Development Management Submission 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,
* Chapter 4, Objectives, page 62 - insert an additional objective to read, 'Ensure that the vulnerability to climate change impacts is minimised by the development proposal and that such development will not increase the vulnerability from climate change impacts.'

The Document should note in Paragraph 4.3 that since adoption of the Core Strategy the eastern part of the District has been included in the Greater Thames Marshes Nature Improvement Area.

Paragraph 2.33 - the requirement that 'All non-habitable rooms should be of an adequate size, height and shape, with sufficient natural lighting, and be ventilated directly by external air via a window.' is very prescriptive given the specified exclusions from the definition of habitable floorspace in Paragraph 2.25. The text should be amended such that only rooms in excess of 3 sq m should meet these requirements. This would ensure, for instance, that bathrooms had a window but a shower room or separate toilet facilities did not need to have a window.

Essex County Council, as the Mineral and Waste Planning Authority, welcomes and fully supports the reference to the Minerals and Waste Local Plans (Paragraph 1.12) and the Document's thorough identification of waste storage and management provision for new development. However, in view of the known minerals resources existing in the District reference should be made to the Mineral Safeguarding Areas and Mineral Consultation Areas identified through Policy S8 (Safeguarding mineral resources and mineral reserves) in the Replacement Minerals Local Plan, January 2013. To ensure compatibility and consistency between the Development Management Document and the Minerals Local Plan a sentence should be added to Paragraph 1.12, to read,
'Parts of Rochford District lie within a Minerals Safeguarding Area and therefore consultation on the proposed development of the site with Essex County Council is required'

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,

* Policy DM13 - Conversion of Existing Agricultural and Rural Buildings in the Green Belt
(vi) there would be no detrimental impact on nature conservation or historic environment interests
Reason: To ensure that the heritage is appropriately protected during conversion.

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,
* Chapter 4, Vision, page 61 - insert additional text into the Vision to read,
Short term:
* Local, regional and national sites of historic environment importance are protected
Medium Term
* Local, regional and national sites of historic environment importance are being both protected and enhanced
Long term
* Historic environment assets are protected and managed for the future and are an integral part of the local sense of Place.

The Document should give positive support for the improvement and expansion of existing schools. Schools evolve over time to reflect changes in educational practice and operational requirements that better meet, and improve, future educational quality and standards. This results in proposals for remodelling and reconfiguration of school sites that are likely to require extension of buildings beyond the existing built footprint on school sites. It may not be possible to obtain the required educational outcomes without using parts of school playing fields which may be designated also as lying within the Green Belt.
Retaining Green Belt status for school playing fields would not offer sufficient flexibility to attain the intent of Core Strategy Objective 2 (Page 90) due to some school expansion proposals necessarily extending across the Green Belt boundary. Core Strategy Policy CLT2 (Primary Education, Early Years and Childcare Facilities) and Policy CLT3 (Secondary Education) do not fill the void. Consequently, a new and additional policy should be added to the Document, to read,

'Policy *****: Existing Education Provision
The re-modelling and expansion of primary and secondary schools, including necessary development on school playing fields will be supported to meet local need.'

With supporting text, to read,

'There are 21 existing primary schools and 4 secondary schools (July 2012) in the District. There is a need for these important facilities to continue to be fit for purpose to deliver high standard education provision. Where schools are retained in education use the Council will support their re-modelling and expansion to meet local need.'