7. How best do we ensure healthy communities and development is appropriate and of a quality design, whilst ensuring we enhance our built heritage assets

Showing comments and forms 1 to 10 of 10

Comment

New Local Plan

Representation ID: 3836

Received: 10/04/2019

Respondent: Anglian Water

Representation Summary:

Reference is made to the provision of Sustainable Drainage Systems forming part of development proposals which is fully supported.
Anglian Water support a requirement in the New Local Plan for applicants to include the provision of Sustainable Drainage Systems (SuDS) so as not to increase flood risk and to reduce flood risk where possible. The use of SuDS would help to reduce the risk of surface water and sewer flooding.
We would also ask that SuDs are considered as an early stage in the design process so that these are of suitable standard and are an integral part of the development.
We are happy to support the Southend on Sea Local Plan Team on the preparation of policy wording relevant to Anglian Water prior to the next formal stage of the preparation of the Local Plan. This would include a number of the issues identified – delivery of water recycling infrastructure improvements required to support growth and regeneration and managing water quality and flood risk.

Full text:

Thanks for your help with this. Please find attached Anglian Water’s comments relating to the most recent consultation.

Support

New Local Plan

Representation ID: 3900

Received: 26/03/2019

Respondent: Sport England (East Office)

Representation Summary:

The reference to the Health and Wellbeing Strategy, the role that the local plan plays in achieving its objectives, reference to creation of health environments which make it easier to participate in physical activity, and the reference to Sport England’s Active Design guidance in the evidence list and supporting topic paper is endorsed.
The focus on facilitating good design and healthy living in chapter 7 and providing for community services (including sport and recreation) in chapter 8 is particularly welcomed.

Full text:

General
Sport England is a Non-Departmental Public Body and the Government’s strategic lead for community sport. We provide advice and support to local planning authorities preparing development plans on community sport related matters. We are also a statutory consultee on planning applications affecting playing fields and therefore we engage in the development plan process to complement this role.
Sport England advocates that the new local plan is prepared in accordance with the relevant Government planning policy in section 8 of the NPPF especially paragraphs 96 and 97 which specifically focus on open space, sport and recreation. To complement Government policy, Sport England has prepared a Forward Planning guidance note http://www.sportengland.org/facilities-planning/planning-for-sport/forward-planning/ aimed at local planning authorities preparing local plans which provides more detailed guidance on planning for sport in development plans. Please note that this guide will shortly be updated by Sport England – a draft of the new guidance is on our website at https://www.sportengland.org/facilities-planning/planning-for-sport/planning-for-sport-guidance-consultation-draft/. .
I have considered the main consultation document and the topic papers on ‘Good Design and Healthy Living’ and ‘Social and Community Infrastructure Needs’. The focus on facilitating good design and healthy living in chapter 7 and providing for community services (including sport and recreation) in chapter 8 is particularly welcomed.
7. Facilitating Good Design and Healthy Living
The reference (page 49) to the Health & Wellbeing Strategy and the role that the local plan plays in achieving its objectives is supported as well as the specific reference to helping to create healthy living environments which make it easier to participate in physical activity. The reference to Sport England’s Active Design guidance in the list of evidence (page 52) and the topic paper is especially endorsed as the guidance can be used for helping to shape local plan policies to deliver the wider health and activity related aims and objectives. In response to the question about how to ensure healthy communities and development is appropriate and of a quality design through the local plan I would provide the following advice:
• The local plan should include a strategic objective related to improving health and well-being through creating active environments. This would be consistent with Government policy and Sport England’s strategy.
• Sport England’s Active Design principles should be embedded into the local plan’s policies including those relating to urban design, health/well-being, active transport and green infrastructure. The application of the Active Design principles would represent a clear and transparent approach for helping to deliver the local plan’s emerging focus on creating healthy living environments. The principles can be applied at both a strategic scale in the master planning of major new developments and at the local scale in the detailed design of both new developments and enhancements to existing communities. The principles complement conventional urban design principles so policies in the local plan that deal with matters such as high quality design, design principles in new development etc. should include these principles. Embedding the Active Design principles throughout the plan is considered to be more effective in terms of delivery than treating Active Design as a standalone issue in the local plan. This approach has been taken through the recent review of the Essex Design Guide https://www.essexdesignguide.co.uk/ where Active Design principles have been embedded throughout the guide so that they are considered when issues as diverse as highway design and landscaping are looked at rather than being potentially overlooked if treated as a separate theme. Sport England has published a case study https://www.sportengland.org/facilities-planning/active-design/ on how the Essex Design Guide has successfully embedded the Active Design principles which is aimed at local authorities considering taking a similar approach in other strategic documents. The adoption by the Council of the Essex Design Guide or a similar approach being taken in a review of the Council’s Design & Townscape Guide is advocated. The Active Design guidance includes a checklist so that any development can undertake a self-assessment against the guidance under each principle (or be assessed by the local authority) to ensure that opportunities for encouraging physical activity are maximised in practice. Such an approach could be incorporated into design and access statements (or design codes) for major developments or part of HIAs as a requirement of local plan policy for instance to assist with delivery. This provides a consistent and transparent way of ensuring the principles are considered.
• Local plan policies should require Health Impact Assessments (HIAs) to be submitted as part of large and/or sensitive applications but for this to be effective in terms of outcomes, the Council would need to give weight to HIAs and subject them to appropriate scrutiny to ensure that the health impacts of developments are fully considered in practice. While HIAs are established, in general terms, the weight given to them in the application determination process by local planning authorities has been variable in practice. If their preparation by developers is to be justified, appropriate weight needs to be given to them in planning policy and by requiring them to be included as part of Environmental Impact Assessments for major developments is a suggestion as this would help in terms of the status given to health impacts in the preparation and determination of planning applications. The Council’s Public Health team should be engaged in reviewing HIAs to ensure that the issues are satisfactorily considered and where appropriate mitigation is made as part of an application. The scope of HIAs should be widened beyond conventional health impact considerations to include how a development creates opportunities for people to be physically active e.g. through demonstrating that Sport England’s Active Design guidance checklist has been completed to demonstrate how physical activity opportunities have been considered in practice in new developments. As the Council will be aware, the Essex Planning Officers Association (EPOA) have recently approved the revised Essex HIA guidance for developers and part of the review is focused around widening the scope to include physical activity considerations including the application of Active Design principles. It is advocated that the Council (as a member of EPOA) either advocate the use of this guidance in the local plan or develops its own guidance which incorporates advice in the EPOA guidance.
• Local Plan policies should advocate that developers consider the ‘Essex Healthy Places - Advice note for planners, developers and designers’ that has recently been approved by the EPOA as this provides specific guidance on how health (including physical activity) considerations should be addressed in the planning and design of new developments.
8. Providing Community Services and Infrastructure
The joint preparation of a Playing Pitch Strategy and a Built Facilities Strategy by the Council and the other South Essex authorities is welcomed. These strategies together with the expected overarching South Essex strategies for playing pitches and built facilities will provide a robust basis for informing and justifying the policies and allocations in the emerging local plan in relation to planning for community sports facilities. This approach would accord with paragraph 96 of the NPPF. More specifically, these strategies should be used for the following:
• Justifying the protection of existing sports facilities in accordance with paragraph 97 of the NPPF;
• Planning positively for meeting identified needs for new or enhanced sports facilities associated with meeting the needs of both the current and future population of the area;
• Allocating sites for new sports facilities to meet identified needs if applicable;
• Setting out the approach to sports facility provision in new development in relation to both direct provision as part of developments or through securing developer contributions (planning obligations or CIL) towards priority projects identified within the strategies;
• Planning for the shared use of existing and new community facilities e.g. the shared use of sports facilities in schools by expecting new schools or new/enhanced facilities on existing school sites to provide for community use secured through community use agreements.
• Planning to meet strategic and cross-boundary sports facility needs of the wider South Essex area.
Sport England would expect policies and (if applicable) allocations to be developed through the emerging local plan which positively address the above matters in response to the evidence base. These should be consistent with Government policy in the NPPF (especially section 8) and consider Sport England’s guidance referred to above. Sport England would be happy to provide further advice to the Council on this matter and would be willing to comment on draft policies in advance of formal consultations.
12. Ensuring that the New Local Plan is Delivered
In relation to delivering the new local plan’s emerging priorities in relation to sport and physical activity, the following is advocated:
• Provision for Sport in New Development: In an urban area like Southend, it is considered unlikely that it will be appropriate to provide on-site provision for formal sports facilities in the majority of new developments that come forward. The Council therefore needs to develop an approach to developer contributions that provides some certainty that new developments that generates a need for additional sports facilities make an appropriate contribution towards priority sports facility projects that will meet the needs of the community. In many areas of the country, the introduction of CIL has resulted in provision for sport being reduced as other infrastructure projects have taken priority when allocating CIL receipts. Consideration will therefore need to be given to whether it is more appropriate in the future to seek to secure provision for sport through planning obligations instead especially in the light of the expected changes to Government legislation and policy which will remove the pooling of contributions secured through planning obligations and Regulation 123 lists that relate to CIL. A review of the Council’s approach to planning obligations and CIL in the context of the Council’s new local plan policies and evidence base for sport would be necessary to deliver this. The approach to planning for sport needs to avoid a scenario where the Council identify contributions and projects in response to each individual planning application on an ad hoc and reactive basis. Such an approach would not considered to be appropriate or sustainable and would not ensure that the local community consistently receive the benefits of new development in their areas. Furthermore, the local plan needs to make provision for a planned approach to community sports provision on strategic scale developments where provision is made on-site to ensure that where new facilities are provided that they are responsive to the needs identified by the community (in the Council’s evidence base documents) rather than led by developers who often have limited understanding of sports facility planning and local needs. For example, when the allocations for major development have been decided through the local plan process, a strategy should be prepared identifying how each development should make provision for sport and recreation based on the priorities identified in the Council’s evidence base in order to provide clarity and transparency to all parties.
• Public Health: Funding that may be available through the Council’s public health function that can be used towards sports facilities should be co-ordinated with developer contributions to ensure that opportunities for delivering priority projects are maximised. Sports facility projects may offer the potential to deliver public health priorities identified in the refreshed Health & Well-being Strategy especially those that encourage participation in physical activity by under-represented groups. Close working between planning and public health functions will be required to ensure that co-ordination of priorities takes place in practice.
• Partnership Working: To maximise the potential to secure funding for delivering key sports facility projects it will be essential that partnership working takes place because without this there is a risk that the limited funding available from different partners will not be co-ordinated. To take this forward in practical terms, as already advocated by Sport England through its engagement with the Council on the playing pitch/built facility strategies, an implementation group should be set up consisting of the Council, Active Essex, Sport England and sports governing bodies which would identify the priority projects to meet identified needs and develop an action plan for securing the funding for delivering these priorities. The local plan can assist by aligning such an action plan to the a review of the Infrastructure Delivery Plan to ensure that priorities agreed by the partners are prioritised for funding in relation to the use of CIL and planning obligation receipts. Such funding could then be used as match funding in relation to conventional funding sources such as Sport England’s lottery funds, governing body funding, public health funding etc. Strategic working with the other South Essex authorities is also advocated as it may be possible to provide facilities that serve more than one local authority by joint working which would reduce the funding required. In this regard, consideration should be given to the principle of cross-boundary financial contributions towards strategic projects that serve more than one local authority area.

Comment

New Local Plan

Representation ID: 3901

Received: 26/03/2019

Respondent: Sport England (East Office)

Representation Summary:

The local plan should include a strategic objective related to improving health and well-being through creating active environments. This would be consistent with Government policy and Sport England’s strategy.

