New Local Plan: Spatial Options Document 2021

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Comment

New Local Plan: Spatial Options Document 2021

Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the plan?

Representation ID: 43282

Received: 27/09/2021

Respondent: Natural England

Representation Summary:

IIA Theme – Health and Wellbeing
Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by
adding a reference to neighbouring authority areas. The amended wording would be:
“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring
authority areas?”
This adjustment is still considered advisable as green infrastructure networks may well involve land
that extends beyond the District boundary and restricting the provision to the District boundary
could exclude the scope for landscape scale provision. This could be particularly important given
the location of some of the growth options now being considered. It is of note that the
recommended adjustment to the appraisal question was made in the Final Scoping report dated
March 2017.
There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question
features in the “Climate Change” theme, it would still be a relevant consideration in assessing the
extent to which a proposal meets the Health and Wellbeing IIA Objective.
Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020
as this could provide a relevant addition to the evidence base for this aspect of the emerging Local
Plan.

Full text:

Dear Strategic Planning Team

Rochford District Council New Local Plan Spatial Options document consultation

Thank you for your consultation on the above dated 28 July 2021 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

The following comments are principally focussed on the Integrated Impact Assessment that accompanies the Spatial Options document. They also reflect Natural England’s response to the previous consultation on the Draft Sustainability Appraisal Scoping Report (our letter dated 31 January 2017, reference 204441).

IIA Theme – Health and Wellbeing

Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by adding a reference to neighbouring authority areas. The amended wording would be:

“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring authority areas?”

This adjustment is still considered advisable as green infrastructure networks may well involve land that extends beyond the District boundary and restricting the provision to the District boundary could exclude the scope for landscape scale provision. This could be particularly important given the location of some of the growth options now being considered. It is of note that the recommended adjustment to the appraisal question was made in the Final Scoping report dated March 2017.

There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question features in the “Climate Change” theme, it would still be a relevant consideration in assessing the extent to which a proposal meets the Health and Wellbeing IIA Objective.

Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020 as this could provide a relevant addition to the evidence base for this aspect of the emerging Local Plan.

IIA Theme – Landscape

Natural England supports the inclusion of an appraisal question that considers the relationship and potential impact of any option/proposal on existing areas of tranquillity.

IIA Theme – Climate Change

As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options document. The following wording is suggested for the appraisal question:

“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”

IIA Theme – Biodiversity

Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme and should be referenced and adjustments are recommended to the appraisal questions to better reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will be an increased emphasis on the delivery of biodiversity net gain. The following wording is suggested for the first appraisal question:

“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”

We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

For any queries regarding this letter, for new consultations, or to provide further information on this
consultation please send your correspondences to consultations@naturalengland.org.uk.

Yours sincerely

Tessa Lambert
Lead Adviser – Land Use Planning
West Anglia Area Team

Comment

New Local Plan: Spatial Options Document 2021

Q51. With reference to the options above, or your own options, how do you feel we can best address our transport and connectivity needs through the plan?

Representation ID: 43283

Received: 27/09/2021

Respondent: Natural England

Representation Summary:

There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question
features in the “Climate Change” theme, it would still be a relevant consideration in assessing the
extent to which a proposal meets the Health and Wellbeing IIA Objective.

Full text:

Dear Strategic Planning Team

Rochford District Council New Local Plan Spatial Options document consultation

Thank you for your consultation on the above dated 28 July 2021 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

The following comments are principally focussed on the Integrated Impact Assessment that accompanies the Spatial Options document. They also reflect Natural England’s response to the previous consultation on the Draft Sustainability Appraisal Scoping Report (our letter dated 31 January 2017, reference 204441).

IIA Theme – Health and Wellbeing

Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by adding a reference to neighbouring authority areas. The amended wording would be:

“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring authority areas?”

This adjustment is still considered advisable as green infrastructure networks may well involve land that extends beyond the District boundary and restricting the provision to the District boundary could exclude the scope for landscape scale provision. This could be particularly important given the location of some of the growth options now being considered. It is of note that the recommended adjustment to the appraisal question was made in the Final Scoping report dated March 2017.

There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question features in the “Climate Change” theme, it would still be a relevant consideration in assessing the extent to which a proposal meets the Health and Wellbeing IIA Objective.

Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020 as this could provide a relevant addition to the evidence base for this aspect of the emerging Local Plan.

IIA Theme – Landscape

Natural England supports the inclusion of an appraisal question that considers the relationship and potential impact of any option/proposal on existing areas of tranquillity.

