defining what should be considered acceptable development.
4. Environmental Issues
With regard to the short term vision for Environmental Issues, it is suggested that the text at point 3 is amended to read 'Local, national and international sites of nature conservation importance are protected and enhanced to maintain their biodiversity, geodiveristy and wildlife value.'
At point 3 of the medium term vision, it is suggested that the term 'unnecessary development' is elaborated to include examples of development which would be considered as such, e.g. campsites.
Natural England supports Draft Policy DM24 - Trees and Woodland, specifically in relation to the provision that new woodland creation should be sought, where appropriate.
5. Transport
Natural England broadly supports the general thrust of this Chapter, particularly in its efforts to minimise the impact of traffic on rural character through the reduction of dependency on private cars.
6. Economic Development
Natural England has no specific observations or comments on this chapter.
7. Retail and Town Centres
Natural England would like to see a description of how open space and nature conservation are to be catered for in the urban areas of the District. We note the absence of any provision for recreational space in the town centre, which should be included in the Objectives section.

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