New Local Plan: Spatial Options Document 2021

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Comment

New Local Plan: Spatial Options Document 2021

Q21. With reference to the options listed, or your own options, what do you think is the most appropriate way of meeting our temporary Gypsy and Traveller accommodation needs?

Representation ID: 40411

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

ECC consider the approach to the provision for temporary Gypsy and Traveller Accommodation to be a cross boundary matter and suggest that the approach is explored in co-operation with Essex authorities, through the EPOA.

Comment

New Local Plan: Spatial Options Document 2021

Q22. What do you consider would need to be included in a criteria-based policy for assessing potential locations for new Gypsy and Traveller sites?

Representation ID: 40412

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

ECC would anticipate the development of a relevant criteria and site allocation requirements to be based on best practice and guidance. ECC can provide further guidance and advice on this matter.

Comment

New Local Plan: Spatial Options Document 2021

Q23. With reference to the options listed above, or your own options, how do you feel we can best ensure that we meet our employment and skills needs through the plan?

Representation ID: 40414

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

ECC welcome reference to London Southend Airport (LSA) and the important contribution it can and does make to the local economy, please see Q28.
Recommend a review of the Issues to include highlights a low proportion of B1a/B1b jobs, as outlined in the Economic Topic Paper; and the poor quality of business accommodation.
ECC recommend a policy approach to adopt a sequential test to apply the requirements of NPPF paragraph 73 b), namely for large scale developments to provide “sufficient access to services and employment opportunities within the development itself (without expecting an unrealistic level of self-containment), or in larger towns to which there is good access”.
ECC support the majority of options, to provide a mix and range of solutions to address employment and skills requirements within the district, however consider the overarching objective should be to increase the provision of local employment sites to address out commuting, and to support inward investment. (See also Q6)

It would be of assistance to include an update on the status of the employment land areas remaining as currently allocated employment sites (e.g. Saxon Way, Land West of A1245).

ECC would anticipate employment land and to be located in suitable and accessible locations for employees.

There is a need for further consideration of the employment and skills options, in particular the links to LSA, to recognise the importance of the airport and related businesses for the local economy and inward investment, as evidenced by Question 28.

It is noted that the Economic Topic paper also identified the following issues to be considered / addressed, and ECC would anticipate these being addressed through the Local Plan:
• Low proportion of B1a/b jobs;
• Poor quality of business accommodation; and
• A need to plan for “grow on space”.

In respect of provision of employment land and jobs, ECC consider there would be benefit from some discussion on shared employment needs and suggest that RDC consider and explore this further noting that the London Southend Airport and Environs Joint Area Action Plan (JAAP) allocations partly serve demand from Southend Borough Council (SBC). Given the low job densities in ECC support the majority of options, to provide a mix and range of solutions to address employment and skills requirements within the district, however consider the overarching objective should be to increase the provision of local employment sites to address out commuting, and to support inward investment. (See also Q6)

It would be of assistance to include an update on the status of the employment land areas remaining as currently allocated employment sites (e.g. Saxon Way, Land West of A1245).

ECC would anticipate employment land and to be located in suitable and accessible locations for employees.

There is a need for further consideration of the employment and skills options, in particular the links to LSA, to recognise the importance of the airport and related businesses for the local economy and inward investment, as evidenced by Question 28.

It is noted that the Economic Topic paper also identified the following issues to be considered / addressed, and ECC would anticipate these being addressed through the Local Plan:
• Low proportion of B1a/b jobs;
• Poor quality of business accommodation; and
• A need to plan for “grow on space”.

In respect of provision of employment land and jobs, ECC consider there would be benefit from some discussion on shared employment needs and suggest that RDC consider and explore this further noting that the London Southend Airport and Environs Joint Area Action Plan (JAAP) allocations partly serve demand from Southend Borough Council (SBC). Given the low job densities in the district, there may be benefits associated with meeting further employment need from SBC (which has supply challenges that warrant articulating).

ECC would anticipate there to be a range and mix of provision to respond to the identified need and recognition the different accommodation and space requirements. For example, occupiers of offices and industrial accommodation would have a different range of needs, including securing digital connectivity (full fibre and mobile). It is important that the respective requirements are identified and planned for separately. There is a need to ensure new employment space is flexible and adaptable for businesses to grow.

