New Local Plan: Spatial Options Document 2021
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New Local Plan: Spatial Options Document 2021
Q1. Are there any other technical evidence studies that you feel the Council needs to prepare to inform its new Local Plan, other than those listed in this section?
Representation ID: 40376
Received: 22/09/2021
Respondent: Essex County Council
It is noted that further additional technical evidence is required to support the final strategy and site allocations. This consultation is the first opportunity for ECC to respond to RDC’s strategic growth options where, in broad terms has been informed by proposed sites, which are still to be fully assessed through site selection. ECC will work with RDC to progress the necessary evidence through the next stage of Plan preparation to inform the Preferred Options.
In addition to the list of technical studies completed/to be commissioned to support the preparation of the Local Plan, ECC consider the following strategies and evidence to be of relevance to the preparation of the new Local Plan going forward:
1. It is recommended that reference is made to ECC as the Upper tier authority for the Rochford District administrative area, and the preparation of the new Local Plan should be informed by, and set out, the county strategic policy context. ECC welcome and support reference to the ASELA and South Essex Strategic context, however it is also necessary to present the county context for the provision and delivery of infrastructure and services to inform and promote a sustainable pattern of development that seeks to: meet the development needs of their area; align growth and infrastructure; improve the environment and mitigate and adapt to climate change (including by making effective use of land in urban areas).
For example, the new Local Plan is required to be prepared in conformity with the adopted Essex Minerals Local Plan (MLP) and the Essex and Southend-on-Sea Waste Local Plans (WLP) and this will inform the context of the new Rochford Local Plan. It should be noted that the MLP and WLP also form part of Rochford’s Development Plan at the “local” level, rather than “regional” as presented in Figure 6. This should be stated as such in the Preferred Options document.
2. There are a range of relevant strategies produced either solely by ECC or in collaboration with the Essex borough, city, district councils, and the Greater Essex unitary authorities including Southend BC and Thurrock Council, and these are listed below. This has been and is provided as ECC evidence for context and consideration to inform the preparation of the Local Plan and ongoing discussions under the Duty:
ECC Plan
• ECC Everyone’s Essex – Our draft plan for 2021 to 2025
ECC Highways and Transportation
• Essex Transport Strategy, the Local Transport Plan for Essex (June 2011)
• A127 Corridor for Growth - An Economic Plan 2014 (A127 Route Management Strategy)
• A127 Air Quality Management Plan - (Strategic Outline Case) March 2018
• Safer Greener, Healthier Communities
• Essex Cycling Strategy (2016), Essex Cycle Action Programme, and Rochford District Cycling Action Plan (2018)
• The Essex Walking Strategy
• Getting around in Essex - A bus and passenger transport strategy
• Highways Development Management Policies (2011)
• Essex Parking Standards Design and Good Practice (2009)
ECC Infrastructure Planning
• ECC Developers’ Guide to Infrastructure Contributions (2020)
ECC Education
• School Organisation 10 Year Plan for Essex school places 2021-2030
• Local and Neighbourhood Planners’ Guide to School Organisation
• Childcare Sufficiency Assessment Summary
Economic Growth
• Essex Economic Commission, January 2017
• Economic Plan for Essex (April 2014)
ECC Waste Management
• Joint Municipal Waste Management Strategy for Essex (2007 - 2032)
ECC Minerals and Waste Planning
• Essex Minerals Local Plan 2014
• Essex and Southend-on-Sea Waste Local Plan 2017
ECC Lead Local Flood Authority
• ECC Sustainable Drainage Systems Design Guide (February 2020)
• ECC Revised Critical Drainage Areas and South Essex Surface Water Management Plan – Acton Plan (see Appendix A)
ECC Housing Strategy
• Essex Housing Strategy 2021-2025
Greater Essex
• Essex Design Guide
• Essex Green Infrastructure Strategy (2020)
3. Whilst it is noted that RDC have/are commissioning additional technical evidence, ECC has identified the following aspects to be addressed to inform the preparation of the draft Plan.
• Transport evidence and assessment of the active and sustainable travel network (walking, cycling and passenger transport - bus infrastructure, networks and services), including a gap analysis of the existing networks to identify gaps and additional infrastructure provision required to inform and deliver modal shift. This includes, but extends beyond the recommendation to prepare (in collaboration with ECC) a Local Walking and Cycling Infrastructure Plan and Passenger Transport (LCWIP).
• Transport Modelling – ECC notes RDC is commissioning transport modelling in liaison with ECC and recommend the use of the South Essex Transport Mode; and a full transport network assessment, to identify transport mitigation for junctions impacted by the Local Plan development having regard to the existing traffic pressures and pinch points and to identify a transport solution which includes sustainable transport networks. (see Q28 & Q51 – 53)
• A review of case studies to explore whether or not employment allocations in new large developments are achieving the local types of trips which are desired or in fact just further dispersing trips across the district.
• Economic Need and Employment Evidence to refine the level of economic growth to be planned for as part of a balanced strategy, and to take into account changes post pandemic economic recovery including change in needs such as increased home working, flexible home and business accommodation, importance of digital technology, future growth of London Southend Airport and opportunities for local low carbon energy provision; as well as approaches to improve provision and quality for B1a/b uses.
