5.2.1 Amenity Space

Section 1
1.1 How are the ambitions and aspirations of the local community to be assessed on an on-going basis?
1.1 Reviews should be frequent, easy to initiate, responsive to local comments and published in full.
1.1.1 The Document accepts that people care about their local area and therefore it should be made easier for them to comment and for their views to be taken into account. People will not have a pride in their local area unless they have more input.
The views of relevant parish and town councils and local organisations should be sought and also taken into account.
Development should add to local indentity, not uniformity; empirically the latter currently seems to be the case.
1.2 Who should decide what will 'adversley affect an area'?
Section 2
Council planning staff need to be well-trained to appreciate Southend's architectural history and the character of local areas.
A broad consensus is needed on what is good design for Southend; this must include residents and community architects who live in and understand the town. The arbiters of design and style must not be limited to official architects who may well not be local and may not empathise with the town.
2.2 It is very important that local character is considered. More weight must be given to opinions of people in the area.
2.2.2 The impact on skyline must be considered for all new developments. Some of the large new blocks already dominate the skyline from a distance.
2.2.3 Who decides if existing character is poor? By allowing 'a new characteristic which will provide an enhanced identity 'can mean that anything new will be permitted.
2.3.1 The contributions from major developers must benefit the local area (i.e not simply money in a Borough-wide pot) must be practical and, during time of financial constraint, not used for 'civic art'. These contributions must not be a simple option for developers.
2.3.4 If height etc is determined in each case, it depends too much on the opinions of individual officers. Developers will try to say that each development is a 'landmark' building (as is happening now). Landmark buildings should be few and far between, not just an excuse for something large.
2.3.4 Careful detailing can help but this is sadly lacking in most recent plans (the example shown in Prince Avenue illustrates a significant lack of detailing. This picture should be removed from the final document and replaced by one which shows the detailing)
2.3.5 This section is very important but needs more specific guidelines or it will be in danger of being ignored. These are the details that can seriously affect the quality of life for residents.
2.3.8 Building close up to a public highway should be avoided except for public buildings. In these cases, higher floors should be set back to avoid a dominating appearance and creating a 'canyon' effect.
2.5.1 It is important that there is no loss of existing open space and new open space should be created, as green as possible. People appreciate even small areas of local green space that they pass every day; it increases their sense of well-being and they may never get to larger, more organised green spaces.
Public open spaces should be designed for relaxed use by people and durability in the real world, not just to look attractive on the drawing board. They should have permeable surfaces and plenty of soft landscaping including grass.
2.5.4 New buildings should avoid blocking important distant views which give a sense of openess. Buildings on corner sites should be set back and not too high, to avoid blocking views; streets should lead into each other.
2.5.5 Form should follow function only if it also fits with the surroundings.
2.5.6 Whilst lighting is important, it should be energy efficient and effectively directed. There is too much unnecessary light in the town now with spillage into the sky and neighbours; this is pollution and a waste of energy.
2.6.3 In order to optimise natural resources, the use of solar panels and systems for the recycling of rainwater should be actively encouraged in new developments of all sizes. Energy and water conservation measures must be inlcuded.
2.6.5 This states the importance of tree's and vegetation but no mention is made of gardens, particularly front gardens. As required previously, these must not be given over entirely to car parking or hard-surfaced across the whole width.
2.6.6 Large commercial developments should provide transport or contribute to a subsidy for public transport, unless it is already plentiful.
2.7 The size of sites and the number of dwellings proposed for which provision must be made for affordable housing should be as small as possible, and the percentage of such dwellings should be high. Directives for these must be quantitatively defined and enforced; the alternative of commuted sums should be avoided. These are essential to achieve the mix of house types mentioned in PPG3 para 14. Southend should aim for the percentage levels of affordable housing required by Government.
2.8.2 We strongly disagree with the principle of 'enabling development'. The use of publicly owned land for development purposes must not be linked directly to another project. The decision to release publicly owned land must be taken on its own merits. The decision on the use of any released funds must be taken subsequently. The release of tracts of publicly owned land should only take place following direct consultation with residents.
2.8.5 Reviews of conservation areas should be publicised and comment welcomed and considered.
Section 3
3.1.3 The set-back of windows should be actively encouraged; many modern buildings would have been dramatically improved by this simple device.