ECC can provide further specific information and wish to work with RDC and partners, to explore opportunities to support economic growth, employment, skills and digital connectivity within the district. (see also Q52)

It is noted that the Options do not identify priorities for skills to address the challenges identified including mismatch of skills and jobs, and out commuting. This amongst the wider challenges and opportunities in South Essex is a unique opportunity in which RDC working collaboratively in partnership with ECC and other public sector partners, can reshape the district including the delivery of services such as a civic hub, or through a re-development work programme to identify and implement strategies to address inequalities or opportunities identified, to enhance the skills offer for apprenticeships and training (such as construction) and deliver improved connectivity, both transport and digital.

Option 3. Further consideration is required given the level of housing growth to be planned for in the new Local Plan. Further clarification and evidence is required on the level of employment land and retail space.

Option 4. In accordance with NPPF paragraph 73, consideration should also be given to the location and provision for access to services and employment within any large-scale development, such as concentrated growth areas / new communities / large urban extensions.

Options 5 and 7. Require further consideration and clarification, would anticipate that the specific locations would be considered on a case by case base in relation to their suitability and accessibility. Further consideration also required in relation to the Airport Safeguarding Zone.

Option 8. ECC welcome the references to Grow on Space and seek clarification on which employment sites this policy would apply to, for example the large scale developments, or concentrated growth options / strategic sites.

Options 10 and 11 are supported.

Comment

New Local Plan: Spatial Options Document 2021

Q25. With reference to your preferred Strategy Option, are there opportunities for growth to deliver new employment facilities or improvements to existing employment facilities?

Representation ID: 40415

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

Spatial Strategy Options 3b / 3c, may provide the opportunity for a new mixed-use area including high-productivity employment uses, given their relationship to the Airport and existing employment areas.

Comment

New Local Plan: Spatial Options Document 2021

Q26. Are there any particular types of employment site or business accommodation that you consider Rochford District is lacking, or would benefit from?

Representation ID: 40416

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

ECC recommend further consideration to the impact of the Covid 19 Pandemic, on employment including changes in work patterns, including an increase in homeworking. This will increase the importance and need for digital infrastructure. There is also a need to consider the nature of the existing employment offer, automation and industry 4.0 which will affect workplaces, such as factories, where home/remote working is not an option.

Comment

New Local Plan: Spatial Options Document 2021

Q27. Are there other measures we can take through the plan to lay the foundations for long-term economic growth, e.g. skills or connectivity?

Representation ID: 40418

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

Both skills and connectivity are vital for a vibrant economy, and recommend RDC work with ECC, neighbouring authorities and partners to secure district wide deployment of digital technology and access to skills and training for all.

Comment

New Local Plan: Spatial Options Document 2021

Q28. With reference to the options listed above, or your own options, how do you feel we can best manage the Airport’s adaptations and growth through the planning system?

Representation ID: 40420

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

LSA is as an international gateway of strategic importance to the local economy, residents and businesses in South Essex, and is considered to be a strategic cross boundary matter, to be explored further between RDC, SBC and ECC; with partners. There is a need for alignment of approaches to secure a consistent approach. (see also Q23)

There are issues with the ease of connectivity from LSA by bus, therefore any future growth at LSA should be supported by improvements to bus connectivity. This will ensure that the airport functions are as multi modal as possible.

Any future growth to LSA will need to be supported by improvements to parts of the strategic highway routes and in particular the A127. In addition to working with South Essex partners there will be a need to liaise with ECC. SBC and Highways England/National Highways in respect of any forthcoming proposals or new business cases for potential investment on the A127

In respect of any future proposals for the airport’s growth these should consider:
• Provision of bus priority infrastructure and bus network improvements including a multi-modal interchange at the Airport and Railway Station for passengers, employees (not just Airport) and existing residents and businesses (see Q51);
• The needs of both passengers and freight movements;
• Appreciating that any future growth at the airport would need to be supported by improvements to some of the strategic routes - in particular A127;
• The role of the airport and related businesses as employers and the needs to ensure appropriate and sustainable transport accessibility to the airport to help maximise local employment opportunities. This could include provision of a multi modal interchange, to serve passengers, employees and residents;
• The need for Local Plan policies to comply with the revised Aviation Strategy 2050, anticipated winter 2021/22; and
• The requirements of the ECAC in relation to air travel and airports and be set within the context of climate change, decarbonisation of transport and the outcomes of the current DfT consultation Jet Zero and the further evidence base required.

Support

New Local Plan: Spatial Options Document 2021

Q29. Do you agree that the plan should designate and protect areas of land of locally important wildlife value as a local wildlife site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection?