• Review of the Site Appraisal Process to include an assessment of the safeguarding/consultation areas within policy S8 and policy 2 respectively of the MLP and& WLP (see Q6 and Appendix B). There is also a need to reassess the Passenger Transport Scores and to correct the distances to train stations.
• Review and capacity assessment of surface water management infrastructure capacity review within existing urban areas to manage and mitigate the impacts of urban intensification including the provision of additional dedicated surface water management infrastructure.
• IDP and Viability Assessments – note that these are to be commissioned and ECC will work with RDC in preparation of Infrastructure Delivery Plan (IDP), based on ECC infrastructure and service requirements. It is recommended that consideration is given to how these would apply to both district wide policies and strategic sites and mechanisms for delivery of any larger scale developments or strategic infrastructure, including preparation of Implementation Delivery Strategies, to clearly define funding, phasing and delivery as appropriate. ECC can assist in viability assessment and would welcome the opportunity to be involved in this aspect of plan evidence.
Comment
New Local Plan: Spatial Options Document 2021
Q2. Do you agree with our draft vision for Rochford District?
Representation ID: 40377
Received: 22/09/2021
Respondent: Essex County Council
Our Economy
Suggest consideration is given to the identifying an optimal location for science, medical and technology sectors, as part of the strategic spatial options and site appraisal. For example, east of Rochford / north of Prittlewell may provide a new mixed use area including high-productivity employment uses.
Vision (p20)
Greater emphasis should be placed on the enhancing the provision of the transport network and in particular the active and sustainable transport network for walking, cycling and passenger transport including buses to increase connectivity and accessibility to underpin and deliver the aspirations in the vision. (See Q51)
Comment
New Local Plan: Spatial Options Document 2021
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
Representation ID: 40378
Received: 22/09/2021
Respondent: Essex County Council
There is a need for a clear over-arching vision, to provide clarity for the draft Plan to 2050, which extends beyond the 2040 Plan period. Within the overarching vision there is potential for focussed visions to be developed, these could include:
• A vision for London Southend Airport, in recognition of the importance of the Airport for the local and South Essex economy for existing and future residents. (See Q28)
• A vision for Baltic Wharf, as an international gateway
• Visons for the main town centres, with a focus on the regeneration
• Visions for the respective growth areas and / or the respective cluster of settlements within chapter 8
Comment
New Local Plan: Spatial Options Document 2021
Q4. Do you agree with the strategic priorities and objectives we have identified?
Representation ID: 40389
Received: 22/09/2021
Respondent: Essex County Council
ECC suggest the following aspects are included in a review of the Strategic Priorities and Strategic Objectives.
• Provision of an explicit overarching Health and Wellbeing objective (see Q8)
• Housing design and layout - need for flexibility, the ability to adapt homes over time (Lifetime Homes), and support homeworking
• Businesses – need for flexible and adaptable accommodation in town centres
• Provision for transport network improvements, especially active and sustainable transport networks, to support modal shift for existing and new communities (residents and business) and consider setting targets for example
• Need to balance the promotion of green tourism and protecting the environment
• Include reference to the Essex SuDS Design Guide for new development, including intensification in urban areas (See Q8).
• Need to plan to future proof transport infrastructure, including provision for vehicle e-charging points, and cycle storage
• Consideration to merge some of the Strategic Objectives as there appear to be many overlaps with content
ECC welcomes the following Strategic Objectives: -
• SO 3, 4, 5, 6 and support the focus of growth of the local economy to minimise out commuting and to focus on the provision of local jobs and employment. Suggest emphases is placed on improving / retaining existing employment sites
• SO21 to retain landscape character and value of the coastal areas
• SO12 approach to Minerals and Waste planning.
Comment
New Local Plan: Spatial Options Document 2021
Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
Representation ID: 40392
Received: 22/09/2021
Respondent: Essex County Council
The impacts of growth and future development that will likely be set out within the emerging Local Plan will need to be assessed, including infrastructure requirements, any mitigation, and how they will be funded and delivered.
In respect of larger scale developments consideration will need to be given to planning beyond the Plan period for up to 30 years ahead as set out in the revised NPPF.
ECC note that the Spatial Strategy Options include the potential for cross boundary developments, ECC would expect to be fully engaged in any relevant discussions to ensure the consideration on ECC’s infrastructure and services, such as education and transportation and highways.
Housing Growth Scenario
ECC welcome and support the identified need to plan for housing, economic growth and retail and in particular the need to plan for the right amount of growth with regard to infrastructure; and the reference to the ECC Developers’ Guide to Infrastructure Contributions (2020) (ECC Developers’ Guide), and scales of development required to deliver infrastructure. However, this is a starting point, and ECC will work with RDC to refine the infrastructure and service requirements as the growth options are refined.
Growth Scenario 1 (current trajectory). ECC do not consider this option to be consistent with the NPPF and PPG.
Growth Scenarios 2 (Standard Methodology). ECC consider this option consistent with NPPF and would be supported.
Growth Scenario 3 (Standard Methodology +50%). ECC would support this option but RDC will need sound evidence to justify the rationale for the +50% uplift. It is noted that through the Housing Delivery Test a 20% buffer is applied where delivery is not met. This may be a more appropriate range and has been adopted by other Essex authorities.