Full text:

General
Sport England is a Non-Departmental Public Body and the Government’s strategic lead for community sport. We provide advice and support to local planning authorities preparing development plans on community sport related matters. We are also a statutory consultee on planning applications affecting playing fields and therefore we engage in the development plan process to complement this role.
Sport England advocates that the new local plan is prepared in accordance with the relevant Government planning policy in section 8 of the NPPF especially paragraphs 96 and 97 which specifically focus on open space, sport and recreation. To complement Government policy, Sport England has prepared a Forward Planning guidance note http://www.sportengland.org/facilities-planning/planning-for-sport/forward-planning/ aimed at local planning authorities preparing local plans which provides more detailed guidance on planning for sport in development plans. Please note that this guide will shortly be updated by Sport England – a draft of the new guidance is on our website at https://www.sportengland.org/facilities-planning/planning-for-sport/planning-for-sport-guidance-consultation-draft/. .
I have considered the main consultation document and the topic papers on ‘Good Design and Healthy Living’ and ‘Social and Community Infrastructure Needs’. The focus on facilitating good design and healthy living in chapter 7 and providing for community services (including sport and recreation) in chapter 8 is particularly welcomed.
7. Facilitating Good Design and Healthy Living
The reference (page 49) to the Health & Wellbeing Strategy and the role that the local plan plays in achieving its objectives is supported as well as the specific reference to helping to create healthy living environments which make it easier to participate in physical activity. The reference to Sport England’s Active Design guidance in the list of evidence (page 52) and the topic paper is especially endorsed as the guidance can be used for helping to shape local plan policies to deliver the wider health and activity related aims and objectives. In response to the question about how to ensure healthy communities and development is appropriate and of a quality design through the local plan I would provide the following advice:
• The local plan should include a strategic objective related to improving health and well-being through creating active environments. This would be consistent with Government policy and Sport England’s strategy.
• Sport England’s Active Design principles should be embedded into the local plan’s policies including those relating to urban design, health/well-being, active transport and green infrastructure. The application of the Active Design principles would represent a clear and transparent approach for helping to deliver the local plan’s emerging focus on creating healthy living environments. The principles can be applied at both a strategic scale in the master planning of major new developments and at the local scale in the detailed design of both new developments and enhancements to existing communities. The principles complement conventional urban design principles so policies in the local plan that deal with matters such as high quality design, design principles in new development etc. should include these principles. Embedding the Active Design principles throughout the plan is considered to be more effective in terms of delivery than treating Active Design as a standalone issue in the local plan. This approach has been taken through the recent review of the Essex Design Guide https://www.essexdesignguide.co.uk/ where Active Design principles have been embedded throughout the guide so that they are considered when issues as diverse as highway design and landscaping are looked at rather than being potentially overlooked if treated as a separate theme. Sport England has published a case study https://www.sportengland.org/facilities-planning/active-design/ on how the Essex Design Guide has successfully embedded the Active Design principles which is aimed at local authorities considering taking a similar approach in other strategic documents. The adoption by the Council of the Essex Design Guide or a similar approach being taken in a review of the Council’s Design & Townscape Guide is advocated. The Active Design guidance includes a checklist so that any development can undertake a self-assessment against the guidance under each principle (or be assessed by the local authority) to ensure that opportunities for encouraging physical activity are maximised in practice. Such an approach could be incorporated into design and access statements (or design codes) for major developments or part of HIAs as a requirement of local plan policy for instance to assist with delivery. This provides a consistent and transparent way of ensuring the principles are considered.
• Local plan policies should require Health Impact Assessments (HIAs) to be submitted as part of large and/or sensitive applications but for this to be effective in terms of outcomes, the Council would need to give weight to HIAs and subject them to appropriate scrutiny to ensure that the health impacts of developments are fully considered in practice. While HIAs are established, in general terms, the weight given to them in the application determination process by local planning authorities has been variable in practice. If their preparation by developers is to be justified, appropriate weight needs to be given to them in planning policy and by requiring them to be included as part of Environmental Impact Assessments for major developments is a suggestion as this would help in terms of the status given to health impacts in the preparation and determination of planning applications. The Council’s Public Health team should be engaged in reviewing HIAs to ensure that the issues are satisfactorily considered and where appropriate mitigation is made as part of an application. The scope of HIAs should be widened beyond conventional health impact considerations to include how a development creates opportunities for people to be physically active e.g. through demonstrating that Sport England’s Active Design guidance checklist has been completed to demonstrate how physical activity opportunities have been considered in practice in new developments. As the Council will be aware, the Essex Planning Officers Association (EPOA) have recently approved the revised Essex HIA guidance for developers and part of the review is focused around widening the scope to include physical activity considerations including the application of Active Design principles. It is advocated that the Council (as a member of EPOA) either advocate the use of this guidance in the local plan or develops its own guidance which incorporates advice in the EPOA guidance.
• Local Plan policies should advocate that developers consider the ‘Essex Healthy Places - Advice note for planners, developers and designers’ that has recently been approved by the EPOA as this provides specific guidance on how health (including physical activity) considerations should be addressed in the planning and design of new developments.
8. Providing Community Services and Infrastructure
The joint preparation of a Playing Pitch Strategy and a Built Facilities Strategy by the Council and the other South Essex authorities is welcomed. These strategies together with the expected overarching South Essex strategies for playing pitches and built facilities will provide a robust basis for informing and justifying the policies and allocations in the emerging local plan in relation to planning for community sports facilities. This approach would accord with paragraph 96 of the NPPF. More specifically, these strategies should be used for the following:
• Justifying the protection of existing sports facilities in accordance with paragraph 97 of the NPPF;
• Planning positively for meeting identified needs for new or enhanced sports facilities associated with meeting the needs of both the current and future population of the area;
• Allocating sites for new sports facilities to meet identified needs if applicable;
• Setting out the approach to sports facility provision in new development in relation to both direct provision as part of developments or through securing developer contributions (planning obligations or CIL) towards priority projects identified within the strategies;
• Planning for the shared use of existing and new community facilities e.g. the shared use of sports facilities in schools by expecting new schools or new/enhanced facilities on existing school sites to provide for community use secured through community use agreements.
• Planning to meet strategic and cross-boundary sports facility needs of the wider South Essex area.
Sport England would expect policies and (if applicable) allocations to be developed through the emerging local plan which positively address the above matters in response to the evidence base. These should be consistent with Government policy in the NPPF (especially section 8) and consider Sport England’s guidance referred to above. Sport England would be happy to provide further advice to the Council on this matter and would be willing to comment on draft policies in advance of formal consultations.
12. Ensuring that the New Local Plan is Delivered
In relation to delivering the new local plan’s emerging priorities in relation to sport and physical activity, the following is advocated:
• Provision for Sport in New Development: In an urban area like Southend, it is considered unlikely that it will be appropriate to provide on-site provision for formal sports facilities in the majority of new developments that come forward. The Council therefore needs to develop an approach to developer contributions that provides some certainty that new developments that generates a need for additional sports facilities make an appropriate contribution towards priority sports facility projects that will meet the needs of the community. In many areas of the country, the introduction of CIL has resulted in provision for sport being reduced as other infrastructure projects have taken priority when allocating CIL receipts. Consideration will therefore need to be given to whether it is more appropriate in the future to seek to secure provision for sport through planning obligations instead especially in the light of the expected changes to Government legislation and policy which will remove the pooling of contributions secured through planning obligations and Regulation 123 lists that relate to CIL. A review of the Council’s approach to planning obligations and CIL in the context of the Council’s new local plan policies and evidence base for sport would be necessary to deliver this. The approach to planning for sport needs to avoid a scenario where the Council identify contributions and projects in response to each individual planning application on an ad hoc and reactive basis. Such an approach would not considered to be appropriate or sustainable and would not ensure that the local community consistently receive the benefits of new development in their areas. Furthermore, the local plan needs to make provision for a planned approach to community sports provision on strategic scale developments where provision is made on-site to ensure that where new facilities are provided that they are responsive to the needs identified by the community (in the Council’s evidence base documents) rather than led by developers who often have limited understanding of sports facility planning and local needs. For example, when the allocations for major development have been decided through the local plan process, a strategy should be prepared identifying how each development should make provision for sport and recreation based on the priorities identified in the Council’s evidence base in order to provide clarity and transparency to all parties.
• Public Health: Funding that may be available through the Council’s public health function that can be used towards sports facilities should be co-ordinated with developer contributions to ensure that opportunities for delivering priority projects are maximised. Sports facility projects may offer the potential to deliver public health priorities identified in the refreshed Health & Well-being Strategy especially those that encourage participation in physical activity by under-represented groups. Close working between planning and public health functions will be required to ensure that co-ordination of priorities takes place in practice.
• Partnership Working: To maximise the potential to secure funding for delivering key sports facility projects it will be essential that partnership working takes place because without this there is a risk that the limited funding available from different partners will not be co-ordinated. To take this forward in practical terms, as already advocated by Sport England through its engagement with the Council on the playing pitch/built facility strategies, an implementation group should be set up consisting of the Council, Active Essex, Sport England and sports governing bodies which would identify the priority projects to meet identified needs and develop an action plan for securing the funding for delivering these priorities. The local plan can assist by aligning such an action plan to the a review of the Infrastructure Delivery Plan to ensure that priorities agreed by the partners are prioritised for funding in relation to the use of CIL and planning obligation receipts. Such funding could then be used as match funding in relation to conventional funding sources such as Sport England’s lottery funds, governing body funding, public health funding etc. Strategic working with the other South Essex authorities is also advocated as it may be possible to provide facilities that serve more than one local authority by joint working which would reduce the funding required. In this regard, consideration should be given to the principle of cross-boundary financial contributions towards strategic projects that serve more than one local authority area.

Comment

New Local Plan

Representation ID: 3902

Received: 26/03/2019

Respondent: Sport England (East Office)

Representation Summary:

Active Design principles should be embedded throughout the plan, and should be applied at both a strategic scale in masterplanning of major new developments and at the local scale in the detailed design of both new developments and enhancement of existing communities.
This is considered to be more effective in terms of delivery than treating Active Design as a standalone issue in the local plan. This approach has been taken through the recent review of the Essex Design Guide https://www.essexdesignguide.co.uk/ where Active Design principles have been embedded throughout the guide so that they are considered when issues as diverse as highway design and landscaping are looked at rather than being potentially overlooked if treated as a separate theme. Sport England has published a case study https://www.sportengland.org/facilities-planning/active-design/ on how the Essex Design Guide has successfully embedded the Active Design principles which is aimed at local authorities considering taking a similar approach in other strategic documents. This could be incorporated into design and access statements (or design codes) for major developments or part of HIAs as a requirement of local plan policy e.g. to assist with delivery, providing a consistent and transparent way of ensuring the principles are delivered.

Full text:

