Development Management Submission Document

For the avoidance of doubt on Rochford District Council's stance with regard to planning obligations and standard charges the Document should make reference to Policy CLT1 of the Core Strategy and the separate Planning Obligations and Standard Charges Document. This could be achieved through a minor alteration to the text within Table 1 of the Document.

The references to climate change in the Document are welcomed, particularly those in paragraphs 2.5, 2.11 and 2.12 of the Document. However, the risk from climate change should be embedded and considered elsewhere in the Document, for instance,
* Paragraph 1.4, point 4 - by addition of the words, 'and also considers measures to address the impacts from a changing climate.'

Introduction: Paragraph 1.29 - the Evidence Base includes no reference to any research or reports on climate change. The following should be added,
* A Summary of Climate Change Risks for the East of England -To coincide with the publication of the UK Climate Change Risk Assessment (CCRA) 2012 by Sustainability East - http://www.sustainabilityeast.org.uk/index.php?option=com_content&view=article&id=128:uk-climate-change-risk-assessment&catid=5:latest-news&Itemid=9
* UK Climate Change Risk Assessment - Built Environment http://randd.defra.gov.uk/Document.aspx?Document=CCRASummaryBuiltEnvironment.pdf and full Built Environment report: http://randd.defra.gov.uk/Document.aspx?Document=CCRAfortheBuiltEnvironmentSector.pdf (Information on NAP: http://www.defra.gov.uk/environment/climate/government/nap/ )
* Planning and Climate Change Coalition (2012) planning for climate change -guidance for local authorities, TCPA - http://www.tcpa.org.uk/data/files/PCC_Guide_April_2012.pdf
* Climate Ready Programme for Built Environment http://www.environment-agency.gov.uk/research/policy/132333.aspx
* Shaw, R., Colley, M. and Connell, R (2007) Climate change adaptation by design: a guide for sustainable communities. TCPA, London - http://www.tcpa.org.uk/pages/climate-change-adaptation-by-design.html
* North West Green Infrastructure Valuation Toolkit - http://www.greeninfrastructurenw.co.uk/html/index.php?page=index
* Henderson, K. (2009) The Case for Climate Change Adaptation, TCPA - http://www.tcpa.org.uk/data/files/GXP1adaptation.pdf

In order to meet the requirements of the National Planning Policy Framework and to more clearly support Rochford District Council's objectives for the historic environment additional text should be included in the Document, to read,

* Page 3 section 4: 'This chapter sets out detailed policies for historic and natural environment, air quality and houseboats'.

The references in the Document to support the ageing population are supported. Attached is the Essex County Council draft strategy 'Housing for People with Additional Needs Strategy 2013-2016' which could usefully be added to the Evidence Base at Paragraph 1.29.

The National Planning Policy Framework (Section 10, paragraph 94), the 40-100 year lifespan of development and the fact that climate change predictions are locked in for the next 30-40 years means that all opportunities should be taken to incorporate adaptive capacity from the beginning of the development. The references to the Code for Sustainable Homes and BREEAM are noted but these standards need to be supported by adaptation measures such as climate proofing through the use of green infrastructure assets. Specific measures associated with enhancing the natural environment/biodiversity adaptation to climate change can be expected to generate social, economic and cultural co-benefits as well as reduce the negative effects of climate change. Accordingly, the Document should include a requirement that all developments should address climate change through appropriate use of adaptation, mitigation and renewables. Ideally, this should be through addition of a new Policy to read,

'Policy - Addressing Climate Change
New or redevelopment will be considered acceptable, provided that:

I. It has considered climate change adaptation measures and technology from the outset including reduction of emissions, renewable and low carbon, passive design, and through green infrastructure techniques where appropriate.
II. That vulnerability to climate change impacts is minimised and that such development does not increase vulnerability to climate change impacts.
III. The potential effects of climate change on the development is taken into consideration, such as:
a. Water conservation and drainage
b. Need for summer cooling
c. Risk of subsidence
d. Flood risk from fluvial and surface water
IV. Associated activities adhere to local, regional and national targets for reducing carbon emissions.
V. Consideration of on-site small scale renewable or low-carbon technology where appropriate such as solar panels, geothermal heat pumps, small-scale wind turbine, photovoltaic cells, Combined Heat and Power etc.
VI. Measures to connect to off-site, decentralised energy networks (e.g. District Heating) either at commissioning or in the future are considered.'