ECC recommend further work is undertaken on the Economic Development Needs Assessment to clarify the economic needs to understand the requirements and implications for future economic growth. At present the range from 7ha – 40ha is too broad. (see Q23 – 28)
Spatial Strategy Options
ECC welcomes that RDC are seeking to consider a range of potential spatial strategy options and welcomes engagement in the identification of any future strategy given our role as an infrastructure and service provider.
ECC would anticipate a Spatial Strategy Options 1 to 4 to be developed and refined, in accordance with the requirements set out in the revised NPPF. Namely for the new Local Plan to positively seek opportunities promote a sustainable pattern of development in accordance with the NPPF - meet the development needs of their area, align growth and infrastructure, improve the environment; mitigate climate change (including by making effective use of land in urban areas).
Option 1 (Urban Intensification). ECC note that this option alone, would not deliver the level of growth required to be planned for in accordance with the revised NPPF. The inclusion of this option within Options 2 -4, could provide for a more balanced approach, and the opportunity promote and regenerate the existing town centres, through some intensification using existing infrastructure to access employment opportunities via public transport. However, there may be limitations on the scale of intensification that could be achieved and the LLFA will require additional evidence to assess the capacity, including potential need for additional dedicated surface water management provision. (see Q9).
Option 2b. ECC would not support option 2b (proportionate distribution). ECC do not consider such a ‘pepper pot’ approach would deliver or secure necessary sustainable development and would limit opportunities for securing significant infrastructure improvements. It is likely to increase demands on existing provision, with limited capacity to expand to meet the needs of the existing and new communities, as such the scale and pattern of new growth options should be informed by the capacity of existing services to expand and that the level of growth is at a scale to secure delivery of viable and sustainable infrastructure required to support the new communities.
Options 2a and 3 provide the opportunity through large scale developments to secure the delivery of viable and sustainable large-scale infrastructure such as a secondary school or transformational infrastructure for the connectivity and the movement of people and goods.
See Q 51, identifying a range of cross boundary matters to be addressed with ECC and respective neighbouring authorities and their emerging Local Plans.
Larger Scale Developments
In accordance with the NPPF, ECC recommend that the strategic plan-making for larger scale development (such as new settlements or significant extensions to existing villages and towns form part of the strategy) policies should be set within a vision that looks further ahead (at least years), to take into account the likely timescale for phasing, infrastructure, investment, implementation delivery, and may need to consider greater provision given increase in timeframe. Whilst there is no definition of “larger-scale development” given it depends upon the context, scale and setting, ECC consider Option 2a and 3 to be applicable, and should be considered in accordance with NPPF (paragraph 73), which recognises the supply of large numbers of new homes can often be best achieved through planning for larger scale development, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
ECC would anticipate RDC working with ECC under the Duty to identify suitable locations for such development, to meet identified needs in a sustainable way. This should: consider the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains.
This is particularly relevant given the range of identified constraints and the necessary scale of growth required for the provision of a new secondary school, which for ECC as set out in the ECC Developers’ Guide, is a 6 Form of Entry school, requiring 4,500 new homes (see Q35). Please note, Government is considering providing guidance on the evidence base required to support a 30 year vision, which will significantly differ from a 15 year plan period.
Two of the three Concentrated Growth Options (3a and 3b) are identified as possible cross boundary development. ECC would expect to be a partner to any discussions and exploration of such proposals, to ensure the wider strategic infrastructure requirements such as transport and education are fully considered. ECC would seek formal working arrangements and mechanisms to be set up under the Duty, including Memoranda of Understanding and Statements of Common Ground, that would agree the approach, strategic outcomes and cross boundary matters, and may well cover design principles, funding, phasing and delivery mechanisms.
As indicated in option 4 (balanced combination) any spatial strategy option should seek to provide a mix of sites at different scales in order to ensure that any future five housing year supply could be managed, particularly if any large allocation is delayed and/or consideration given to its lead in time.
However, there remains a risk of significant development in a location overwhelming secondary school capacity without a critical mass of housing sufficient for a new school. On this point, ECC would require any future mix, scale of patten of delivery to be fully assessed to achieve the right balance to fully mitigate any impacts, secure the necessary developer funding and provision for the necessary supporting infrastructure and services.
ECC would expect any large developments to be planned for having regard to clear place making design principles and guidance as outlined below and in the response to Q51, and these should be incorporated in any RDC Place Charter (see Q15).
• Essex Design Guide principles, aligning with active design and, garden community principles, including those related to health and wellbeing. (See Q8, Q12 & Q15)
• A Net Zero Future as set out in the ECAC Report 2021 (see Q12,Q12 & Q15)
• A high delivery of multi-functional green infrastructure (GI) and biodiversity net-gain - to align with the nine principles to delivering good GI and the emerging Essex GI Standards Guidance prepared in consultation with Natural England. Such an approach would be consistent with the South Essex GI Study.
• Designed to actively promote modal shift through active and sustainable travel and passenger transport provision, promoting walkable neighbourhoods, traffic free areas and “traffic free” school zones” (see Q51).
The impacts of growth and future development that will likely be set out within the emerging Local Plan will need to be assessed, including infrastructure requirements, any mitigation, and how they will be funded and delivered.