General
Sport England is a Non-Departmental Public Body and the Government’s strategic lead for community sport. We provide advice and support to local planning authorities preparing development plans on community sport related matters. We are also a statutory consultee on planning applications affecting playing fields and therefore we engage in the development plan process to complement this role.
Sport England advocates that the new local plan is prepared in accordance with the relevant Government planning policy in section 8 of the NPPF especially paragraphs 96 and 97 which specifically focus on open space, sport and recreation. To complement Government policy, Sport England has prepared a Forward Planning guidance note http://www.sportengland.org/facilities-planning/planning-for-sport/forward-planning/ aimed at local planning authorities preparing local plans which provides more detailed guidance on planning for sport in development plans. Please note that this guide will shortly be updated by Sport England – a draft of the new guidance is on our website at https://www.sportengland.org/facilities-planning/planning-for-sport/planning-for-sport-guidance-consultation-draft/. .
I have considered the main consultation document and the topic papers on ‘Good Design and Healthy Living’ and ‘Social and Community Infrastructure Needs’. The focus on facilitating good design and healthy living in chapter 7 and providing for community services (including sport and recreation) in chapter 8 is particularly welcomed.
7. Facilitating Good Design and Healthy Living
The reference (page 49) to the Health & Wellbeing Strategy and the role that the local plan plays in achieving its objectives is supported as well as the specific reference to helping to create healthy living environments which make it easier to participate in physical activity. The reference to Sport England’s Active Design guidance in the list of evidence (page 52) and the topic paper is especially endorsed as the guidance can be used for helping to shape local plan policies to deliver the wider health and activity related aims and objectives. In response to the question about how to ensure healthy communities and development is appropriate and of a quality design through the local plan I would provide the following advice:
• The local plan should include a strategic objective related to improving health and well-being through creating active environments. This would be consistent with Government policy and Sport England’s strategy.
• Sport England’s Active Design principles should be embedded into the local plan’s policies including those relating to urban design, health/well-being, active transport and green infrastructure. The application of the Active Design principles would represent a clear and transparent approach for helping to deliver the local plan’s emerging focus on creating healthy living environments. The principles can be applied at both a strategic scale in the master planning of major new developments and at the local scale in the detailed design of both new developments and enhancements to existing communities. The principles complement conventional urban design principles so policies in the local plan that deal with matters such as high quality design, design principles in new development etc. should include these principles. Embedding the Active Design principles throughout the plan is considered to be more effective in terms of delivery than treating Active Design as a standalone issue in the local plan. This approach has been taken through the recent review of the Essex Design Guide https://www.essexdesignguide.co.uk/ where Active Design principles have been embedded throughout the guide so that they are considered when issues as diverse as highway design and landscaping are looked at rather than being potentially overlooked if treated as a separate theme. Sport England has published a case study https://www.sportengland.org/facilities-planning/active-design/ on how the Essex Design Guide has successfully embedded the Active Design principles which is aimed at local authorities considering taking a similar approach in other strategic documents. The adoption by the Council of the Essex Design Guide or a similar approach being taken in a review of the Council’s Design & Townscape Guide is advocated. The Active Design guidance includes a checklist so that any development can undertake a self-assessment against the guidance under each principle (or be assessed by the local authority) to ensure that opportunities for encouraging physical activity are maximised in practice. Such an approach could be incorporated into design and access statements (or design codes) for major developments or part of HIAs as a requirement of local plan policy for instance to assist with delivery. This provides a consistent and transparent way of ensuring the principles are considered.
• Local plan policies should require Health Impact Assessments (HIAs) to be submitted as part of large and/or sensitive applications but for this to be effective in terms of outcomes, the Council would need to give weight to HIAs and subject them to appropriate scrutiny to ensure that the health impacts of developments are fully considered in practice. While HIAs are established, in general terms, the weight given to them in the application determination process by local planning authorities has been variable in practice. If their preparation by developers is to be justified, appropriate weight needs to be given to them in planning policy and by requiring them to be included as part of Environmental Impact Assessments for major developments is a suggestion as this would help in terms of the status given to health impacts in the preparation and determination of planning applications. The Council’s Public Health team should be engaged in reviewing HIAs to ensure that the issues are satisfactorily considered and where appropriate mitigation is made as part of an application. The scope of HIAs should be widened beyond conventional health impact considerations to include how a development creates opportunities for people to be physically active e.g. through demonstrating that Sport England’s Active Design guidance checklist has been completed to demonstrate how physical activity opportunities have been considered in practice in new developments. As the Council will be aware, the Essex Planning Officers Association (EPOA) have recently approved the revised Essex HIA guidance for developers and part of the review is focused around widening the scope to include physical activity considerations including the application of Active Design principles. It is advocated that the Council (as a member of EPOA) either advocate the use of this guidance in the local plan or develops its own guidance which incorporates advice in the EPOA guidance.
• Local Plan policies should advocate that developers consider the ‘Essex Healthy Places - Advice note for planners, developers and designers’ that has recently been approved by the EPOA as this provides specific guidance on how health (including physical activity) considerations should be addressed in the planning and design of new developments.
8. Providing Community Services and Infrastructure
The joint preparation of a Playing Pitch Strategy and a Built Facilities Strategy by the Council and the other South Essex authorities is welcomed. These strategies together with the expected overarching South Essex strategies for playing pitches and built facilities will provide a robust basis for informing and justifying the policies and allocations in the emerging local plan in relation to planning for community sports facilities. This approach would accord with paragraph 96 of the NPPF. More specifically, these strategies should be used for the following:
• Justifying the protection of existing sports facilities in accordance with paragraph 97 of the NPPF;
• Planning positively for meeting identified needs for new or enhanced sports facilities associated with meeting the needs of both the current and future population of the area;
• Allocating sites for new sports facilities to meet identified needs if applicable;
• Setting out the approach to sports facility provision in new development in relation to both direct provision as part of developments or through securing developer contributions (planning obligations or CIL) towards priority projects identified within the strategies;
• Planning for the shared use of existing and new community facilities e.g. the shared use of sports facilities in schools by expecting new schools or new/enhanced facilities on existing school sites to provide for community use secured through community use agreements.
• Planning to meet strategic and cross-boundary sports facility needs of the wider South Essex area.
Sport England would expect policies and (if applicable) allocations to be developed through the emerging local plan which positively address the above matters in response to the evidence base. These should be consistent with Government policy in the NPPF (especially section 8) and consider Sport England’s guidance referred to above. Sport England would be happy to provide further advice to the Council on this matter and would be willing to comment on draft policies in advance of formal consultations.
12. Ensuring that the New Local Plan is Delivered
In relation to delivering the new local plan’s emerging priorities in relation to sport and physical activity, the following is advocated:
• Provision for Sport in New Development: In an urban area like Southend, it is considered unlikely that it will be appropriate to provide on-site provision for formal sports facilities in the majority of new developments that come forward. The Council therefore needs to develop an approach to developer contributions that provides some certainty that new developments that generates a need for additional sports facilities make an appropriate contribution towards priority sports facility projects that will meet the needs of the community. In many areas of the country, the introduction of CIL has resulted in provision for sport being reduced as other infrastructure projects have taken priority when allocating CIL receipts. Consideration will therefore need to be given to whether it is more appropriate in the future to seek to secure provision for sport through planning obligations instead especially in the light of the expected changes to Government legislation and policy which will remove the pooling of contributions secured through planning obligations and Regulation 123 lists that relate to CIL. A review of the Council’s approach to planning obligations and CIL in the context of the Council’s new local plan policies and evidence base for sport would be necessary to deliver this. The approach to planning for sport needs to avoid a scenario where the Council identify contributions and projects in response to each individual planning application on an ad hoc and reactive basis. Such an approach would not considered to be appropriate or sustainable and would not ensure that the local community consistently receive the benefits of new development in their areas. Furthermore, the local plan needs to make provision for a planned approach to community sports provision on strategic scale developments where provision is made on-site to ensure that where new facilities are provided that they are responsive to the needs identified by the community (in the Council’s evidence base documents) rather than led by developers who often have limited understanding of sports facility planning and local needs. For example, when the allocations for major development have been decided through the local plan process, a strategy should be prepared identifying how each development should make provision for sport and recreation based on the priorities identified in the Council’s evidence base in order to provide clarity and transparency to all parties.
• Public Health: Funding that may be available through the Council’s public health function that can be used towards sports facilities should be co-ordinated with developer contributions to ensure that opportunities for delivering priority projects are maximised. Sports facility projects may offer the potential to deliver public health priorities identified in the refreshed Health & Well-being Strategy especially those that encourage participation in physical activity by under-represented groups. Close working between planning and public health functions will be required to ensure that co-ordination of priorities takes place in practice.
• Partnership Working: To maximise the potential to secure funding for delivering key sports facility projects it will be essential that partnership working takes place because without this there is a risk that the limited funding available from different partners will not be co-ordinated. To take this forward in practical terms, as already advocated by Sport England through its engagement with the Council on the playing pitch/built facility strategies, an implementation group should be set up consisting of the Council, Active Essex, Sport England and sports governing bodies which would identify the priority projects to meet identified needs and develop an action plan for securing the funding for delivering these priorities. The local plan can assist by aligning such an action plan to the a review of the Infrastructure Delivery Plan to ensure that priorities agreed by the partners are prioritised for funding in relation to the use of CIL and planning obligation receipts. Such funding could then be used as match funding in relation to conventional funding sources such as Sport England’s lottery funds, governing body funding, public health funding etc. Strategic working with the other South Essex authorities is also advocated as it may be possible to provide facilities that serve more than one local authority by joint working which would reduce the funding required. In this regard, consideration should be given to the principle of cross-boundary financial contributions towards strategic projects that serve more than one local authority area.

Comment

New Local Plan

Representation ID: 3903

Received: 26/03/2019

Respondent: Sport England (East Office)

Representation Summary:

Local plan policies should require Health Impact Assessments (HIAs) to be submitted as part of large and/or sensitive applications but for this to be effective in terms of outcomes, the Council would need to give policy weight to HIAs and subject them to appropriate scrutiny to ensure that the health impacts of developments are fully considered in practice. HIAs could be required to be included as part of Environmental Impact Assessments for major developments. The Council’s Public Health team should be engaged in reviewing HIAs to ensure that the issues are satisfactorily considered and where appropriate mitigation is required as part of an application.

The Essex Planning Officers Association (EPOA) have recently approved the revised Essex HIA guidance for developers and part of the review is focused around widening the scope to include physical activity considerations including the application of Active Design principles. It is advocated that the Council (as a member of EPOA) either advocate the use of this guidance in the local plan or develops its own guidance which incorporates advice in the EPOA guidance.

Full text:

