Allocations Submission Document

ROCHFORD SITE ALLOCATIONS SUBMISSION DOCUMENT

Thank you for your letter dated 29 November 2012 consulting English Heritage on above documents.

We note that you propose to continue to prepare several development plan documents (DPDs) and these will combine to form your Local Plan. The Area Action Plans for the three main centres and for Southend Airport will be brought forward separately, and we look forward to consultations on those in due course. A consultation on your Development Management Policies DPD is due shortly. All of these will sit within the recently adopted Core Strategy. With the publication of the National Planning Policy Framework (NPPF) it will be important that all the documents taken together provide the appropriate policy coverage. In this context, we would like to make some general comments regarding the NPPF policy approach to the historic environment.

General Comments

The NPPF provides greater clarity than previous national policy guidance regarding the place of the historic environment among issues that contribute to sustainable development. Paragraphs 7 and 8 of the Framework are especially relevant. The identification of the historic environment within the core planning principles (paragraph 17) underpinning plan-making and decision-taking further underlines the importance of heritage considerations.

In the context of the NPPF, it would be appropriate to consider if there is a need to reflect the historic environment strand more strongly in the DPDs that take forward the adopted Core Strategy. The Core Strategy contains some important references to the historic environment in the objectives for Chapter 5 Character of Place, and Chapter 8 Environmental Issues. The evidence base for the historic environment referred to in the Core Strategy in terms of the Historic Environment Characterisation report, Conservation Area Appraisals and Management Pans is helpful. However, the policies relating to the historic environment are not as detailed as they could be, to take forward the positive approach to the historic environment that the NPPF recommends (paragraph 126). The emphasis on 'heritage at risk' in paragraph 126 is also a matter we would hope to see taken forward in local plan policies for Rochford.

We hope that the Council will consider how the historic environment can be promoted in all the development plan documents that are now coming forward, to reflect the approach set out in national policy.

Site Allocations DPD

I attach a schedule of detailed comments on the specific aspects of the Site Allocations DPD. Where we have expressed concern, we would like the comments to be treated as a formal objection to the soundness of the plan in terms of consistency with national guidance for the historic environment. We hope, however, that we will be able to discuss these concerns with you, with a view to agreeing modifications to the plan.

General matters

There are some points that arise throughout the plan text which we have some concerns about. These are as follows:

1. Archaeology
There are no references to the archaeological interest, or potential interest, in the policies and text for the individual site allocations. To take forward Core Strategy policy ENV1, and to be in line with the guidance in the National Planning Policy Framework (NPPF), we recommend that the allocations are reviewed for their sensitivity.

If it has not already been obtained, advice should be sought from the county archaeologist. Where evaluation of sites reveals significant archaeological interest, revisions to the plan should be made in accordance with the significance of the remains. We would expect additional requirements to be added to the parameters for development set out in the individual site allocation policies, as appropriate.

2. Sustainable Urban Drainage (SUDs)
We understand the need for the plan to make provision for SUDs in the individual development sites. A standard set of words is used, for instance in paras 3.94, 3.281, and 5.48. It should, however, be noted, perhaps in the introductory sections of the plan, that balancing ponds, swales, changes to the water table and so on can, like other forms of development, have significant impacts on below ground archaeology, and these will need to be taken into account.

3. Implementation, Delivery and Monitoring, section 10
This section does not refer to any risks associated with sites that contain heritage assets, or below ground archaeology. While we do not make this a point of objection, the plan should seek opportunities for positive enhancement of the historic environment in appropriate circumstances, perhaps in the form of compensatory gains.

4. The setting of heritage assets
We note that in the case of several proposed site allocations that the need to protect the setting of heritage assets on adjoining land has been recognised. We welcome this. English Heritage's guidance may be of assistance in considering this matter.