In respect of larger scale developments consideration will need to be given to planning beyond the Plan period for up to 30 years ahead as set out in the revised NPPF.
ECC note that the Spatial Strategy Options include the potential for cross boundary developments, ECC would expect to be fully engaged in any relevant discussions to ensure the consideration on ECC’s infrastructure and services, such as education and transportation and highways.
Housing Growth Scenario
ECC welcome and support the identified need to plan for housing, economic growth and retail and in particular the need to plan for the right amount of growth with regard to infrastructure; and the reference to the ECC Developers’ Guide to Infrastructure Contributions (2020) (ECC Developers’ Guide), and scales of development required to deliver infrastructure. However, this is a starting point, and ECC will work with RDC to refine the infrastructure and service requirements as the growth options are refined.
Growth Scenario 1 (current trajectory). ECC do not consider this option to be consistent with the NPPF and PPG.
Growth Scenarios 2 (Standard Methodology). ECC consider this option consistent with NPPF and would be supported.
Growth Scenario 3 (Standard Methodology +50%). ECC would support this option but RDC will need sound evidence to justify the rationale for the +50% uplift. It is noted that through the Housing Delivery Test a 20% buffer is applied where delivery is not met. This may be a more appropriate range and has been adopted by other Essex authorities.
ECC recommend further work is undertaken on the Economic Development Needs Assessment to clarify the economic needs to understand the requirements and implications for future economic growth. At present the range from 7ha – 40ha is too broad. (see Q23 – 28)
Spatial Strategy Options
ECC welcomes that RDC are seeking to consider a range of potential spatial strategy options and welcomes engagement in the identification of any future strategy given our role as an infrastructure and service provider.
ECC would anticipate a Spatial Strategy Options 1 to 4 to be developed and refined, in accordance with the requirements set out in the revised NPPF. Namely for the new Local Plan to positively seek opportunities promote a sustainable pattern of development in accordance with the NPPF - meet the development needs of their area, align growth and infrastructure, improve the environment; mitigate climate change (including by making effective use of land in urban areas).
Option 1 (Urban Intensification). ECC note that this option alone, would not deliver the level of growth required to be planned for in accordance with the revised NPPF. The inclusion of this option within Options 2 -4, could provide for a more balanced approach, and the opportunity promote and regenerate the existing town centres, through some intensification using existing infrastructure to access employment opportunities via public transport. However, there may be limitations on the scale of intensification that could be achieved and the LLFA will require additional evidence to assess the capacity, including potential need for additional dedicated surface water management provision. (see Q9).
Option 2b. ECC would not support option 2b (proportionate distribution). ECC do not consider such a ‘pepper pot’ approach would deliver or secure necessary sustainable development and would limit opportunities for securing significant infrastructure improvements. It is likely to increase demands on existing provision, with limited capacity to expand to meet the needs of the existing and new communities, as such the scale and pattern of new growth options should be informed by the capacity of existing services to expand and that the level of growth is at a scale to secure delivery of viable and sustainable infrastructure required to support the new communities.
Options 2a and 3 provide the opportunity through large scale developments to secure the delivery of viable and sustainable large-scale infrastructure such as a secondary school or transformational infrastructure for the connectivity and the movement of people and goods.
See Q 51, identifying a range of cross boundary matters to be addressed with ECC and respective neighbouring authorities and their emerging Local Plans.
Larger Scale Developments
In accordance with the NPPF, ECC recommend that the strategic plan-making for larger scale development (such as new settlements or significant extensions to existing villages and towns form part of the strategy) policies should be set within a vision that looks further ahead (at least years), to take into account the likely timescale for phasing, infrastructure, investment, implementation delivery, and may need to consider greater provision given increase in timeframe. Whilst there is no definition of “larger-scale development” given it depends upon the context, scale and setting, ECC consider Option 2a and 3 to be applicable, and should be considered in accordance with NPPF (paragraph 73), which recognises the supply of large numbers of new homes can often be best achieved through planning for larger scale development, provided they are well located and designed, and supported by the necessary infrastructure and facilities (including a genuine choice of transport modes).
ECC would anticipate RDC working with ECC under the Duty to identify suitable locations for such development, to meet identified needs in a sustainable way. This should: consider the opportunities presented by existing or planned investment in infrastructure, the area’s economic potential and the scope for net environmental gains.
This is particularly relevant given the range of identified constraints and the necessary scale of growth required for the provision of a new secondary school, which for ECC as set out in the ECC Developers’ Guide, is a 6 Form of Entry school, requiring 4,500 new homes (see Q35). Please note, Government is considering providing guidance on the evidence base required to support a 30 year vision, which will significantly differ from a 15 year plan period.
Two of the three Concentrated Growth Options (3a and 3b) are identified as possible cross boundary development. ECC would expect to be a partner to any discussions and exploration of such proposals, to ensure the wider strategic infrastructure requirements such as transport and education are fully considered. ECC would seek formal working arrangements and mechanisms to be set up under the Duty, including Memoranda of Understanding and Statements of Common Ground, that would agree the approach, strategic outcomes and cross boundary matters, and may well cover design principles, funding, phasing and delivery mechanisms.