General
Sport England is a Non-Departmental Public Body and the Government’s strategic lead for community sport. We provide advice and support to local planning authorities preparing development plans on community sport related matters. We are also a statutory consultee on planning applications affecting playing fields and therefore we engage in the development plan process to complement this role.
Sport England advocates that the new local plan is prepared in accordance with the relevant Government planning policy in section 8 of the NPPF especially paragraphs 96 and 97 which specifically focus on open space, sport and recreation. To complement Government policy, Sport England has prepared a Forward Planning guidance note http://www.sportengland.org/facilities-planning/planning-for-sport/forward-planning/ aimed at local planning authorities preparing local plans which provides more detailed guidance on planning for sport in development plans. Please note that this guide will shortly be updated by Sport England – a draft of the new guidance is on our website at https://www.sportengland.org/facilities-planning/planning-for-sport/planning-for-sport-guidance-consultation-draft/. .
I have considered the main consultation document and the topic papers on ‘Good Design and Healthy Living’ and ‘Social and Community Infrastructure Needs’. The focus on facilitating good design and healthy living in chapter 7 and providing for community services (including sport and recreation) in chapter 8 is particularly welcomed.
7. Facilitating Good Design and Healthy Living
The reference (page 49) to the Health & Wellbeing Strategy and the role that the local plan plays in achieving its objectives is supported as well as the specific reference to helping to create healthy living environments which make it easier to participate in physical activity. The reference to Sport England’s Active Design guidance in the list of evidence (page 52) and the topic paper is especially endorsed as the guidance can be used for helping to shape local plan policies to deliver the wider health and activity related aims and objectives. In response to the question about how to ensure healthy communities and development is appropriate and of a quality design through the local plan I would provide the following advice:
• The local plan should include a strategic objective related to improving health and well-being through creating active environments. This would be consistent with Government policy and Sport England’s strategy.
• Sport England’s Active Design principles should be embedded into the local plan’s policies including those relating to urban design, health/well-being, active transport and green infrastructure. The application of the Active Design principles would represent a clear and transparent approach for helping to deliver the local plan’s emerging focus on creating healthy living environments. The principles can be applied at both a strategic scale in the master planning of major new developments and at the local scale in the detailed design of both new developments and enhancements to existing communities. The principles complement conventional urban design principles so policies in the local plan that deal with matters such as high quality design, design principles in new development etc. should include these principles. Embedding the Active Design principles throughout the plan is considered to be more effective in terms of delivery than treating Active Design as a standalone issue in the local plan. This approach has been taken through the recent review of the Essex Design Guide https://www.essexdesignguide.co.uk/ where Active Design principles have been embedded throughout the guide so that they are considered when issues as diverse as highway design and landscaping are looked at rather than being potentially overlooked if treated as a separate theme. Sport England has published a case study https://www.sportengland.org/facilities-planning/active-design/ on how the Essex Design Guide has successfully embedded the Active Design principles which is aimed at local authorities considering taking a similar approach in other strategic documents. The adoption by the Council of the Essex Design Guide or a similar approach being taken in a review of the Council’s Design & Townscape Guide is advocated. The Active Design guidance includes a checklist so that any development can undertake a self-assessment against the guidance under each principle (or be assessed by the local authority) to ensure that opportunities for encouraging physical activity are maximised in practice. Such an approach could be incorporated into design and access statements (or design codes) for major developments or part of HIAs as a requirement of local plan policy for instance to assist with delivery. This provides a consistent and transparent way of ensuring the principles are considered.
• Local plan policies should require Health Impact Assessments (HIAs) to be submitted as part of large and/or sensitive applications but for this to be effective in terms of outcomes, the Council would need to give weight to HIAs and subject them to appropriate scrutiny to ensure that the health impacts of developments are fully considered in practice. While HIAs are established, in general terms, the weight given to them in the application determination process by local planning authorities has been variable in practice. If their preparation by developers is to be justified, appropriate weight needs to be given to them in planning policy and by requiring them to be included as part of Environmental Impact Assessments for major developments is a suggestion as this would help in terms of the status given to health impacts in the preparation and determination of planning applications. The Council’s Public Health team should be engaged in reviewing HIAs to ensure that the issues are satisfactorily considered and where appropriate mitigation is made as part of an application. The scope of HIAs should be widened beyond conventional health impact considerations to include how a development creates opportunities for people to be physically active e.g. through demonstrating that Sport England’s Active Design guidance checklist has been completed to demonstrate how physical activity opportunities have been considered in practice in new developments. As the Council will be aware, the Essex Planning Officers Association (EPOA) have recently approved the revised Essex HIA guidance for developers and part of the review is focused around widening the scope to include physical activity considerations including the application of Active Design principles. It is advocated that the Council (as a member of EPOA) either advocate the use of this guidance in the local plan or develops its own guidance which incorporates advice in the EPOA guidance.
• Local Plan policies should advocate that developers consider the ‘Essex Healthy Places - Advice note for planners, developers and designers’ that has recently been approved by the EPOA as this provides specific guidance on how health (including physical activity) considerations should be addressed in the planning and design of new developments.
8. Providing Community Services and Infrastructure
The joint preparation of a Playing Pitch Strategy and a Built Facilities Strategy by the Council and the other South Essex authorities is welcomed. These strategies together with the expected overarching South Essex strategies for playing pitches and built facilities will provide a robust basis for informing and justifying the policies and allocations in the emerging local plan in relation to planning for community sports facilities. This approach would accord with paragraph 96 of the NPPF. More specifically, these strategies should be used for the following:
• Justifying the protection of existing sports facilities in accordance with paragraph 97 of the NPPF;
• Planning positively for meeting identified needs for new or enhanced sports facilities associated with meeting the needs of both the current and future population of the area;
• Allocating sites for new sports facilities to meet identified needs if applicable;
• Setting out the approach to sports facility provision in new development in relation to both direct provision as part of developments or through securing developer contributions (planning obligations or CIL) towards priority projects identified within the strategies;
• Planning for the shared use of existing and new community facilities e.g. the shared use of sports facilities in schools by expecting new schools or new/enhanced facilities on existing school sites to provide for community use secured through community use agreements.
• Planning to meet strategic and cross-boundary sports facility needs of the wider South Essex area.
Sport England would expect policies and (if applicable) allocations to be developed through the emerging local plan which positively address the above matters in response to the evidence base. These should be consistent with Government policy in the NPPF (especially section 8) and consider Sport England’s guidance referred to above. Sport England would be happy to provide further advice to the Council on this matter and would be willing to comment on draft policies in advance of formal consultations.
12. Ensuring that the New Local Plan is Delivered
In relation to delivering the new local plan’s emerging priorities in relation to sport and physical activity, the following is advocated:
• Provision for Sport in New Development: In an urban area like Southend, it is considered unlikely that it will be appropriate to provide on-site provision for formal sports facilities in the majority of new developments that come forward. The Council therefore needs to develop an approach to developer contributions that provides some certainty that new developments that generates a need for additional sports facilities make an appropriate contribution towards priority sports facility projects that will meet the needs of the community. In many areas of the country, the introduction of CIL has resulted in provision for sport being reduced as other infrastructure projects have taken priority when allocating CIL receipts. Consideration will therefore need to be given to whether it is more appropriate in the future to seek to secure provision for sport through planning obligations instead especially in the light of the expected changes to Government legislation and policy which will remove the pooling of contributions secured through planning obligations and Regulation 123 lists that relate to CIL. A review of the Council’s approach to planning obligations and CIL in the context of the Council’s new local plan policies and evidence base for sport would be necessary to deliver this. The approach to planning for sport needs to avoid a scenario where the Council identify contributions and projects in response to each individual planning application on an ad hoc and reactive basis. Such an approach would not considered to be appropriate or sustainable and would not ensure that the local community consistently receive the benefits of new development in their areas. Furthermore, the local plan needs to make provision for a planned approach to community sports provision on strategic scale developments where provision is made on-site to ensure that where new facilities are provided that they are responsive to the needs identified by the community (in the Council’s evidence base documents) rather than led by developers who often have limited understanding of sports facility planning and local needs. For example, when the allocations for major development have been decided through the local plan process, a strategy should be prepared identifying how each development should make provision for sport and recreation based on the priorities identified in the Council’s evidence base in order to provide clarity and transparency to all parties.
• Public Health: Funding that may be available through the Council’s public health function that can be used towards sports facilities should be co-ordinated with developer contributions to ensure that opportunities for delivering priority projects are maximised. Sports facility projects may offer the potential to deliver public health priorities identified in the refreshed Health & Well-being Strategy especially those that encourage participation in physical activity by under-represented groups. Close working between planning and public health functions will be required to ensure that co-ordination of priorities takes place in practice.
• Partnership Working: To maximise the potential to secure funding for delivering key sports facility projects it will be essential that partnership working takes place because without this there is a risk that the limited funding available from different partners will not be co-ordinated. To take this forward in practical terms, as already advocated by Sport England through its engagement with the Council on the playing pitch/built facility strategies, an implementation group should be set up consisting of the Council, Active Essex, Sport England and sports governing bodies which would identify the priority projects to meet identified needs and develop an action plan for securing the funding for delivering these priorities. The local plan can assist by aligning such an action plan to the a review of the Infrastructure Delivery Plan to ensure that priorities agreed by the partners are prioritised for funding in relation to the use of CIL and planning obligation receipts. Such funding could then be used as match funding in relation to conventional funding sources such as Sport England’s lottery funds, governing body funding, public health funding etc. Strategic working with the other South Essex authorities is also advocated as it may be possible to provide facilities that serve more than one local authority by joint working which would reduce the funding required. In this regard, consideration should be given to the principle of cross-boundary financial contributions towards strategic projects that serve more than one local authority area.

Comment

New Local Plan

Representation ID: 3904

Received: 26/03/2019

Respondent: Sport England (East Office)

Representation Summary:

Local Plan policies should advocate that developers consider the ‘Essex Healthy Places - Advice note for planners, developers and designers’ that has recently been approved by the EPOA as this provides specific guidance on how health (including physical activity) considerations should be addressed in the planning and design of new developments.

Full text:

General
Sport England is a Non-Departmental Public Body and the Government’s strategic lead for community sport. We provide advice and support to local planning authorities preparing development plans on community sport related matters. We are also a statutory consultee on planning applications affecting playing fields and therefore we engage in the development plan process to complement this role.
Sport England advocates that the new local plan is prepared in accordance with the relevant Government planning policy in section 8 of the NPPF especially paragraphs 96 and 97 which specifically focus on open space, sport and recreation. To complement Government policy, Sport England has prepared a Forward Planning guidance note http://www.sportengland.org/facilities-planning/planning-for-sport/forward-planning/ aimed at local planning authorities preparing local plans which provides more detailed guidance on planning for sport in development plans. Please note that this guide will shortly be updated by Sport England – a draft of the new guidance is on our website at https://www.sportengland.org/facilities-planning/planning-for-sport/planning-for-sport-guidance-consultation-draft/. .
I have considered the main consultation document and the topic papers on ‘Good Design and Healthy Living’ and ‘Social and Community Infrastructure Needs’. The focus on facilitating good design and healthy living in chapter 7 and providing for community services (including sport and recreation) in chapter 8 is particularly welcomed.
7. Facilitating Good Design and Healthy Living
The reference (page 49) to the Health & Wellbeing Strategy and the role that the local plan plays in achieving its objectives is supported as well as the specific reference to helping to create healthy living environments which make it easier to participate in physical activity. The reference to Sport England’s Active Design guidance in the list of evidence (page 52) and the topic paper is especially endorsed as the guidance can be used for helping to shape local plan policies to deliver the wider health and activity related aims and objectives. In response to the question about how to ensure healthy communities and development is appropriate and of a quality design through the local plan I would provide the following advice:
• The local plan should include a strategic objective related to improving health and well-being through creating active environments. This would be consistent with Government policy and Sport England’s strategy.
• Sport England’s Active Design principles should be embedded into the local plan’s policies including those relating to urban design, health/well-being, active transport and green infrastructure. The application of the Active Design principles would represent a clear and transparent approach for helping to deliver the local plan’s emerging focus on creating healthy living environments. The principles can be applied at both a strategic scale in the master planning of major new developments and at the local scale in the detailed design of both new developments and enhancements to existing communities. The principles complement conventional urban design principles so policies in the local plan that deal with matters such as high quality design, design principles in new development etc. should include these principles. Embedding the Active Design principles throughout the plan is considered to be more effective in terms of delivery than treating Active Design as a standalone issue in the local plan. This approach has been taken through the recent review of the Essex Design Guide https://www.essexdesignguide.co.uk/ where Active Design principles have been embedded throughout the guide so that they are considered when issues as diverse as highway design and landscaping are looked at rather than being potentially overlooked if treated as a separate theme. Sport England has published a case study https://www.sportengland.org/facilities-planning/active-design/ on how the Essex Design Guide has successfully embedded the Active Design principles which is aimed at local authorities considering taking a similar approach in other strategic documents. The adoption by the Council of the Essex Design Guide or a similar approach being taken in a review of the Council’s Design & Townscape Guide is advocated. The Active Design guidance includes a checklist so that any development can undertake a self-assessment against the guidance under each principle (or be assessed by the local authority) to ensure that opportunities for encouraging physical activity are maximised in practice. Such an approach could be incorporated into design and access statements (or design codes) for major developments or part of HIAs as a requirement of local plan policy for instance to assist with delivery. This provides a consistent and transparent way of ensuring the principles are considered.
• Local plan policies should require Health Impact Assessments (HIAs) to be submitted as part of large and/or sensitive applications but for this to be effective in terms of outcomes, the Council would need to give weight to HIAs and subject them to appropriate scrutiny to ensure that the health impacts of developments are fully considered in practice. While HIAs are established, in general terms, the weight given to them in the application determination process by local planning authorities has been variable in practice. If their preparation by developers is to be justified, appropriate weight needs to be given to them in planning policy and by requiring them to be included as part of Environmental Impact Assessments for major developments is a suggestion as this would help in terms of the status given to health impacts in the preparation and determination of planning applications. The Council’s Public Health team should be engaged in reviewing HIAs to ensure that the issues are satisfactorily considered and where appropriate mitigation is made as part of an application. The scope of HIAs should be widened beyond conventional health impact considerations to include how a development creates opportunities for people to be physically active e.g. through demonstrating that Sport England’s Active Design guidance checklist has been completed to demonstrate how physical activity opportunities have been considered in practice in new developments. As the Council will be aware, the Essex Planning Officers Association (EPOA) have recently approved the revised Essex HIA guidance for developers and part of the review is focused around widening the scope to include physical activity considerations including the application of Active Design principles. It is advocated that the Council (as a member of EPOA) either advocate the use of this guidance in the local plan or develops its own guidance which incorporates advice in the EPOA guidance.
• Local Plan policies should advocate that developers consider the ‘Essex Healthy Places - Advice note for planners, developers and designers’ that has recently been approved by the EPOA as this provides specific guidance on how health (including physical activity) considerations should be addressed in the planning and design of new developments.
8. Providing Community Services and Infrastructure
The joint preparation of a Playing Pitch Strategy and a Built Facilities Strategy by the Council and the other South Essex authorities is welcomed. These strategies together with the expected overarching South Essex strategies for playing pitches and built facilities will provide a robust basis for informing and justifying the policies and allocations in the emerging local plan in relation to planning for community sports facilities. This approach would accord with paragraph 96 of the NPPF. More specifically, these strategies should be used for the following:
• Justifying the protection of existing sports facilities in accordance with paragraph 97 of the NPPF;
• Planning positively for meeting identified needs for new or enhanced sports facilities associated with meeting the needs of both the current and future population of the area;
• Allocating sites for new sports facilities to meet identified needs if applicable;
• Setting out the approach to sports facility provision in new development in relation to both direct provision as part of developments or through securing developer contributions (planning obligations or CIL) towards priority projects identified within the strategies;
• Planning for the shared use of existing and new community facilities e.g. the shared use of sports facilities in schools by expecting new schools or new/enhanced facilities on existing school sites to provide for community use secured through community use agreements.
• Planning to meet strategic and cross-boundary sports facility needs of the wider South Essex area.
Sport England would expect policies and (if applicable) allocations to be developed through the emerging local plan which positively address the above matters in response to the evidence base. These should be consistent with Government policy in the NPPF (especially section 8) and consider Sport England’s guidance referred to above. Sport England would be happy to provide further advice to the Council on this matter and would be willing to comment on draft policies in advance of formal consultations.
12. Ensuring that the New Local Plan is Delivered
In relation to delivering the new local plan’s emerging priorities in relation to sport and physical activity, the following is advocated:
• Provision for Sport in New Development: In an urban area like Southend, it is considered unlikely that it will be appropriate to provide on-site provision for formal sports facilities in the majority of new developments that come forward. The Council therefore needs to develop an approach to developer contributions that provides some certainty that new developments that generates a need for additional sports facilities make an appropriate contribution towards priority sports facility projects that will meet the needs of the community. In many areas of the country, the introduction of CIL has resulted in provision for sport being reduced as other infrastructure projects have taken priority when allocating CIL receipts. Consideration will therefore need to be given to whether it is more appropriate in the future to seek to secure provision for sport through planning obligations instead especially in the light of the expected changes to Government legislation and policy which will remove the pooling of contributions secured through planning obligations and Regulation 123 lists that relate to CIL. A review of the Council’s approach to planning obligations and CIL in the context of the Council’s new local plan policies and evidence base for sport would be necessary to deliver this. The approach to planning for sport needs to avoid a scenario where the Council identify contributions and projects in response to each individual planning application on an ad hoc and reactive basis. Such an approach would not considered to be appropriate or sustainable and would not ensure that the local community consistently receive the benefits of new development in their areas. Furthermore, the local plan needs to make provision for a planned approach to community sports provision on strategic scale developments where provision is made on-site to ensure that where new facilities are provided that they are responsive to the needs identified by the community (in the Council’s evidence base documents) rather than led by developers who often have limited understanding of sports facility planning and local needs. For example, when the allocations for major development have been decided through the local plan process, a strategy should be prepared identifying how each development should make provision for sport and recreation based on the priorities identified in the Council’s evidence base in order to provide clarity and transparency to all parties.
• Public Health: Funding that may be available through the Council’s public health function that can be used towards sports facilities should be co-ordinated with developer contributions to ensure that opportunities for delivering priority projects are maximised. Sports facility projects may offer the potential to deliver public health priorities identified in the refreshed Health & Well-being Strategy especially those that encourage participation in physical activity by under-represented groups. Close working between planning and public health functions will be required to ensure that co-ordination of priorities takes place in practice.
• Partnership Working: To maximise the potential to secure funding for delivering key sports facility projects it will be essential that partnership working takes place because without this there is a risk that the limited funding available from different partners will not be co-ordinated. To take this forward in practical terms, as already advocated by Sport England through its engagement with the Council on the playing pitch/built facility strategies, an implementation group should be set up consisting of the Council, Active Essex, Sport England and sports governing bodies which would identify the priority projects to meet identified needs and develop an action plan for securing the funding for delivering these priorities. The local plan can assist by aligning such an action plan to the a review of the Infrastructure Delivery Plan to ensure that priorities agreed by the partners are prioritised for funding in relation to the use of CIL and planning obligation receipts. Such funding could then be used as match funding in relation to conventional funding sources such as Sport England’s lottery funds, governing body funding, public health funding etc. Strategic working with the other South Essex authorities is also advocated as it may be possible to provide facilities that serve more than one local authority by joint working which would reduce the funding required. In this regard, consideration should be given to the principle of cross-boundary financial contributions towards strategic projects that serve more than one local authority area.