3.1.6 All off street surface parking, on whatever scale, must be water permeable to avoid shedding water to the highway and burdening drainage system. This will help retain moisture in the soil.
The other guidelines for parking must be pursued and enforced.
3.1.8 Care should be taken to check existing trees and shrubs and ensure they remain as agreed. Graduitous removal must be penalised and replacements must survive.
3.1.9 Recycling facilities should go beyond current requirements. Southend should be a leader in the provision of both residential and commercial recycling.
3.2.1 Private amenity space is highly valued, and has a different quality from public amenity space. Quanitative requirements for private amenity space must be specified to ensure adequate provision and preserve the quality of life for residents.
3.2.3 Side extensions - Inclusion of the 1 metre rule is good but 'where necessary' may be removed from the document.
Limits on extension sizes should be specified to protect neighbours and aid determination of applications.
3.2.3 The restrictions on dormer size and style are good and needs reinforcing.
3.2.3 Additional Storeys - after 'street' add 'or a significant stretch of the street'.
3.2.4 There should be a presumption against backland development in private gardens.
3.2.6 Conversion to Flats - the onus should be on the applicant to show that there will be no additional strain on local amenities.
3.3.2 Illuminated signs should be switched off over night to avoid distraction, light pollution and energy waste.
3.3.3 Perimeter blocks should still have a band of soft landscape around them. Buildings directly on the highway are stark and reflect and amplify noise.
3.4 The current rules for shopfronts in conservation areas should be retained; this is not stated.
Section 4
4.2.1 The location plan must be large enough to identify the site easily and indicate the orientation accurately.
4.2.1 Additional Visual Information - A scale bar should also be given, by at least the main drawings and/or important dimensions given (to enable dimensions to be appreciated when viewing on the web later this year).
'Street Scene' elevations (which are theoretical views from infinity) should be accompanied by ground plans as the relative set back of buildings influences the human perception of the street scene.
Spurious vegetation should not be shown on plans to artificially soften the design.
Plans which are difficult to understand or lack information should not be accepted until they have been improved.
4.2.2 Travel plans must be realistic, not rely on theoretical buses, car share, cycling etc, which may never materialise.
4.2.2 There must be a presumption against building in flood risk areas; no assessments will stop flooding. Development in these areas should be commensurate with the degree of risk.
4.2.2 Ecological assessments must be realistic and concern for local ecology should be an important consideration in planning applications.
4.2.2 Recycing should 'look ahead' and exceed current requirements.
General
The document contains general ideas of development in an ideal world (with which few could disagree) but must also contain clear objective evaluation and provide the authority with the means to support good practice.
Without specific, quantitative definitions and criteria, decisions will be subjective, inconsistent and harder to support to residents and at appeal. The frequent use of 'should' implies a lack of enforcement; 'must' would give greater power.
Omissions
Examples of supposedly good design are shown; some of poor design (identified as such) could be equally helpful.
No public or school playing fields must be lost.
Optimum and maximum housing densities must be specified.
There should be no increase in housing unless the infrastructure of sewerage, water supply, medical services and local schooling are increased commensurately.
Account should be taken of other locally produced documents which affect design and townscape.

A) Summary
Much of the content of this document accords with Natural England's aspirations for the built environment. There are two main points:
Natural England commends the use of Concept Statements as a quick, effective and participatory tool to produce the basic development principles for individual sites to guide the ensuing master-planing process. We note that these are finally mentioned as a possibility in 6.5 but not as a requirement, as many other councils are requiring, either for all development sites or at least for key sites that require a masterplan. We would be happy to provide further information on this.
Natural England recommends the adoption of ANGSt standards to determine the size and nature of new open spaces.
The ANGSt standards as currently defined and recommended for adoption in PPG17 are:
Every home should be within 300m of an accessible natural greenspace of at least 2ha plus.
At least one accessible 20ha site within 2km
At least one accessible 100ha site within 5km
At least one accessible 500ha site within 10km
The original English Nature ANGSt model also included provision of at least 1ha Local Nature Reserve/1000 population.