As indicated in option 4 (balanced combination) any spatial strategy option should seek to provide a mix of sites at different scales in order to ensure that any future five housing year supply could be managed, particularly if any large allocation is delayed and/or consideration given to its lead in time.
However, there remains a risk of significant development in a location overwhelming secondary school capacity without a critical mass of housing sufficient for a new school. On this point, ECC would require any future mix, scale of patten of delivery to be fully assessed to achieve the right balance to fully mitigate any impacts, secure the necessary developer funding and provision for the necessary supporting infrastructure and services.
ECC would expect any large developments to be planned for having regard to clear place making design principles and guidance as outlined below and in the response to Q51, and these should be incorporated in any RDC Place Charter (see Q15).
• Essex Design Guide principles, aligning with active design and, garden community principles, including those related to health and wellbeing. (See Q8, Q12 & Q15)
• A Net Zero Future as set out in the ECAC Report 2021 (see Q12,Q12 & Q15)
• A high delivery of multi-functional green infrastructure (GI) and biodiversity net-gain - to align with the nine principles to delivering good GI and the emerging Essex GI Standards Guidance prepared in consultation with Natural England. Such an approach would be consistent with the South Essex GI Study.
• Designed to actively promote modal shift through active and sustainable travel and passenger transport provision, promoting walkable neighbourhoods, traffic free areas and “traffic free” school zones” (see Q51).
• Integrated transport package, to support development as integrated communities where growth responds to and supports the local economy, recognising these would not be fully self-contained.
• In partnership with South Essex Authorities through ASELA and A127 task force seek opportunities for strategic transformation of the transport network for the movement of people and goods.
• Provision of a mix of employment uses and retail provision, is planned seeking opportunities for skills and training integrated within the development, and provision of range of ECC community uses as set out in the ECC Developers’ Guide.
• Delivery mechanisms to be put in place, to plan for funding (developer contributions, CIL and government investment), to manage the phasing, implementation and delivery of the new community and the preparation of Implementation Delivery Strategies for the provision of strategic infrastructure, for example to identify manage any forward fund investment.
• Apply the Minerals and Waste Local Plan policy requirements including exploring the potential for prior extraction of minerals, protection of existing infrastructure and procurement of sustainable construction practices and site waste management plans.
• A master planning approach should be applied to any medium to large developments.
• Cross boundary engagement with neighbouring authorities and ECC to ensure the development is considered in the wider strategic and South Essex growth ambitions
We also refer to the Gilston Town Garden Principles document, which provides an example of a large scale development and associated development principles.
Minerals and Waste Planning and the Site Assessment Process
In respect of the MLP, it is noted and welcomed that the Site Appraisals includes a partial assessment against the MLP, however this should be reviewed and extended to include policy 2 of the WLP. ECC has provided an initial assessment of the promoted sites (see Appendix B),and seek engagement by RDC as part of a review of the Site Appraisals.
For information, the Essex MLP 2014:
• Policy S8 establishes Mineral Safeguarding Areas (MSAs) and a requirement in which ECC as Minerals and Waste Planning Authority (MWPA) must be consulted
• Policy S8 establishes Mineral Consultation Areas (MCAs) in which ECC as MWPA must be consulted
• Policy S4 seeks to secure the sustainable procurement practices, construction and minimisation of waste through site waste management plans on construction sites
For information, the Essex and Southend-on-Sea WLP 2017:
• Policy 2 establishes Waste Consultation Areas (WCAs) in which ECC as MWPA must be consulted.
It is noted that there are areas of overlap between the promoted sites and MLP and WLP, including where there is a concentration of sites East of Rochford/Ashingdon and North of Southend. It is too early to draw conclusions and ECC seek engagement with RDC to explore the next stages and requirements as RDC progress and refine the emerging strategy.
Why is it important to plan for the right amount of growth? (p23 para 3)
Recommend that the emphasis is changed to that of planning for the right amount of growth, taking account of the capacity of both infrastructure and the environment. There is a need to plan for biodiversity net gain in the right place, as part of greener healthier places, through the natural environment to build climate change resilience.
Comment
New Local Plan: Spatial Options Document 2021
Q7. Are there any reasonable alternatives to these options that should be considered instead?
Representation ID: 40393
Received: 22/09/2021
Respondent: Essex County Council
See ECC response to Question 6, 15 and 51 and the principles and approaches to be considered in the development of the spatial options
Comment
New Local Plan: Spatial Options Document 2021
Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?
Representation ID: 40395
Received: 22/09/2021
Respondent: Essex County Council
Recommend inclusion of the following key spatial themes
• Overarching strategy to promote health and wellbeing
• Approach to infrastructure funding, developer contributions and CIL
1. Overarching Strategy to Promote Health and Wellbeing
ECC recommend that public health and health and wellbeing are explicitly included within the Local Plan, as set out in ECC Developers’ Guide and the Essex Design Guide. Health and wellbeing has an important role at underpinning place shaping and ensuring that leisure, culture and healthy lifestyles are facilitated and supported. ECC as the organisation with lead responsibility for public health within Essex welcomes working with RDC in seeking to shape the draft Plan in this subject matter.
The ECAC Report highlights the ambition to create and maintain ‘Healthy Places’ in terms of design, placemaking and place management to ensure these locations both positively contribute to physical and mental health and mitigate climate change. This is critical to promoting healthy and safe communities as set out in the NPPF (paragraph 92) and to enable and support healthy lifestyles.