Comment

New Local Plan

Representation ID: 3937

Received: 26/03/2019

Respondent: Environment Agency

Representation Summary:

Pressure for high density development should not detract from an aspiration to include SUDs, landscape and public open space. Development sites should retain natural features such as trees for shading, and natural flood management, and incorporate Green walls/roofs to mitigate the adverse impact of climate change.

Full text:

Thank you for the opportunity to comment on the Southend on Sea, new local plan, issues and options consultation. We have reviewed the issues and options document and have provided comments related to our remit following the format of your document.
Introduction No comments
Section 1: A Vision for Change
We support the inclusion of the renewal and replacement of sea defences as one of the challenges illustrated in Figure 7. It would also be useful to acknowledge the challenges of surface water flooding (from urban drainage systems) and fluvial flooding (from watercourses) as being a significant challenge given that flooding from both of these sources has affected the Borough in the past decade. This is a challenge for both the Borough and ourselves as we both have responsibilities under the Flood & Water Management Act 2010 as respective Flood Management Authorities. We will need to work closely together over the plan period to ensure that we can meet both technical and funding challenges in seeking solutions to these issues.
The challenge to enhance the built and natural environment, should fully consider the aquatic environment. The Local Plan should have suitable Policies to cover the significant pressures posed by development on the water environment. The Local Plan should reference the Water Framework Directive (WFD) and the two key objectives of WFD: no deterioration of waterbodies and ultimately improving all waterbodies to Good status. These objectives are key requirements of WFD and we would expect to see reference to both in the Local Plan. Local Authorities must have regard to the requirements of WFD when making their plans. From a water quality perspective; it would be useful to highlight the number of waterbodies within the borough failing WFD ‘ecological status or potential’ and ‘chemical status’. Information about the water environment and WFD reasons for not achieving good status and reasons for deterioration can be found in the Catchment Data Explorer: https://environment.data.gov.uk/catchment-planning
The Thames and Anglian River Basin Management Plans should be identified as sources of evidence: https://www.gov.uk/government/collections/river-basin-management-plans-2015
The Essex Rivers Hub provides a portal for sharing information about Essex Rivers and project work aimed at achieving good ecological status: http://essexrivershub.org.uk/index.php/about-us
Spatial Strategy
Option 1 – All development provided within the existing built up area
This option lends potential for re-development within the existing built up area to replace older conventional drainage systems on site with newer sustainable drainage systems (SUDS). This creates an opportunity to reduce peak drainage rates entering arterial surface water sewers and open watercourses from the site. Such measures could help the Council to meet NPPF objectives to reduce flood risk and offset the impacts of climate change (NPPF paras 149, 157c, 165).
The option also lends potential for re-development to restore localised green corridors adjacent to urban watercourses (Eastwood Brook, Prittle Brook, Southchurch Brook & Gunners Park Brook) and could provide net gains for biodiversity (NPPF para. 170).
Plans for redevelopment of sites near to the seafront should respect the key messages of the Thames Estuary 2100 Plan. Particularly regard should be made to opportunities to improve the riverside/seafront public spaces, access and to create new habitats as part of a riverside strategy and to not compromise the ability of the Borough Council or ourselves, to build those defences, integrating new defences with the new developments. This can be achieved as part of the Council’s plans for renewing or replacing its tidal flood defences. It is important that the vision for this is enhanced by the opportunities arising from redevelopments in riverside/seafront area and that land and access for the siting, construction and maintenance of future flood defences is not compromised by the layout, form and delivery of that development. Any work with 16 metres of a tidal flood defence would require an environmental permit.
The LPA’s role is crucial in helping to deliver the TE2100 plan’s recommendations. The planning system provides opportunities to implement the necessary improvements to the tidal flood defences that currently protect over 3700 homes and provide the Borough nearly £1 billion of economic benefits. Funding to renew or replace the flood defences will have to be supported, in part from local beneficiaries and from external contributions. Therefore it is very important that the Council seeks opportunities to secure contributions towards this infrastructure via developer contributions, Community Infrastructure Levy & bidding for Housing Infrastructure Funds.
Option 2 – Most development within the existing built up area with some development on the urban edges on greenfield and greenbelt land in Southend
There are some green field areas located adjacent to watercourses, which provide valuable green corridors and maintenance access. New development should not be allowed to encroach into these areas unless areas of public open space are to be maintained along the stream’s corridor. Any work undertaken within 8 metres of a main river would require an environmental permit. Opportunities should be taken to incorporate ecological enhancements to watercourses as part of any development. Some of these green field sites currently perform a flood storage purpose and this may be identified on the Flood Map for Planning or the Risk of Flooding from Surface Water maps. The frequency of this flood storage function is likely to become greater with the forecast impacts of climate change. The Council should therefore adhere to the sequential approach as advocated by para 157 of the NPPF and seek to avoid introducing development into areas that are required for current or future flood risk management.
We are currently in discussions with Southend Borough Council and Rochford District Council over the potential to develop a project to lower flood risk to properties from the Eastwood Brook and from surface water flooding in the areas adjacent to the Brook. The Local Planning Authority should ensure that it liaises with this project group to ensure that it adheres with NPPF paras 157 (b) and (c) to support this project and to safeguard land that may be required for future flood risk management. The EA contact for this Project is Roger Webster (roger.webster@environment-agency.gov.uk ).
Option 3 – Option 2 & working with neighbouring authorities to develop a comprehensive new settlement on Green Belt land (Strategic scale development)
Any Garden Community in the area north of Fossetts Farm, Garon Park and Bournes Green Chase should maintain a green open space corridor for the Mucking Hall Brook, with built development sited outside of the flood plain and incorporating SuDs drainage to ensure that peak flows, post development, in the Mucking Hall Brook are not increased above pre-development levels. It should be noted that this watercourse has never been modelled by ourselves and the areas of land peripheral to it are currently shown as Flood Zone 1 (low risk) on the Flood Map for Planning.
We would therefore advise that flood modelling is carried out as part of the information requirements for the South Essex Joint Strategic Plan to help identify any zones of higher flooding risk to ensure that the Council(s) can apply a Sequential Approach and avoid areas of flood risk in preliminary plans for the siting of built development within this potential strategic growth area. As above, all opportunities for ecological enhancements should be integrated into development.
Section 2: Planning for Growth and Change
Increases in density of housing on redevelopment sites across the existing built area should not compromise the ability to deliver sustainable drainage systems.
Residential developments
All new residential development is required to achieve a water consumption limit of a maximum of 125 litres per person per day as set out within the Building Regulations &c. (Amendment) Regulations 2015.
However, we recommend that in areas of serious water stress (as identified in our report Water stressed areas - final classification) a higher standard of a maximum of 110 litres per person per day is applied. This standard or higher should be included in a local plan policy.
Consideration for the waste created by growth should be considered in the local plan. Information in managing waste within planning system can be found at https://www.gov.uk/guidance/waste . As a minimum developers should follow the waste hierarchy but consideration could be given to the re-use of reclaimed aggregates in road building or within foundations for building projects.
Commercial/Industrial developments
We recommend that all new non-residential development of 1000sqm gross floor area or more should meet the BREEAM ‘excellent’ standards for water consumption.
Promoting Southend as a Major Resort
Significant lengths of the seafront and its associated homes and businesses are protected from flooding by tidal defences which will have to be raised in height after the year 2035 in order to combat the impacts of sea level rise and increasing flood risk. This is identified in the Thames Estuary 2100 Plan and as a “challenge” in Figure 7 of your Local Plan Issues and Option Consultation document.
Raising the defences on the existing ‘footprint’ would achieve the flood risk management objectives of the TE2100 Plan but would not provide any wider landscape or environmental benefits and could introduce a barrier to viewing the river/sea from the landward side.
There is therefore an opportunity to improve the riverside/seafront with the potential to improve public spaces, access, and to create new habitats both when defences are raised and repaired/replaced, and when new or re-developments are planned. This is referred to in the TE2100 Plan as the riverside strategy approach, which encourages partners to work together to implement improvements to the riverside in an integrated way. Maintaining the standard of the flood defences will assist in creating Southend as a major resort in the future.
Bathing Waters
Given that Southend is a coastal borough, and has numerous designated bathing water sites with varying bathing water quality, we would expect to see reference to the Bathing Water Directive in the Local Plan. Consideration should be given regarding the impacts of developments on these designated areas, particularly with regards to bathing water quality. Longer term utility planning should also consider bathing water quality as this could be affected by increases in sewage flows.
Providing for Vibrant and Attractive Town Centres No comments
Providing for a Sustainable Transport System
The C2C operated rail service from Southend Central to Fenchurch Street crosses the Hadleigh Marshes which is an area a risk of flooding from the Thames Estuary and is identified in the Action Plan for Zone 6 of the Thames Estuary 2100 Plan.
The TE2100 Plan has recommended a P3 policy for the future management of the tidal defences that protect the Hadleigh Marshes. Policy P3 advocates continuing with existing or alternative actions to manage flood risk. This means that we will continue to maintain flood defences at their current height, accepting that the likelihood and/or consequences of a flood will increase because of sea level rise. This policy therefore has potential impacts for the long term sustainability of the railway line as the chance of overtopping of the tidal defences will increase over time.
Our Thames Estuary Asset Management 2100 (TEAM2100) are near to completing an appraisal to help inform a future management strategy for the tidal defences at Hadleigh Marshes.
We are therefore keen to develop the management strategy and to commence dialogue to develop a long term programme with Southend Borough Council, Castle Point Borough Council, C2C Rail Operator, Network Rail and landowners as partners to better understand resilience opportunities for the rail transport infrastructure. The strategy that we develop must ensure that long term impacts of climate change on the C2C service and Network Rail infrastructure are understood and is built into local plans for infrastructure improvement and for flood warning.
Section 3: Creating Good Quality and Healthy Places
Facilitating Good Design and Healthy Living and Built Heritage
The design of quality SUDs features can lend wider benefits if combined with landscape and design of public open space associated with developments. The pressure for high density development should not detract from an aspiration to provide these combined benefits and the associated wellbeing merits of these open space areas. Development sites should retain natural features, such as trees, which will provide shade and assist in the reduction of the urban island heat effect. Additionally natural features like trees may intercept heavy rainfall and assist in natural flood management. Similarly the adverse impact of climate change on human health maybe reduced by incorporating features such as green roofs and walls into development.
Providing Community Services and Infrastructure
Flood Infrastructure
It is important that the Council seeks opportunities to secure contributions towards tidal and fluvial flood defence infrastructure, improved sewer and surface water infrastructure and for riverside strategy improvements. This is because central government’s Flood Defence Grant in Aid will not be sufficient on its own to fund necessary improvements / replacements to existing flood defence infrastructure.
As previously stated we would stress the importance of the Council in helping to secure developer contributions, using Community Infrastructure Levy & in bidding for Housing Infrastructure Funds in order to support future flood defence infrastructure that will help to sustain Southend’s vitality into the future.
Foul wastewater infrastructure capacity:
We would expect to see a section in the Local Plan looking at wastewater infrastructure and treatment. In general the Local Plan should:
• Demonstrate that adequate foul drainage infrastructure can be provided in a timely manner ahead of occupation of new properties – both for sewerage network and Water Recycling Centres (WRC).
• Demonstrate that the proposed development can be delivered without causing a breach of environmental legislation. Developments within the district and their associated increase in wastewater flows from Water Recycling Centres should not cause a deterioration in the receiving rivers / waterbodies.
• Demonstrate the need for all developers to liaise with the local sewerage undertaker regarding capacity of the existing sewerage infrastructure in the area.
• Sewerage networks - The plan will need to ensure there is sufficient volumetric capacity in the existing sewerage networks in each of the areas where development is planned. If no capacity is currently available, then provisions need to be in place ahead of the occupation of dwellings.
• Water Recycling Centres - The Local Plan needs to highlight which WRC within the district are proposed to receive additional flows from planned development. A thorough assessment of existing capacity and future flows against the current discharge permit should be made (this is usually done via the WCS). Any WRC predicted to exceed its permitted Dry Weather Flow will require a new discharge permit to accommodate the additional growth – this may contain potential tighter permit limits which could provide a constraint on development.
Contaminated Land
We would encourage the use of brownfield sites and contamination issues should be considered in relation to development and within the local plan. The guiding principles for land contamination provide guidance and considerations involved in the evaluation of the risk associated with land and water contamination. Further information can be found at https://www.gov.uk/government/publications/managing-and-reducing-land-contamination . Further information on the protection of groundwater can found in the groundwater protection documentation at https://www.gov.uk/government/collections/groundwater-protection
Enhancing our Natural Environment
We encourage you to adopt a riverside strategy approach in your local plans, strategies and guidance documents. This concept was introduced in the Thames Estuary 2100 Plan as a way for local planning authorities to ensure that future changes to the riverside take place in a planned and integrated way which maximise the potential environmental, social, cultural and economic benefits. We encourage you to work with your partners to ensure improvements to the riverside align with other relevant plans and strategies. There is the opportunity to improve the riverside both when flood defences are raised and when they are repaired or replaced. Raising the defences on the existing ‘footprint’ would achieve the flood risk management objectives of the TE2100 Plan but would not provide any wider landscape or environmental benefits and could introduce a barrier to viewing the river from the landward side. If planned for, there is the potential to achieve significant improvements when undertaking flood defence works, at modest cost. This includes improved public spaces, access, and potential creation of new habitats.
We have produced a separate guidance document which sets out our aspirations for the riverside strategy approach and what this means for you as our partner. We can also provide examples for improving the riverside on request.
Water Cycle Study (WCS) We are aware of a WCS which was undertaken for the Southend District in 2010 – we are unaware that this has been revised or updated. The WCS will assess the likely impact of all proposed growth and development across all aspects of the water environment within the District and where necessary will detail necessary measures to ensure that environmental legislation will not be compromised. Usually the WCS will serve as an evidence base to support the Local Plan and should suggest Policies and measures to enable the delivery of all proposed development. We would therefore, usually expect to see the WCS referenced in the plan and a summary of the findings/recommendations highlighted linking to how development will be dealt with sustainably within the district.
Green Infrastructure
We feel that green infrastructure should be given a more prominent place in this part of the plan. The plan should be looking to protect and enhance biodiversity and all development should be required to incorporate meaningful green infrastructure. Features that could be incorporated into developments include swales, ponds, reed beds and wildflower rich grasslands. Incorporating features such as green roofs and walls can be particularly effective measures providing urban habitats, increasing energy efficiency for buildings and attenuation of rain water.
Sustainable drainage systems should be promoted as they offer the opportunity to enhance the environment by providing blue infrastructure and can increase water quality, as well as providing drainage to developments.
In brief, our general requirements with regards to SuDS are:
1. Infiltration SuDS such as soakaways, unsealed porous pavement systems or infiltration basins shall only be used where it can be demonstrated that they will not pose a risk to the water environment.
2. Infiltration SuDS have the potential to provide a pathway for pollutants and must not be constructed in contaminated ground. They would only be acceptable if a phased site investigation showed the presence of no significant contamination. Other SuDS methods should be used in such cases.
3. Only clean water from roofs can be directly discharged to any soakaway or watercourse. Systems for the discharge of surface water from associated hard-standing, roads and impermeable vehicle parking areas shall incorporate appropriate pollution prevention measures and a suitable number of SuDS treatment train components appropriate to the environmental sensitivity of the receiving waters.
4. The maximum acceptable depth for infiltration SuDS is 2.0 m below ground level, with a minimum of 1.2 m clearance between the base of infiltration SuDS and peak seasonal groundwater levels.
5. Deep bore and other deep soakaway systems are not appropriate in areas where groundwater constitutes a significant resource (that is where aquifer yield may support or already supports abstraction). If deep soakaways are proposed you should contact us, as an environmental permit maybe needed.
Please also refer to the SuDS Manual (CIRIA C753, 2015), the Susdrain website (http://www.susdrain.org/) and the draft National Standards for SuDS (Defra, 2015) for more information.
Planning for Climate Change
We believe that you should develop local planning policies for the development of new or renewed sea defences as this would add weight to the recommendations of the TE2100 Plan and could set a framework for protecting land that is important for future flood defences (NPPF para 157b), and for making clear requirements for contributions towards infrastructure on sites that come forward that will benefit from those defences, or for integration of new developments with defences.
Water Efficiency/Supply
The section on climate change does not mention the effect this may have on water supply. Water resources should be protected for people and the environment.
We would like to see consideration of water supply for all new developments. We recommend an assessment regarding availability of water supply for further development and water saving measures. Development should be phased to ensure water supply demands are met.
Increased water efficiency for all new developments potentially enables more growth with the same water resources. Developers can highlight positive corporate social responsibility messages and the use of technology to help sell their homes. For the homeowner lower water usage also reduces water and energy bills. We endorse the use of water efficiency measures especially in new developments. Use of technology that ensures efficient use of natural resources could support the environmental benefits of future proposals and could help attract investment to the area. Therefore, water efficient technology, fixtures and fittings should be considered as part of new developments.
Section 4 – Southend’s Neighbourhoods No Comments