IIA Theme – Climate Change

As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options document. The following wording is suggested for the appraisal question:

“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”

IIA Theme – Biodiversity

Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme and should be referenced and adjustments are recommended to the appraisal questions to better reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will be an increased emphasis on the delivery of biodiversity net gain. The following wording is suggested for the first appraisal question:

“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”

We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

For any queries regarding this letter, for new consultations, or to provide further information on this
consultation please send your correspondences to consultations@naturalengland.org.uk.

Yours sincerely

Tessa Lambert
Lead Adviser – Land Use Planning
West Anglia Area Team

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: 43284

Received: 27/09/2021

Respondent: Natural England

Representation Summary:

IIA Theme – Health and Wellbeing

Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by adding a reference to neighbouring authority areas. The amended wording would be:

“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring authority areas?”

This adjustment is still considered advisable as green infrastructure networks may well involve land that extends beyond the District boundary and restricting the provision to the District boundary could exclude the scope for landscape scale provision. This could be particularly important given the location of some of the growth options now being considered. It is of note that the recommended adjustment to the appraisal question was made in the Final Scoping report dated March 2017.

There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question features in the “Climate Change” theme, it would still be a relevant consideration in assessing the extent to which a proposal meets the Health and Wellbeing IIA Objective.

Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020 as this could provide a relevant addition to the evidence base for this aspect of the emerging Local Plan.

IIA Theme – Landscape

Natural England supports the inclusion of an appraisal question that considers the relationship and potential impact of any option/proposal on existing areas of tranquillity.

IIA Theme – Climate Change

As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options document. The following wording is suggested for the appraisal question:

“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”

IIA Theme – Biodiversity

Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme and should be referenced and adjustments are recommended to the appraisal questions to better reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will be an increased emphasis on the delivery of biodiversity net gain. The following wording is suggested for the first appraisal question:

“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”

Full text:

Dear Strategic Planning Team

Rochford District Council New Local Plan Spatial Options document consultation

Thank you for your consultation on the above dated 28 July 2021 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

The following comments are principally focussed on the Integrated Impact Assessment that accompanies the Spatial Options document. They also reflect Natural England’s response to the previous consultation on the Draft Sustainability Appraisal Scoping Report (our letter dated 31 January 2017, reference 204441).

IIA Theme – Health and Wellbeing

Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by adding a reference to neighbouring authority areas. The amended wording would be:

“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring authority areas?”

This adjustment is still considered advisable as green infrastructure networks may well involve land that extends beyond the District boundary and restricting the provision to the District boundary could exclude the scope for landscape scale provision. This could be particularly important given the location of some of the growth options now being considered. It is of note that the recommended adjustment to the appraisal question was made in the Final Scoping report dated March 2017.

There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question features in the “Climate Change” theme, it would still be a relevant consideration in assessing the extent to which a proposal meets the Health and Wellbeing IIA Objective.

Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020 as this could provide a relevant addition to the evidence base for this aspect of the emerging Local Plan.

IIA Theme – Landscape

Natural England supports the inclusion of an appraisal question that considers the relationship and potential impact of any option/proposal on existing areas of tranquillity.

IIA Theme – Climate Change

As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options document. The following wording is suggested for the appraisal question:

“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”

IIA Theme – Biodiversity

Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme and should be referenced and adjustments are recommended to the appraisal questions to better reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will be an increased emphasis on the delivery of biodiversity net gain. The following wording is suggested for the first appraisal question:

“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”

We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

For any queries regarding this letter, for new consultations, or to provide further information on this
consultation please send your correspondences to consultations@naturalengland.org.uk.

Yours sincerely

Tessa Lambert
Lead Adviser – Land Use Planning
West Anglia Area Team

Comment

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: 43285

Received: 27/09/2021

Respondent: Natural England

Representation Summary:

As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options document. The following wording is suggested for the appraisal question:
“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”

Full text:

Dear Strategic Planning Team

Rochford District Council New Local Plan Spatial Options document consultation

Thank you for your consultation on the above dated 28 July 2021 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

The following comments are principally focussed on the Integrated Impact Assessment that accompanies the Spatial Options document. They also reflect Natural England’s response to the previous consultation on the Draft Sustainability Appraisal Scoping Report (our letter dated 31 January 2017, reference 204441).

IIA Theme – Health and Wellbeing

Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by adding a reference to neighbouring authority areas. The amended wording would be:

“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring authority areas?”