ECC welcome the range of actions and physical provision identified within the Spatial Options. However, there is no overarching health and wellbeing strategy policy to identify how the new Local Plan will most effectively address the health and wellbeing matters identified in the Joint Strategic Needs Assessment, Essex Health and Wellbeing Strategy and importantly the Castle Point and Rochford Health and Wellbeing Strategy (2019-2021), in order to influence behavioural change, as well as deprivation and to address inequalities within the district. It is also noted that RDC is a major stakeholder of the Essex Health and Wellbeing Board.
ECC recommends that in seeking to deliver the Corporate strategic priorities, that Strategic Objectives 14 and 15 are amended, and that a Health and Wellbeing Strategy is prepared to address key health issues and inequalities identified, namely:
• obesity (such as a review of provisions and location of future Hot Fast Food Takeaways)
• supporting people to lead independent lives,
• improving mental health and wellbeing.
Health Impact Assessment (HIA) is the established and recognised means of providing a comprehensive and systematic process for assessing health and wellbeing impacts from new development proposals. HIA ensures that the wider determinants of health can be factored into the assessment process, including socio-economic, lifestyle and other considerations.
The HIA best practice guidance publication led by Public Health England (PHE) Health Impact Assessment in Spatial Planning states, ‘Local authorities are encouraged to adopt policies that require an HIA to be carried out for certain types of developments in their local plan or spatial development processes’. In Essex, this process is supported by comprehensive guidance in the form of the updated Recommend inclusion of the following key spatial themes
• Overarching strategy to promote health and wellbeing
• Approach to infrastructure funding, developer contributions and CIL
1. Overarching Strategy to Promote Health and Wellbeing
ECC recommend that public health and health and wellbeing are explicitly included within the Local Plan, as set out in ECC Developers’ Guide and the Essex Design Guide. Health and wellbeing has an important role at underpinning place shaping and ensuring that leisure, culture and healthy lifestyles are facilitated and supported. ECC as the organisation with lead responsibility for public health within Essex welcomes working with RDC in seeking to shape the draft Plan in this subject matter.
The ECAC Report highlights the ambition to create and maintain ‘Healthy Places’ in terms of design, placemaking and place management to ensure these locations both positively contribute to physical and mental health and mitigate climate change. This is critical to promoting healthy and safe communities as set out in the NPPF (paragraph 92) and to enable and support healthy lifestyles.
ECC welcome the range of actions and physical provision identified within the Spatial Options. However, there is no overarching health and wellbeing strategy policy to identify how the new Local Plan will most effectively address the health and wellbeing matters identified in the Joint Strategic Needs Assessment, Essex Health and Wellbeing Strategy and importantly the Castle Point and Rochford Health and Wellbeing Strategy (2019-2021), in order to influence behavioural change, as well as deprivation and to address inequalities within the district. It is also noted that RDC is a major stakeholder of the Essex Health and Wellbeing Board.
ECC recommends that in seeking to deliver the Corporate strategic priorities, that Strategic Objectives 14 and 15 are amended, and that a Health and Wellbeing Strategy is prepared to address key health issues and inequalities identified, namely:
• obesity (such as a review of provisions and location of future Hot Fast Food Takeaways)
• supporting people to lead independent lives,
• improving mental health and wellbeing.
Health Impact Assessment (HIA) is the established and recognised means of providing a comprehensive and systematic process for assessing health and wellbeing impacts from new development proposals. HIA ensures that the wider determinants of health can be factored into the assessment process, including socio-economic, lifestyle and other considerations.
The HIA best practice guidance publication led by Public Health England (PHE) Health Impact Assessment in Spatial Planning states, ‘Local authorities are encouraged to adopt policies that require an HIA to be carried out for certain types of developments in their local plan or spatial development processes’. In Essex, this process is supported by comprehensive guidance in the form of the updated Essex Planning Officers’ Association’s (EPOA) HIA guidance Essex Healthy Places Advice - Notes for planners developers and designers (hosted on the Essex Design Guide - Health Impact Assessment website).
ECC can provide further guidance on this matter as the Plan preparation continues
2. Approach to Infrastructure Funding Delivery and Implementation
ECC acknowledge that RDC are to prepare an IDP and a whole plan viability evidence base to inform and support the Plan preparation. However, the draft Plan is silent on the matter of delivery mechanism, infrastructure delivery and implementation including Developer Contributions and CIL. ECC would anticipate that these matters are specifically addressed as the Plan is progressed to ensure the proposals are sustainable, viable and deliverable, especially in relation to any large-scale developments, or any identified strategic infrastructure, including phasing, funding, viability and delivery of the draft Plan. ECC can provide further guidance on this matter as the Plan preparation continues that draws on recently prepared and examined Essex local plans.
Comment
New Local Plan: Spatial Options Document 2021
Q9. Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and coastal change wherever possible? How can we best protect current and future communities from
Representation ID: 40397
Received: 22/09/2021
Respondent: Essex County Council
South Suffolk and Essex Shoreline Management Plan
It is recommended greater reference is made to the time periods within the Shoreline Management Plan, and that for Epochs 2 (2025 – 2055) and Epoch 3 (2055 – 2100), the proportion of frontage where the preferred management policy is either managed realignment or no active intervention, significantly increases so that awareness in communities living in these areas is raised and they realise that adaptation could become necessary.