Comment

New Local Plan

Representation ID: 3968

Received: 01/04/2019

Respondent: Historic England

Representation Summary:

References should be made to the Historic Buildings and Monuments Commission (“Historic England”), not English Heritage (in Statement of Community Involvement).
Glossaries should include consistent definitions for all heritage assets mentioned in the local plan.
SM should be referred to as scheduled monuments rather than scheduled ancient monuments.
We recommend that designated heritage assets are marked on maps, where appropriate.

Full text:

Thank you for you notification of Issues and Options consultation for your Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process. We do not have the capacity to review the consultation document in detail. However, we provide the following general advice which may be useful to you as you prepare your Local Plan. We have produced a number of detailed Good Practice Advice and Advice Note documents. We recommend that you review the following as part of your local plan development: The Historic Environment in Local Plan - Good Practice Advice in Planning 1 https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans Managing Significance in Decision-Taking in the Historic Environment - Good Practice Advice in Planning 2 https://content.historicengland.org.uk/images-books/publications/gpa2- managing-significance-in-decision-taking/gpa2.pdf/ The Setting of Heritage Assets - Good Practice Advice in Planning 3 https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/ Conservation Area Appraisal, Designation and Management - Advice Note 1 https://historicengland.org.uk/images-books/publications/conservation-area-designation-appraisal-management-advice-note-1/ Making Changes to Heritage Assets - Advice Note 2 https://historicengland.org.uk/images-books/publications/making-changes-heritage-assets-advice-note-2/ The Historic Environment and Site Allocations and Local Plans - Advice Note 3 https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/ Tall buildings – Advice Note 4 https://historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/ Local Heritage Listing - Advice Note 7 https://www.historicengland.org.uk/images-books/publications/local-heritage-listing-advice-note-7/ Sustainability Appraisal and Strategic Environmental Assessment – Advice Note 8
https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/ All Historic England advice should be read alongside our Conservation Principles, which underpin our work. Conservation Principles can be found here:
https://historicengland.org.uk/advice/constructive-conservation/conservation-principles/
Specific Advice on Common Themes
Some common themes are clear from the advice we give in the East of England. A summary of some relevant topics follow:
Terminology
The historic environment is considered the most appropriate term to use as a topic heading as it encompasses all aspects of heritage, for example the tangible heritage assets and less tangible cultural heritage. Modern convention is to refer to scheduled monuments rather than scheduled ancient monuments, given that a wide range and age of monuments are scheduled. Please note that the official name of Historic England is the Historic Buildings and Monuments Commission for England. It was first established in 1984 and until 1 April 2015 was commonly known as English Heritage. At that point its common name changed to Historic England and a new charity, officially called the English Heritage Trust, took the name of English Heritage. English Heritage looks after the National Heritage Collection of more than 400 state-owned historic sites and monuments across England. It is therefore Historic England that is the statutory consultee, rather than English Heritage.
Sustainability Appraisal Scoping
The historic environment should be considered as part of the sustainability appraisal process. We recommend that these comments should be read alongside our Advice Note 8.
Key Plans and Programmes
When considering key plans and programmes, we recommend the inclusion and consideration of the following:
International/European
• UNESCO World Heritage Convention
• European Landscape Convention
• The Convention for the Protection of the Architectural Heritage of Europe
• The European Convention on the Protection of Archaeological Heritage
National
• Planning (Listed Buildings & Conservation Areas) Act 1990
• Ancient Monuments & Archaeological Areas Act 1979
• Marine and Coastal Areas Access Act 2009
• Government’s statement on the Historic Environment
• National Planning Policy Framework
• National Planning Policy Guidance
Local
• Local Plans
• Historic Environment Record
• AONB Management Plans
• Heritage/Conservation Strategies
• Other Strategies (e.g. cultural or tourism)
• Conservation Area Character Appraisals and Management Plans
• Listed building Heritage Partnership Agreements
Baseline Information
All designated heritage assets (Conservation Areas, Listed Buildings, Scheduled Monuments, Registered Parks and Gardens, Registered Battlefields, and Protected Wrecks) within the area should be identified. Mapping these assets provides a greater indication of their distribution and highlights sensitive areas. Include, but are not confined to, locally listed buildings. In addition to the above, we would expect reference to currently unknown heritage assets, particularly sites of historic and archaeological interest. The unidentified heritage assets of the City, Borough or District should be acknowledged and outlined in this section. Identification and mapping of designated and non-designated heritage assets at risk can provide an indication of clusters and themes. Historic England’s Good Practice Advice Note 1 contains advice on other relevant sources of evidence. These include Conservation Area Appraisals and Management Plans, Local Lists, Historic Characterisation assessments and any other in-house and local knowledge. We recommend that these other sources of evidence are considered as part of the SA process.
Key Sustainability Issues
We would suggest that the starting point for considering Key Sustainability Issues for the Historic Environment should include:
• Conserving and enhancing designated and non-designated heritage assets and the contribution made by their settings
• Heritage assets at risk from neglect, decay, or development pressures;
• Areas where there is likely to be further significant loss or erosion of landscape/seascape/townscape character or quality, or where development has had or is likely to have significant impact (direct and or indirect) upon the historic environment and/or people’s enjoyment of it
• Traffic congestion, air quality, noise pollution and other problems affecting the historic environment
We would expect to see consideration of opportunities. It is considered that the historic environment can make a significant contribution to the success of development and there may be opportunities for the enhancement of the historic environment which comes from sustainable development proposals. It is considered that the Sustainability Appraisal should highlight these opportunities. Example opportunities for the historic environment to include within the Sustainability Appraisal can be found in our guidance notes in the links above.
Method for Generation of Alternatives
The historic environment should be a factor when considering a method for the generation of alternative proposals. The impact of proposals on the significance of heritage assets should be taken into consideration at an early stage. In terms of sites, this should be based on more than just measuring the proximity of a potential allocation to heritage assets. Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base.
Conclusion
We would encourage local authorities to work with local conservation officers, archaeology officers and local heritage community groups in the preparation of the Sustainability Appraisal. Our advice note provides more guidance to developing a robust sustainability appraisal framework.
Evidence base
Any evidence base should be proportionate. However, with a local plan we would expect to see a comprehensive and robust evidence base. Sources include:
• National Heritage List for England. www.historicengland.org.uk/the-list/
• Heritage Gateway. www.heritagegateway.org.uk
• Historic Environment Record.
• National and local heritage at risk registers. www.historicengland.org.uk/advice/heritage-at-risk
• Non-designated or locally listed heritage assets (buildings, monuments, parks and gardens, areas)
• Conservation area appraisals and management plans
• Historic characterisation assessments e.g. the Extensive Urban Surveys and Historic Landscape Characterisation Programme or more local documents. www.archaeologydataservice.ac.uk/archives/view/EUS/
• Environmental capacity studies for historic towns and cities or for historic areas e.g. the Craven Conservation Areas Assessment Project. www.cravendc.gov.uk/CHttpHandler.ashx?id=11207&p=0
• Detailed historic characterization work assessing impact of specific proposals.
• Heritage Impact Assessments looking into significance and setting.
• Green Belt studies.
• Visual impact assessments.
• Archaeological assessments.
• Topic papers.
Green Belt
One of the five purposes of the Green Belt is to preserve the setting and special character of historic towns. Historic towns and former towns are situated across the region and should form a consideration in any review of Green Belt.
Without an appreciation of the history of the region’s historic settlements and their close relationship to their surrounding landscapes, it is not possible to properly ascribe a value to the openness of the Green Belt land around them. Consideration of the value of the Green Belt requires understanding the historic significance of this open landscape. Whilst Green Belt reviews often divide the area into parcels of land to make the assessment exercise manageable, parcels should not be solely reviewed individually within their immediate context. It also is important to understand how collectively they achieve the strategic aims of the Green Belt.
Green Infrastructure
Landscape, parks and open space often have heritage interest, and it would be helpful to highlight this. It is important not to consider ‘multi-functional’ spaces only in terms of the natural environment, health and recreation. It may be helpful to make reference in the text to the role GI can have to play in enhancing and conserving the historic environment. It can be used to improve the setting of heritage assets and to improve access to it, likewise heritage assets can help contribute to the quality of green spaces by helping to create a sense of place and a tangible link with local history. Opportunities can be taken to link GI networks into already existing green spaces in town or existing historic spaces such as church yards to improve the setting of historic buildings or historic townscape. Maintenance of GI networks and spaces should also be considered so that they continue to serve as high quality places which remain beneficial in the long term.
Site Allocations
Historic England advocates a wide definition of the historic environment which includes not only those areas and buildings with statutory designated protection but also those which are locally valued and important, as well as the landscape and townscape components of the historic environment. The importance and extent of below ground archaeology is often unknown, although information in the Historic Environment Record (HER) will indicate areas of known interest, or high potential where further assessment is required before decisions or allocations are made. Conservation and archaeology staff within the relevant councils should be consulted on matters relating to archaeology, landscape/townscape and the historic environment generally.
We often find that while some of the sites in the Plan identify heritage assets as potential constraints, this is not consistently done for all sites and all heritage assets. There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified. It should be noted that there are areas of archaeological interest beyond scheduled monuments and historic landscape issues beyond registered historic parks & gardens. Wider archaeological and landscape/townscape impacts are important considerations and need to be factored into site assessment. The possible cumulative impact of a number of site allocations in one location could also cause considerable harm to the historic landscape/townscape.
All sites should be scoped for archaeological potential before taking them forward to the next stage, as there is a high likelihood of archaeological sites not on the HER. Archaeological assessment and evaluation should be in line with the NPPF and best practice guidance so that impacts can be assessed at the earliest opportunity.
Assessing sites
Our advice note 3 on site allocations in local plans sets out a suggested approach to assessing sites and their impact on heritage assets. It advocates a number of steps, including understanding what contribution a site, in its current form, makes to the significance of the heritage asset/s, and identifying what impact the allocation might have on significance. This could be applied to the assessment and selecting of sites within a plan.
In essence, it is important that you
a. Identify any heritage assets that may be affected by the potential site allocation.
b. Understand what contribution the site makes to the significance of the asset
c. Identify what impact the allocation might have on that significance
d. Consider maximising enhancements and avoiding harm
e. Determine whether the proposed allocation is appropriate in light of the NPPFs tests of soundness
In assessing sites it is important to identify those sites which are inappropriate for development and also to assess the potential capacity of the site in the light of any historic environment (and other) factors. If a site is allocated, we would expect to see reference in the policy and supporting text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. Paragraph 157 of the National Planning Policy Framework requires Local Plans to provide detail with site allocations where appropriate (fifth bullet point), with the Planning Practice Guidance stating “where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interests about the nature and scale of development (addressing the ‘what, where, when and how’ questions)” (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).
Assessment criteria
Many authorities include a distance based criteria to assess impact on the historic environment. It is important to understand the significance of any heritage assets, and their settings, that would be affected by a potential site allocation. This involves more than identifying known heritage assets within a given distance, but rather a more holistic process which seeks to understand their significance and value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms.
Heritage Impact Assessments