To assist review development proposals for appropriate climate change measures, the District Council could use a checklist similar to that developed by Hertfordshire County Council by asking 'Has the building or development been designed to be resilient to the expected impacts of climate change (including flood risk) during the expected lifetime of the building(s)?'. An example of Hertfordshire Building Futures Adaptation Checklist can be found here:
http://www.hertslink.org/buildingfutures/16557273/16766291/

The references to climate change in the Document are welcomed, particularly those in paragraphs 2.5, 2.11 and 2.12 of the Document. However, the risk from climate change should be embedded and considered elsewhere in the Document, for instance,
* Chapter 3, Objectives, page 34 - insert an additional objective to read, 'Plan positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure and will identify opportunities to incorporate adaptation measures that will address risks associated with climate change'.

Page 70, Paragraph 4.30 - should be deleted in its entirety and replaced by a new paragraph.

The current paragraph incorrectly states that Essex County Council is the authority responsible for the determination of planning applications for SuDS. Rochford DC is the authority responsible for the determination of planning applications for SuDS. Essex County Council currently has only a non-statutory consultee/advisory role in respect of the SuDS aspects of planning applications. The Environment Agency is currently the main statutory consultee on SuDS aspects of planning applications. However, from April 2014 (to be confirmed) it is expected that Essex County Council will take on its duties under the Flood & Water Management Act 2010 as a SuDS Approving Body (SAB), whereupon any proposal for construction work which has surface water drainage implications will require prior approval from the County Council. It is understood this will be a separate but parallel procedure to the planning application process.

Accordingly, the existing paragraph 4.30 should be deleted in its entirety and replaced by a new paragraph, to read,
" Whilst the Local Planning Authority is currently the authority responsible for the determination of planning applications for SuDS, it is expected that Essex County Council will become the SuDS Approving Body (SAB) by the enactment of Schedule 3 of the Flood and Water Management Act 2010, which is likely to be from April 2014. This means that all new development which has surface water drainage implications will potentially require SAB approval and need to conform to National and Local Standards. Essex County Council will be strongly promoting the management of rainfall at the surface and therefore the use of above ground SuDS features (e.g. swales, filter strips, basins. ponds and wetlands etc.) will be required rather than pipes, soakaways and underground storage structures, as these bring more benefits to the community in their amenity and biodiversity value as well as being easier and more economical to maintain and need not be more expensive to install. Also, SuDS proposals which provide for limiting surface water runoff rates from the site to existing greenfield rates will be expected. For further information and enquiries, please contact Essex County Council's SuDS team at suds@essex.gov.uk."

Appendix 1 (Advice on the Design of Waste and Recyclables Storage and Collection Requirements)
Essex County Council, as the Local Highway Authority, recommends that access roads should be designed in accordance with the Essex Design Guide 2005, Urban Place Supplement 2007 and the Department for Transport's Manual for Streets 2 which allow the use of 4.8 metre minimum width roads for refuse collection vehicles. Accordingly, the following texts should be amended to reflect this situation,
Page 96, Appendix 1, Section 7, penultimate paragraph, fourth bullet (General Considerations for Refuse Collection Vehicles) - 'access roads need to be a minimum of 5 metres wide.' and,
Page 98, Appendix 1, Section 12 first paragraph (Refuse Collection Vehicle Size & Turning Area) - 'the construction of all access roads for refuse collection vehicles should be in accordance with the Department for Transport's Design Manual for Roads and Bridges.'

The references to climate change in the Document are welcomed, particularly those in paragraphs 2.5, 2.11 and 2.12 of the Document. However, the risk from climate change should be embedded and considered elsewhere in the Document, for instance,
* Chapter 4, Vision, page 61 - insert additional text into the Vision to read,
o Short term - 'Consideration to be taken into account of the risks to new developments and refurbishments form extreme weather as experienced now to help communities to adapt over the long term.'
o Long term - 'Climate change adaptation measures and technology to be considered from the outset in any development proposal including reduction of emissions, renewable and low carbon technologies, passive design, and through the application of green infrastructure techniques where appropriate.'