Climate Change
ECC is mindful that the Government has signed up to the greenhouse gas emission targets set out in the Paris Agreement by 2050, and Rochford’s own ClimateCo2de and Sustainability Strategy. The ECAC is an independent cross-party commission drawn from a wide cross-section of academia, public and private sector, to provide expert advice and up-to-date recommendations for action on climate change mitigation and adaption, tailored for the county of Essex. The commission will run for two years initially and make recommendations about how we can improve the environment and the economy of Essex. The ECAC Report 2021 sets out recommendations on the actions needed to ensure Essex can meet net zero by 2050.
ECC recognise that action is needed now, to address the scale and magnitude of climate change and a holistic approach is necessary. It is also recognised that in developing the emerging Local Plan and addressing the need for growth within Essex and RDC, consideration and change needs to be included to ensure that climate change action is delivered by all. It is recognised that how we build future social and community infrastructure will need to consider mitigating future climate change.
It is noted and accepted that transport should be less reliant on cars and seek to focus on more active travel with increasing cycling and walking, as well as reducing the need to travel. ECC also appreciates the need for an understanding regarding alternative fuels for vehicles and the associated requirements to cater for this change.
Surface Water Management
It is important to ensure that further consideration is given to minimise impacts of flooding within new and existing developments. ECC is the LLFA for Essex and has the lead responsibility for reducing flood risk from surface water, groundwater and ordinary watercourses working closely with other organisations under the Flood and Water Management Act 2010.
The ECAC Report 2021 recommends that there is stronger policy on sustainable urban drainage (SuDS) to ensure it is included as the default for new developments and that green SuDS is the accepted default in all new developments (buildings and infrastructure), as set out in the NPPF but needs implementation. Further assessment will also be required. There should also be further clarification as to who is taking on the ongoing and permanent maintenance of SuDS measures and schemes.
ECC welcomes joint working with RDC in the preparation of the emerging Local Plan to ensure that future growth and development seeks to minimise flood risk. In the early stages of Plan preparation, the LLFA would welcome engagement regarding a high level assessment of potential development sites in terms of our responsibilities outlined above, particularly their relationship to CDAs. CDA boundaries were historically defined by forming a boundary around a cluster of residential properties at risk of surface water flooding. However, this historical approach did not link the source of flooding to those actual residential properties at risk (i.e. a Receptor), so the LLFA decided to amend the countywide methodology to base the definition of a CDA on the ‘Hydraulic Catchment’ approach. Details have been provided on the Rochford Revised CDA’s and the South Essex Surface Water Management Plan – Action Plan to inform the new Local Plan (see below). It should be noted that whether or not a new development is located within a revised CDA, does not impact on the need for this to have a suitable SuDS strategy, that will need to be approved by the LLFA. This strategy will need to reduce site runoff to greenfield rates and maintain the existing water quality in accordance with the Essex SuDS Design Guide, 2020. This applies to all new major development coming forward for delivery in Essex, irrespective of whether it is in a CDA or not.
Appropriate mitigation should be included and set out in site allocation policies, or as a minimum a criteria requirement to ‘Implement sustainable drainage measures will be implemented to ensure no increase in the risk of surface water flooding to the site or nearby properties’. An overarching surface water management policy within the Local Plan (e.g. SuDS, and other surface water drainage that minimises flooding) would also be necessary and development locations should be avoided that would have a significant impact on the likelihood of future flooding. Consideration should also be given to where future flood alleviation schemes are to be located and the impact for future growth. ECC has prepared a range of guidance and resources that is available to assist developing the emerging Local Plan such as the Essex SuDs Design Guide , and further discussions are welcomed on an ongoing basis.
With respect to strategic option 1 (Urban Intensification) and 2 (Urban Extensions), ECC recommend exploring the need of new surface water infrastructures, on the basis that the majority of old town sewer systems are more likely to be supported by combined sewers. ECC would not recommend the new development surface water runoff is connected to existing combined sewers in the absence of surface water sewers in the vicinity. ECC has concerns regarding the additional demand and cost associated to treat surface water from combined sewers. The old drainage systems do not support ECC’s SuDS principles and ECC would not support proposals of “minimum SuDS onsite” because the discharge would be to combined sewers.
If the other site selection parameters support the development under Spatial Strategy Options option 1 and 2, consideration of the provision of separate surface water sewer to meet the development need would be required.
In addition to the above and in response to Question 9 ECC can advise:
• Sequential Test Approach - NPPF (2021) Paragraph 161 states that “All plans should apply a sequential, risk-based approach to the location of development – taking into account all sources of flood risk and the current and future impacts of climate change – so as to avoid, where possible, flood risk to people and property.”. Paragraph 168 goes on to say that “Applications for some minor development and changes of use should not be subject to the sequential or exception tests but should still meet the requirements for site-specific flood risk assessments set out in footnote 54.”
Further to this, the Flood Risk Vulnerability Classification is now included within the NPPF under Annex 3, moving from guidance to policy. On this basis ECC would agree with a Sequential Test approach being taken to locate development away from areas at risk of flooding from both fluvial and costal flood risk, as this is compliant with National Planning Policy.