In order to help refine which growth allocations to take forward, we would suggest that a Heritage Impact Assessment is undertaken of each of these sites. We would refer you to our Advice Note 3 ‘The Historic Environment and Site Allocations in Local Plans.
All potential sites will need to be appraised against potential historic environment impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or intervisibility with, a potential site. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable. Cumulative effects of site options on the historic environment should be considered too.
The following broad steps might be of assistance in terms of assessing sites:
• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced
The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
A positive strategy for the historic environment
Paragraph 126 of the NPPF requires Local Plans to set out a positive and clear strategy for the conservation, enjoyment and enhancement of the historic environment. Ideally the strategy should offer a strategic overview including overarching heritage policies to deliver the conservation and enhancement of the environment. A good strategy will offer a positive holistic approach throughout the whole plan whereby the historic environment is considered not just as a stand-alone topic but as an integral part of every aspect of the plan, being interwoven within the entire document. So policies for housing, retail, and transport for example may need to be tailored to achieve the positive improvements that paragraph 8 of the NPPF demands. Site allocations may need to refer to the historic environment, identifying opportunities to conserve and enhance the historic environment, avoid harming heritage assets and their settings and may also be able to positively address heritage assets at risk. The plan may need to include areas identified as being inappropriate for certain types of development due to the impact they would have on the historic environment. A good strategy will also be spatially specific, unique to the area, describing the local characteristics of the borough and responding accordingly with policies that address the local situation. We would expect references to the historic environment in the local plan vision, the inclusion of a policy/ies for the historic environment and character of the landscape and built environment, and various other references to the historic environment through the plan relating to the unique characteristics of the area.
Strategic policies
Strategic policies are a very important part of the plan, particularly given the need for Neighbourhood Plans to be in conformity with these policies. Paragraph 156 of the NPPF makes it clear that, ‘Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver conservation and enhancement of the natural and historic environment including landscape.’ Therefore we would strongly advise the inclusion of a strategic policy that addresses these matters.
Site specific policies
Historic England advocates a wide definition of the historic environment which includes not only those areas and buildings with statutory designated protection but also those which are locally valued and important, as well as the landscape and townscape components of the historic environment. The importance and extent of below ground archaeology is often unknown, although information in the Historic Environment Record (HER) will indicate areas of known interest, or high potential where further assessment is required before decisions or allocations are made. Conservation and archaeology staff within the relevant councils should be consulted on matters relating to archaeology, landscape/townscape and the historic environment generally.
Site specific heritage policies may give guidance on development within or adjacent to heritage assets that demonstrate the local area’s special and distinctive character. You may wish to provide such policies for the following areas of the historic environment, along with any others that are appropriate or brought forward via the consultation process; In all cases, it should be emphasised in local policies and supporting text, that the setting of heritage assets should be considered holistically as part of the historic environment and that a consideration of setting should form part of any assessment of significance. Where any site allocation includes heritage assets or could affect their setting, this should be identified as a consideration of material weight in the consideration of subsequent development proposals equal or greater than presumption in favour of development through the site allocation process.
Setting
We expect to see appropriate references to setting in policies. As with assessing the impact of site allocations on setting, with a site specific allocation, it is important to understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations. This involves more than identifying known heritage assets within a given distance, but rather a more holistic process which seeks to understand their significance and value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.
Archaeology
We welcome specific provision for the protection and enhancement of archaeology as well as emphasis that sites of archaeological importance can occur everywhere. We encourage clear guidance on expectations for archaeological recording and the submission of records with an appropriate public record (e.g.: Historic Environment Records) for archaeological remains that are not to be retained in situ. Where suggested sites are located in areas of known archaeological potential, weight should be given to this as a consideration in site selection and the comparison with alternate locations. We encourage close liaison with the County Archaeologist at site allocation stage.
Listed Buildings
Listed buildings include a variety of structures reflecting the areas architectural, industrial and cultural heritage. We will look for policies that carefully consider the preservation and preferably enhancement of these assets and crucially, of their setting. In some instances, a full consideration of setting may require close co-operation with adjoining districts where landscape setting may fall within the boundary of these neighbouring authorities. Where relevant, we will seek evidence of this cross-boundary co-operation in the evidence base.
We also encourage a policy that addresses the potential listing over the plan period of as yet unidentified heritage assets that further demonstrate the development and activity of the town and its inhabitants.
Conservation Areas
Each local authority contains a number of designated Conservation Areas. We encourage that the local plan process provides a basis for the continued update and management of Conservation Management Plans, identifying each conservation area’s local identity and distinctiveness. These should identify features that typify and contribute to this special distinctiveness as well as allow for less tangible judgments of character, quality of place and special distinctiveness. The plan will be more robust where it directs future development to take account of the special and distinctive character of Conservation Areas, emphasising that this is a cumulative result of built form, materials, spaces and street patterns, uses and relationships to surrounding features such as the surviving historic buildings and street patterns. We would also welcome provision for any future designation of conservation areas within cities, districts and boroughs as well as specific provision for the landscape setting of different parts of the area.
Registered Parks and Gardens
It may be appropriate to specifically identify Registered Parks and Gardens as protected by any such policy. The policy should anticipate and protect any future designations.
Heritage at Risk
We recommend the inclusion of a policy basis to address Heritage at Risk. We also recommend the creation and management of a local Heritage at Risk register for Grade II listed buildings. Similarly, we welcome positive local solutions for addressing all heritage at risk, whether nationally or locally identified. The National Heritage at Risk Register can be found and searched here by local authority: www.historicengland.org.uk/advice/heritage-at-risk
Non-designated heritage assets
Historic England has published guidance pertaining to Local Listing which you may find helpful: https://historicengland.org.uk/images-books/publications/local-heritage-listing-advice-note-7/ In national policy terms, ‘non-designated heritage assets’ (including those on a local list) are recognised as having a degree of significance meriting consideration in planning decisions. Paragraph 135 of the National Planning Policy Framework states that decisions on applications affecting such assets will require a balanced judgment that has regard to the significance of the asset and any harm or loss: http://planningguidance.planningportal.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/12-conserving-and-enhancing-the-historic-environment/
Government guidance recognises that local lists and local criteria for identifying non-designated heritage assets are a positive thing and can help with decision-making: http://planningguidance.planningportal.gov.uk/blog/guidance/conserving-and-enhancing-the-historic-environment/what-are-non-designated-heritage-assets-and-how-important-are-they/ We would recommend that as a minimum a local authority has established criteria for identifying non-designated heritage assets, and ideally has a local list of assets linked to planning policies in their Local Plan. A good example is Peterborough: http://www2.peterborough.gov.uk/environment/listed_buildings/locally_listed_building s.aspx There are enough appeal cases to indicate that inspectors regard non-designated heritage assets, and something on a local list, as an important material consideration in planning decisions. In fact, where there isn’t a local list, some inspectors have been unable to give as much weight to a non-designated heritage asset. Our website contains a number of appeal cases and if you search for ‘locally listed heritage asset’ or ‘non-designated heritage asset’, you will get relevant ones: http://www.historicengland.org.uk/advice/hpg/planning-cases Robust provision for these heritage assets will increase the soundness of your forthcoming plan.
Design
We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic environment and reflect local character and distinctiveness. This should not stymie contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design. We would also welcome this in relation to tall buildings policy that may come forward as part of the plan.
Landscape and Streetscape
Landscape
Landscape character assessments, particularly those accommodating major developments, can be deficient in assessing the landscape value relating to scheduled monuments and their settings. The historic environment has an important role to play in understanding the landscape. Many tracks, green lanes, field boundaries and settlement patterns are remnants of past use and provide evidence of how the landscape has evolved over time. The objective of protecting and enhancing the landscape and recognition of its links to cultural heritage can help improve how the historic environment is experienced an enjoyed.
Streetscape
Consideration of streetscape, particularly given the issues of connectivity and traffic management is an area for exploration. For streetscape improvements we would refer you to the Streets for All publications https://historicengland.org.uk/images-books/publications/streets-for-all/. These documents provide updated practical advice for anyone involved in planning and implementing highways and other public realm works in sensitive historic locations. It sets out means to improve public spaces without harming their valued character, including specific recommendations for works to surfaces, street furniture, new equipment, traffic management infrastructure and environmental improvements.
The advice draws on the experience of Historic England's planning teams in the development of highways and public realm schemes. Case studies show where highways works and other public realm schemes have successfully integrated with and enhanced areas of historic or architectural sensitivity. Please also see our advice for highways engineers and designers: https://historicengland.org.uk/advice/caring-for-heritage/streets-for-all/highway-engineers-and-designers/.
Climate Change and Renewable Energy
We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment.
Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiency-historic-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.
Historic Shopfronts
The retention of original/historic or significant shopfronts elements are often integral to the character of these buildings and that of the wider street scene. The Local Plan should highlight the importance of retaining or restoring historic shopfront features. This is both in terms of the positive contribution historic shopfronts make to the character of an area, but also the economic benefit of providing traditional and bespoke shopping units to shop owners. A good example of how historic shopfronts can positively contribute to an area both aesthetically and economically is where Derby City Council teamed up with English Heritage (now Historic England) to help restore an area of Victorian and Edwardian shops, the Strand. The restoration of a number of shops within the area has meant that a previously underused section of the city provides bespoke shopping, now sees a much larger footfall and is considered to be a National success. The council have also seen a ripple effect of surrounding properties being restored.
Enabling Development By definition within the NPPF, enabling development is development that is not otherwise in accordance with adopted policy. We are therefore of the view that a policy on enabling development is not a necessary component of a local plan document. A local plan should adequately set out a positive strategy for the historic environment without the need to include such a policy.
Monitoring
We recommend indicators to measure how successful historic environment policies are. These can include preparation of a local list, completion of conservation area action plans and management plans, reduction in the number of assets that are classified as heritage at risk.
Glossary
Glossaries should include consistent definitions for all heritage assets mentioned in the local plan. These would typically include:
• Listed Buildings
• Scheduled Monuments
• Conservation Areas
• Registered Parks and Gardens
• Registered Battlefields
• Protected Wrecks
• Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage Assets / Locally Listed Buildings
Mapping
We recommend that designated heritage assets are marked on maps, where appropriate.
Statement of Community Involvement
References should be made to the Historic Buildings and Monuments Commission (“Historic England”), not English Heritage.
Concluding thoughts
In preparation of the forthcoming Southend Local Plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups. Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