Representation ID: 40421

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

ECC supports the conclusions of the Local Wildlife Site Review (2018). However, consider clarification is required in the approach to Doggetts Pond, noting that the evidence identifies that it could recover with positive management, and update the site selection assessment and review potential for bio-diversity net gain.

ECC recommend the approaches in the Essex Green Infrastructure Strategy (2020) are followed. This includes early collaboration and engagement to support the delivery of effective and connected GI. ECC can provide guidance and advice through engagement on the placement, supporting policy and delivery of new GI and the protection of existing GI.

Support

New Local Plan: Spatial Options Document 2021

Q30. Do you agree that the plan should designate and protect areas of land of locally important geological value as a local geological site, having regard to the Local Wildlife Sites review? Are there any other sites that you feel are worthy of protection

Representation ID: 40422

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

ECC supports the conclusions of the Local Wildlife Site Review (2018). However, consider clarification is required in the approach to Doggetts Pond, noting that the evidence identifies that it could recover with positive management, and update the site selection assessment and review potential for bio-diversity net gain.

ECC recommend the approaches in the Essex Green Infrastructure Strategy (2020) are followed. This includes early collaboration and engagement to support the delivery of effective and connected GI. ECC can provide guidance and advice through engagement on the placement, supporting policy and delivery of new GI and the protection of existing GI.

Comment

New Local Plan: Spatial Options Document 2021

Q31. Do you consider net gains for biodiversity are best delivered on-site or off-site? Are there specific locations or projects where net gain projects could be delivered?

Representation ID: 40423

Received: 22/09/2021

Respondent: Essex County Council

Representation Summary:

ECC supports the consideration of biodiversity within the emerging Local Plan, and the protection and enhancement of international, national, and local sites of wildlife and/or geological importance, this should not occur at the expense of the provision of most on-site green infrastructure to secure biodiversity net-gains. It is important to note that Natural England is reviewing existing green infrastructure standards and Green Planning Principles to set a national Green Infrastructure standards framework and the emerging Environment Bill aims to embed an environmental net gains requirement into developments, including housing.

ECC recommends that the emerging Local Plan seeks broader environmental net gain. This approach would allow for wider natural capital benefits to be delivered by developments, such as flood protection, recreation, and improved water and air quality. The PPG keeps GI at the forefront of its approach to delivering net gains for the environment. All developments should demonstrate the environmental net gains, and where there is a net loss from the development seek to secure provision through offsetting.

ECC notes that a new set of standards has been developed by Building with Nature to overcome the perceived and actual complexity of delivering high quality green infrastructure and has won a RTPI Award for Research Excellence. Drawing from evidence and good practice on all aspects of Green Infrastructure – wellbeing, water and wildlife, the standards define high quality green infrastructure at each stage of the development process, from planning and design, through to long-term management and maintenance. It provides a framework of quality standards, an assessment and accreditation service, and national awards. By providing an accreditation at the plan/design stage, Building with Nature also starts to raise confidence in the planning and development sector that can achieve a collective understanding of why green infrastructure matters, and how to deliver it more consistently to accelerate the delivery of new homes and new places.

RDC may also be interested to note that Place Services has published an Essex Biodiversity Validation Checklist, which is updated regularly in light of user feedback and changes to biodiversity legislation and policy, such as the introduction of British Standard 42020:2013: Biodiversity Code of practice for planning and development.

ECC supports the delivery of biodiversity net gain on-site in the first instance. However, it is recognised that this might not always be achievable, and that off-site delivery could provide additional benefits and be used to protect areas of land that are of local natural and wildlife value. Multi-functional, accessible GI should be delivered on all major development sites.

Once the Environment Bill is enacted, a requirement for the development of an Essex Local Nature Recovery Strategy (Essex LNRS) is likely and some partners in Essex are already beginning to consider the mapping which would form part of this. Reference to the LNRS should be made, and it is important there is liaison with ECC, Essex Wildlife Trust, Natural England and the Royal Society for the Protection of Birds as both the Local Plan and the LNRS develop.

In addition to the South Essex Green and Blue Infrastructure Study, ECC recommend the use of the Essex Green Infrastructure Strategy (2020), (see Q 32).

The Essex GI Strategy calls for early collaboration and engagement with all relevant stakeholders, partners, and communities to support the delivery of effective and connected GI. ECC can provide guidance and advice through engagement on the placement, supporting policy and delivery of new GI and the protection of existing GI.

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