In respect of the Coastal Change, ECC support the use of a sequential test to provide a clear approach to manage coastal change in accordance with the revised NPPF. This should take into account Shoreline Management Plan and any subsequent amendments including proposals for Managed Retreat, to assist the management of coastal change in risk areas, to reduce the risk from coastal change and to avoid inappropriate development in vulnerable areas.
• Surface Water Management Infrastructure Capacity Review. In respect of options for Urban Intensification, ECC recommended that a review and capacity assessment of surface water management infrastructure is undertaken, within existing urban areas, to manage and mitigate the impacts of urban intensification including the provision of additional dedicated surface water management infrastructure.
• Rochford’s CDA’s and Spatial Strategy Growth Options / promoted sites
ECC has reviewed the spatial option consultation documents, and can advise that most of the promoted site locations fall within a revised CDA. ECC recommend that the RDC’s site selection parameter matrix should assess the proposed development against the need to manage existing surface water flood risk, in accordance with the South Essex Surface Water Management Plan (SWMP) modelling results and the South Essex District Level Action Plan (SWMP Action Plan) prepared by the LLFA. Please see Appendix A, for more details on the CDA’s and SWMP Action Plan to inform the sequential test and site assessment process.
ECC can advise that where new development is located within a CDA, opportunities should be taken to deliver betterment over existing Greenfield rates to reduce flood risk to existing residential properties where this is practical to do so. In accordance with the NPPF and Essex SuDs Design Guide . It is acknowledged that there is only a requirement to mitigate against the impacts of new development, however ECC encourage developers to work with the LLFA on identifying opportunities to identify all sources of flood risk, to reduce flood risk to existing communities and to seek advice from them on what grant funding might be available to do this.
Support
New Local Plan: Spatial Options Document 2021
Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character? Are there other areas that you feel should be protected for their special landscape characte
Representation ID: 40398
Received: 22/09/2021
Respondent: Essex County Council
ECC support the protection of the Coastal Protection Belt (CPB), Upper Roach Valley and other international, national, or local natural importance, and should be protected from development. ECC note the references and importance given to CPB throughout the Spatial Options, and to assist the discussion and identification of issues, recommend a plan is included to identify the extent of the CPB.
Given the importance of the CPB, the need to plan for climate change, mitigation and adaptation, and links to the Shoreline Management Plan, and this should be explicitly addressed further beyond the modest “redrawing” of the CPB as presented, based upon the Landscape Character Sensitivity and Study and Urban Capacity Study. Further analysis and clear rationale for the proposed revision of the CPB boundary is recommended including liaison with the Environment Agency and having regard to the Shoreline Management Plan which identifies preferred management policies and makes it clear that these would be dependent on there being sufficient funding available to deliver these. This is considered necessary to ensure the assumptions are based on sound evidence, for example it is not clear why it is appropriate for some sites proposed to be removed from the CPB given their proximity to proposed Managed Realignment sites in the Shoreline Management Plan. In addition, it is recommended that the special landscape value of the CPB and Upper Roach Valley should be afforded the appropriate protection in a new Local Plan policy.
Support
New Local Plan: Spatial Options Document 2021
Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
Representation ID: 40399
Received: 22/09/2021
Respondent: Essex County Council
It is recommended that RDC require developers to secure all Low Carbon Sources and that all new developments are planned net zero from the outset. It is also recommended that poorer quality agricultural land is assessed for its suitability for energy generation such as by PV Solar Farms.
ECC support the approach, in accordance with the Essex Design Guide, regarding the inclusion of sustainable energy and waste recycling infrastructure sufficient to meet a very significant proportion of the needs of the development.” For large sustainable development: (min site 50 hectares + 65 dwelling per hectare] “Projects would generally be expected to include sustainable energy and waste recycling infrastructure sufficient to meet 100% of the needs of the development.”
Maximisation of renewable energy onsite should be sought and should aim to cover the energy demand onsite. Please see the recommendations within the ECAC Report which include: all new builds to have solar panels installed. Wider opportunities to incorporate renewable energy infrastructure for larger developments include a heat network, capturing and reusing waste heat, and incorporating anchor institutions into the area planning to allow for maximisation of low carbon and renewable opportunities.
Option 3. Recommend that the explanation is expanded to consider the recommendations within the ECAC report and LETI design guide standards which are reflective of the ambition needed to reach net zero carbon in buildings.
Option 4. Would welcome larger renewable feasibility studies. Would also need to ensure that the solar or wind farms also bring forth multiple environmental and socioeconomic benefits to Essex. The solar farm standard guiding principles are in draft and highlight some of the key benefits that should be sought. ECC wish to explore this matter further.
Option 7. Developments should seek to reduce CO2 emissions further than those currently required by building regulations as they lack the ambition needed to reach net zero. The aim should be for net zero, recognising that any new developments which do not meet this standard now, will further add to the size of the challenge to become net zero by 2050 at the latest. This should include both embodied and operational carbon and will tie in to maximisation of renewables onsite to complement the new Future Homes Standards’ ‘fabric plus technology’ approach. The ECAC report and LETI design guide standards are representative of the level of ambition needed.