This adjustment is still considered advisable as green infrastructure networks may well involve land that extends beyond the District boundary and restricting the provision to the District boundary could exclude the scope for landscape scale provision. This could be particularly important given the location of some of the growth options now being considered. It is of note that the recommended adjustment to the appraisal question was made in the Final Scoping report dated March 2017.

There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question features in the “Climate Change” theme, it would still be a relevant consideration in assessing the extent to which a proposal meets the Health and Wellbeing IIA Objective.

Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020 as this could provide a relevant addition to the evidence base for this aspect of the emerging Local Plan.

IIA Theme – Landscape

Natural England supports the inclusion of an appraisal question that considers the relationship and potential impact of any option/proposal on existing areas of tranquillity.

IIA Theme – Climate Change

As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options document. The following wording is suggested for the appraisal question:

“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”

IIA Theme – Biodiversity

Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme and should be referenced and adjustments are recommended to the appraisal questions to better reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will be an increased emphasis on the delivery of biodiversity net gain. The following wording is suggested for the first appraisal question:

“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”

We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

For any queries regarding this letter, for new consultations, or to provide further information on this
consultation please send your correspondences to consultations@naturalengland.org.uk.

Yours sincerely

Tessa Lambert
Lead Adviser – Land Use Planning
West Anglia Area Team

Comment

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: 43286

Received: 27/09/2021

Respondent: Natural England

Representation Summary:

Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme
and should be referenced and adjustments are recommended to the appraisal questions to better
reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is
made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will
be an increased emphasis on the delivery of biodiversity net gain. The following wording is
suggested for the first appraisal question:
“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”

Full text:

Dear Strategic Planning Team

Rochford District Council New Local Plan Spatial Options document consultation

Thank you for your consultation on the above dated 28 July 2021 which was received by Natural England on the same date.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

The following comments are principally focussed on the Integrated Impact Assessment that accompanies the Spatial Options document. They also reflect Natural England’s response to the previous consultation on the Draft Sustainability Appraisal Scoping Report (our letter dated 31 January 2017, reference 204441).

IIA Theme – Health and Wellbeing

Natural England’s previous consultation response recommended the adjustment of the Appraisal
Question “Enhance multifunctional green infrastructure networks throughout the plan area?” by adding a reference to neighbouring authority areas. The amended wording would be:

“Enhance multifunctional green infrastructure networks throughout the plan area and neighbouring authority areas?”

This adjustment is still considered advisable as green infrastructure networks may well involve land that extends beyond the District boundary and restricting the provision to the District boundary could exclude the scope for landscape scale provision. This could be particularly important given the location of some of the growth options now being considered. It is of note that the recommended adjustment to the appraisal question was made in the Final Scoping report dated March 2017.

There is no longer an appraisal question which will consider whether an option promotes the use of
sustainable transport modes such as walking and cycling. Whilst a similar appraisal question features in the “Climate Change” theme, it would still be a relevant consideration in assessing the extent to which a proposal meets the Health and Wellbeing IIA Objective.

Lastly it may be worth reviewing the recently published Essex Green Infrastructure Strategy 2020 as this could provide a relevant addition to the evidence base for this aspect of the emerging Local Plan.

IIA Theme – Landscape

Natural England supports the inclusion of an appraisal question that considers the relationship and potential impact of any option/proposal on existing areas of tranquillity.

IIA Theme – Climate Change

As in its previous response, Natural England recommends the addition of an appraisal question
which will ensure that options are considered in terms of their compatibility with the Essex and Suffolk Shoreline Management Plan which is specifically referenced in the Spatial Options document. The following wording is suggested for the appraisal question:

“Support the priorities identified in the Essex and Suffolk Shoreline Management Plan?”

IIA Theme – Biodiversity

Paragraph 179 of the NPPF (Habitats and Biodiversity) is directly relevant to this particular theme and should be referenced and adjustments are recommended to the appraisal questions to better reflect the NPPF policy advice in that paragraph.
As indicated in our previous response, Natural England would advise that specific reference is made to nationally or locally protected sites. In addition, in light of the updated NPPF text, there will be an increased emphasis on the delivery of biodiversity net gain. The following wording is suggested for the first appraisal question:

“Avoid, or if not possible, minimise impacts on biodiversity, nationally or locally protected sites, and
pursue opportunities for securing net gains for biodiversity?”

We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.

For any queries regarding this letter, for new consultations, or to provide further information on this
consultation please send your correspondences to consultations@naturalengland.org.uk.

Yours sincerely

Tessa Lambert
Lead Adviser – Land Use Planning
West Anglia Area Team

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