Natural England would also like to see a clearer statement regarding Southend's 'Greengrid' to which the document refers. This seems to be merely an aspiration rather than a strategy and it is unclear how this fits with delivery of the South Essex Greengrid Strategy.
B) Specific comments
1.3.2 Commitment to Urban Renaissance and Thames Gateway
12. Natural England welcomes the recognition of the need to identify and enhance sense of place.
13. Natural England assisted the development of the CABE Design Pact and welcomes its proposed use.
1.3.4 Commitment to the Environment
16.
Create a 'Green Grid' of high quality, linked and publicly accessible open spaces across the town, linked to the rest of the sub-region as appropriate - Natural England would welcome clarification as to how this will be achieved.
Protect and enhance both the natural and leisure environment and setting of the River Thames - Natural England welcomes this statement of the Council's commitment.
Provide for the effective management of land on the urban fringe - the interface between town and country - to provide an effective community resource and setting that enhances and protects the Metropolitan Green Belt - Natural England welcomes this statement of the Council's commitment.
1.3.5 Commitment to Good Design
Natural England commends the use of Concept Statements as a quick, effective and participatory tool to produce the basic development principles for individual sites to be used in the ensuing planning process for example to guide the master-planning process. We would be happy to provide further information on this.
1.5 How to Use the Guide
24. The Building for Life Standards are good but are not necessarily quantitative enough.
2.1 Overview of Southend on Sea Borough
30. These are excellent aspirations. Concept statements for individual sites would assist in ensuring that they are achieved.
2.2.2 Topography and Natural Features
34. Natural England recommends the adoption of ANGst standards so that an appropriate amount and type of greenspace is incorporated into new developments. We also would wish to see that every effort is made by new developments to create/enhance linkages from this greenspace to those in adjoining sites and the wider countryside i.e contributing to Thames Gateway South Essex Greengrid principles.
2.3 The Design Concept
2.3.4
The aspirations in this section are excellent; but very lengthy and may not always be achievable. A concept statement produced quickly easily and cheaply at the very outset of the planning process can provide that essential set of development principles to guide any ensuing process.
2.3.4.4 Public Realm and Urban Design
Public Open Space
113. Natural England would wish to see more definitive wording than 'meaningful area', 'large enough' etc - ideally through the adoption of ANGSt standards.
116. In addition to the requirements stated in this section, Natural england would also wish to see aspirations to provide links to adjacent greenspaces in order to assist delivery of Thames Gateway South Essex Greengrid.
3.12 Biodiversity
182, 183 184 and 185 Natural England welcomes this section.
5.1.3 Landscaping
Soft Landscaping
269. In addition to seeking to 'plug the gaps between the borough's existing habitat links and greenways', provision of greenspace should wherever possible contribute to the Greengrid.
270. It is essential that management and financing of landscaping and biodiversity areas is planned in to the proposals from an early stage.
5.2.1 Amenity Space
It is regrettable that no minimum standards for this have been included.
6.5 Planning Briefs, Design Briefs, Concept Statements and Masterplans.
480. Natural England commends the possible use of concept statements but would prefer a policy which made them a requirement at least for sites requiring a masterplan, if not for all development sites.

2.3.2.3 Noise: Point 83
Consideration should be given to adding a further sentence: Noise caused by new development or that will be suffered by the development due to adjoining land uses should be considered at the design stage. Some developments may not be possible if there is an unresolvable noise conflict between adjoining land uses.
5.1.5.1 New Public Roads
Consideration should be given to mentioning the need for a noise assessment in respect of new roads with high traffic flows.
5.1.6.2 Ventilation, Air Handling Equipment and other Plant
314. In addition to odour and fumes etc. it is suggested that dust and particulates are added.
5.2.1 Amenity Space
Consideration should be given to including a comment that amenity space should not normally be provided in situations where the outdoor noise level exceeds World Health Organisation guideline values and there is no option for noise mitigation.
Conversion of Garages to Habitable Rooms
341. consideration should be given to seeking comment from Private Sector Housing Act
346. Noise levels to balconies should not normally exceed World Health Organisation Guideline values for outdoor areas.
5.3.1 Site Layout
361. Consider amending 'A perimeter block can screen nuisance and noise from neighbours'. To read as: 'A perimeter block may form part of a comprehensive noise mitigation scheme to protect the amenity of residential properties.' A scheme would normally be prepared by a competent acoustic consultant.
5.3.4 Servicing
371. Consider amending deliveries should be timed to cause the minimum of inconvenience to other highway users by adding the words 'and residential properties'. Concern is the noise from deliveries.
372. Consider adding after transport assessment the words 'and will not cause adverse impact on the amenity of residential properties'.
373. Consider adding the question of whether the extension will cause adverse impact on residential amenity should be considered.
381. Regarding shop windows and doorways, consider adding the comment 'that light spillage from shop frontages should not adversely impact on residential amenity.
Page 96. 'Pavement Cafes' consider adding the point 'Pavement cafes should not be provided in locations where there will be an adverse impact on residential amenity'.
Page 97. 'Shelters and Compounds for Smokers' please consider adding the further point 'The shelters and compounds should not be provided where they will adversely impact on residential amenity.
Section 5: Check List page 101
Private Amenity Space:
Are the Amenity Spaces Located where they will not be adversely Impacted by Noise from Adjoining Sources such as Roads and Commercial/industrial premises.
Non Residential Schemes:
Page 102. Consider adding the comment 'Does the scheme have an adverse impact on residential amenity'.
6.3.12 Contaminated Land Assessment
440. Consider adding 'The assessment should have regard to the latest edition of the Essex Contaminated Land Consortium Guidance for applicants and developers'.
6.3.13 Noise Assessment
441. Consideration should be given to adding the term 'Detriment to amenity' in addition to noise nuisance. It is understood that avoidance of detriment to amenity is the standard to aim for as regards development subject to planning applications and that this is a higher standard than would be applied if the term nuisance is used.
442. Consider using the following wording 'A noise impact assessment should be submitted for all applications where noise impact on residential amenity may be consideration e.g for sites adjacent to a railway line, a main road, MOD testing area, commercial and industrial developments, and new sporting facilities'
Consider adding a further Section headed 'Artificial Lighting Assessment'. A lighting assessment would be required for developments that have the potential to cause adverse impact on residential amenity such as the flood lighting of sports pitches.
6.3.13 Noise Assessment
The comment for further details see PPG 24: Planning and Noise which can be viewed at www.communities.gov.uk and Environmental Health Guidance - Environmental Noise Impact Residential Developments needs amendment. Please delete 'Environmental Health Guidance - Environmental Noise Impact Residential Developments' and insert 'Guidance by regarding the content of noise impact assessments and criteria sought may be obtained from the Council's Environmental Protection Section via telephone number (01702) 215811.
6.3.17 Lighting Strategy
Please consider adding a comment that the lighting strategy should demonstrate that the proposals will not have an adverse impact on residental amenity.
On page 37 after last paragraph there is a referene to 'see also Environmental Health Guidance-Creation of Residential Dwellings'. I assume this document was produced by private sector housing (PSH), it is recommended that the PSH section is consulted to make sure this advice is current if this has not already been done.
Appendix 5: Code for Sustainable Homes Assessment Criteria
Under the issue 'Construction Site Impacts' in the assessment critera no mention is made of noise control. Suggest the following point is added:
....Adopt best practice policies in respect of noise control including hours of work.
Appendix 6: Options for Resource Minimisation and Development
Under the Option 'Live/work units' in the 'Comments' column consideration should be given to making the comment that only work activities with no impact on the amenity of adjoining residential units would be suitable for these type of units.
Appendix 7: Options for Renewable Power Generation Development
In the option column 'Small Wind Turbine' is noted. In the comments column consideration should be given to making the comment that noise and vibration issues should be considered in respect of the installation of these units.
It is noted that there is an option column referring to 'Wood pellet stoves and boilers'. In the comments column it is suggested that a comment is added regarding the location of the flue and the surroundings and the adequacy of the chimney height in relation to the potential for problems due to odour emissions.

Overall I would like to say that this is excellent document and the revisions that have been made add a lot of value however I have made a few suggested comments sorry for the delay in coming back to you:

Update of introduction in light of recently adopted policy and guidance - no comment
Cross links to the Core Strategy, East of England Regional Spatial Strategy and saved Borough Local Plan Policies - no comment
Improved guidance on
Scale, Height and Massing - could include a recognition that within streets there may be a character within individual street block ie chalkwell esplanade or a characteristic row of properties in a street ie where there is a run of bungalows in a street that is predominantly 2 storey semis.
Sustainable Development and Design - I could not see any where where it is emphasised that these options should be incorporated into the design and not left to be a condition, reference could be made to the local list and that this could be a reason to invalidate the application
The Historic Environment - no comments
Amenity Space - amenity decks and roof terraces - mention a common design solution to prevent overlooking from roof terraces is to set the boundary in from the edge of the roof which removes the need for unsightly obscure panels whilst retaining views of the townscape - the prevention of overlooking can effectively be shown using cross sections
Backland and Infill Development - no comments
Tall Buildings - could maybe add a comment about what you said at the 22 the Leas meeting about have the odd building in strategic locations breaking though the general height of buildings, direct reference could be made to the tall building locations identified within the Central Area Master Plan
Pavement Cafes - no comments
Space Standards including Lifetime Home Standards - this does not go so far as to state a standard for flat sizes (not room sizes) which I thought we were heading towards, maybe we could just adopt those as our standard, I know it is a common thought that the market should determine appropriate sizes however surely we could link the flat sizes to the delivery of a range of accommodation sizes which were identified in the background information that fed into the core strategy
How to Submit an Application - reference that the council's local lists provide further information as to when additional supporting documentation is required which can be found on the council's web site
2.3.2.1 Overshadowing - I think we need to make a commitment to a shadowing school of thought ie P J Littlefair's 'Site layout planning for daylight and sunlight a guide to good practice' as a method that the authority agrees to (this was the guy who came in to do the talk and is nationally renowned in this field)
2.3.4.5 Public Art - I think the word typically is not strong enough for the 1% contribution, it should be more like a 1% contribution will be required unless otherwise agreed with the Council
2.3.5.4 Conversions - houses into flats - Viv may want to look at strengthening this up as I think there is a general push to stop this outside of town centre areas, maybe can be achieved by referencing the Core Strategy
2.3.2.2 Overlooking and privacy - cross sections can be an effective tool to demonstrate overlooking is not possible the Council uses a height of 1.7 metres for eye lines
5.3.8 beach huts - roller shutters are not acceptable in any circumstance even where there is repeat vandalism. When I contacted a number of other authorities with beach huts they do not allow roller shutters as they look like garages. In speaking with colleges in building control they are satisfied that using better hinges and locks on the doors will be just as effective. Staining of beach huts is unacceptable and was accidently included in the first version of the design and townscape guide and should now be omitted. The colour of the beach huts must be vibrant pastels going further than just 'will be welcomed'. I know there are a lot of examples of pretty poor design including roller shutters and staining however over time as these are replaced (generally every 10-15 years) it will be possible to really improve there appearance.
4.5 conservation areas - I could not see it but did we mention about the window grants scheme the council offers - there should be a paragraph stating "Traditional windows are essential to the character of historic buildings and conservation areas. Many need repairing; others have been replaced by inappropriate designs. Window Grants are, therefore, available to help repair and reinstate traditional windows in Conservation Areas. Window Grants provide 40% of the cost of repairing and reinstating traditional windows in Conservation Areas. Grants are up to £500 per property and are restricted to traditional windows facing the street which contribute to the area's character. Grants are discretionary and will depend on funds being available when an application is made. Grant application forms are available from Enterprise, Tourism and the Environment, Southend-on-Sea Borough Council telephone 01702 215004 or can be downloaded from this page. Estimates from two contractors based on the same specification must be enclosed with the application. The offer of a grant is discretionary and will be subject to acceptable estimates and to funds being available. A grant cannot be offered for work that has already been started or carried out. If a grant is offered, it will be in writing and will be subject to appropriate conditions. Subject to agreement, work may be deferred for up to a year following a grant offer. Payment of a grant will normally be made after the work has been completed satisfactorily and receipted invoices have been submitted. Interim payments for larger projects may be made in some instances. Consent under planning legislation and the Building Regulations may be needed before work starts. The Council will advise and help you make any necessary application."
2.3.1.3 - internal arrangements and space standards - all habitable rooms 'must' not 'should' have natural ventilation and daylight