Comment

New Local Plan

Representation ID: 3971

Received: 01/04/2019

Respondent: Historic England

Representation Summary:

Seek a specific requirement for consideration of historic environment within design policies including in relation to tall buildings.
The Plan should highlight importance of retaining or restoring historic shopfronts. A local plan should adequately set out a positive strategy for the historic environment without the need to include a policy on enabling development (as this is already in national policy).

Full text:

Thank you for you notification of Issues and Options consultation for your Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process. We do not have the capacity to review the consultation document in detail. However, we provide the following general advice which may be useful to you as you prepare your Local Plan. We have produced a number of detailed Good Practice Advice and Advice Note documents. We recommend that you review the following as part of your local plan development: The Historic Environment in Local Plan - Good Practice Advice in Planning 1 https://historicengland.org.uk/images-books/publications/gpa1-historic-environment-local-plans Managing Significance in Decision-Taking in the Historic Environment - Good Practice Advice in Planning 2 https://content.historicengland.org.uk/images-books/publications/gpa2- managing-significance-in-decision-taking/gpa2.pdf/ The Setting of Heritage Assets - Good Practice Advice in Planning 3 https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage-assets/ Conservation Area Appraisal, Designation and Management - Advice Note 1 https://historicengland.org.uk/images-books/publications/conservation-area-designation-appraisal-management-advice-note-1/ Making Changes to Heritage Assets - Advice Note 2 https://historicengland.org.uk/images-books/publications/making-changes-heritage-assets-advice-note-2/ The Historic Environment and Site Allocations and Local Plans - Advice Note 3 https://historicengland.org.uk/images-books/publications/historic-environment-and-site-allocations-in-local-plans/ Tall buildings – Advice Note 4 https://historicengland.org.uk/images-books/publications/tall-buildings-advice-note-4/ Local Heritage Listing - Advice Note 7 https://www.historicengland.org.uk/images-books/publications/local-heritage-listing-advice-note-7/ Sustainability Appraisal and Strategic Environmental Assessment – Advice Note 8
https://historicengland.org.uk/images-books/publications/sustainability-appraisal-and-strategic-environmental-assessment-advice-note-8/ All Historic England advice should be read alongside our Conservation Principles, which underpin our work. Conservation Principles can be found here:
https://historicengland.org.uk/advice/constructive-conservation/conservation-principles/
Specific Advice on Common Themes
Some common themes are clear from the advice we give in the East of England. A summary of some relevant topics follow:
Terminology
The historic environment is considered the most appropriate term to use as a topic heading as it encompasses all aspects of heritage, for example the tangible heritage assets and less tangible cultural heritage. Modern convention is to refer to scheduled monuments rather than scheduled ancient monuments, given that a wide range and age of monuments are scheduled. Please note that the official name of Historic England is the Historic Buildings and Monuments Commission for England. It was first established in 1984 and until 1 April 2015 was commonly known as English Heritage. At that point its common name changed to Historic England and a new charity, officially called the English Heritage Trust, took the name of English Heritage. English Heritage looks after the National Heritage Collection of more than 400 state-owned historic sites and monuments across England. It is therefore Historic England that is the statutory consultee, rather than English Heritage.
Sustainability Appraisal Scoping
The historic environment should be considered as part of the sustainability appraisal process. We recommend that these comments should be read alongside our Advice Note 8.
Key Plans and Programmes
When considering key plans and programmes, we recommend the inclusion and consideration of the following:
International/European
• UNESCO World Heritage Convention
• European Landscape Convention
• The Convention for the Protection of the Architectural Heritage of Europe
• The European Convention on the Protection of Archaeological Heritage
National
• Planning (Listed Buildings & Conservation Areas) Act 1990
• Ancient Monuments & Archaeological Areas Act 1979
• Marine and Coastal Areas Access Act 2009
• Government’s statement on the Historic Environment
• National Planning Policy Framework
• National Planning Policy Guidance
Local
• Local Plans
• Historic Environment Record
• AONB Management Plans
• Heritage/Conservation Strategies
• Other Strategies (e.g. cultural or tourism)
• Conservation Area Character Appraisals and Management Plans
• Listed building Heritage Partnership Agreements
Baseline Information
All designated heritage assets (Conservation Areas, Listed Buildings, Scheduled Monuments, Registered Parks and Gardens, Registered Battlefields, and Protected Wrecks) within the area should be identified. Mapping these assets provides a greater indication of their distribution and highlights sensitive areas. Include, but are not confined to, locally listed buildings. In addition to the above, we would expect reference to currently unknown heritage assets, particularly sites of historic and archaeological interest. The unidentified heritage assets of the City, Borough or District should be acknowledged and outlined in this section. Identification and mapping of designated and non-designated heritage assets at risk can provide an indication of clusters and themes. Historic England’s Good Practice Advice Note 1 contains advice on other relevant sources of evidence. These include Conservation Area Appraisals and Management Plans, Local Lists, Historic Characterisation assessments and any other in-house and local knowledge. We recommend that these other sources of evidence are considered as part of the SA process.
Key Sustainability Issues
We would suggest that the starting point for considering Key Sustainability Issues for the Historic Environment should include:
• Conserving and enhancing designated and non-designated heritage assets and the contribution made by their settings
• Heritage assets at risk from neglect, decay, or development pressures;
• Areas where there is likely to be further significant loss or erosion of landscape/seascape/townscape character or quality, or where development has had or is likely to have significant impact (direct and or indirect) upon the historic environment and/or people’s enjoyment of it
• Traffic congestion, air quality, noise pollution and other problems affecting the historic environment
We would expect to see consideration of opportunities. It is considered that the historic environment can make a significant contribution to the success of development and there may be opportunities for the enhancement of the historic environment which comes from sustainable development proposals. It is considered that the Sustainability Appraisal should highlight these opportunities. Example opportunities for the historic environment to include within the Sustainability Appraisal can be found in our guidance notes in the links above.
Method for Generation of Alternatives
The historic environment should be a factor when considering a method for the generation of alternative proposals. The impact of proposals on the significance of heritage assets should be taken into consideration at an early stage. In terms of sites, this should be based on more than just measuring the proximity of a potential allocation to heritage assets. Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base.
Conclusion
We would encourage local authorities to work with local conservation officers, archaeology officers and local heritage community groups in the preparation of the Sustainability Appraisal. Our advice note provides more guidance to developing a robust sustainability appraisal framework.
Evidence base
Any evidence base should be proportionate. However, with a local plan we would expect to see a comprehensive and robust evidence base. Sources include:
• National Heritage List for England. www.historicengland.org.uk/the-list/
• Heritage Gateway. www.heritagegateway.org.uk
• Historic Environment Record.
• National and local heritage at risk registers. www.historicengland.org.uk/advice/heritage-at-risk
• Non-designated or locally listed heritage assets (buildings, monuments, parks and gardens, areas)
• Conservation area appraisals and management plans
• Historic characterisation assessments e.g. the Extensive Urban Surveys and Historic Landscape Characterisation Programme or more local documents. www.archaeologydataservice.ac.uk/archives/view/EUS/
• Environmental capacity studies for historic towns and cities or for historic areas e.g. the Craven Conservation Areas Assessment Project. www.cravendc.gov.uk/CHttpHandler.ashx?id=11207&p=0
• Detailed historic characterization work assessing impact of specific proposals.
• Heritage Impact Assessments looking into significance and setting.
• Green Belt studies.
• Visual impact assessments.
• Archaeological assessments.
• Topic papers.
Green Belt
One of the five purposes of the Green Belt is to preserve the setting and special character of historic towns. Historic towns and former towns are situated across the region and should form a consideration in any review of Green Belt.
Without an appreciation of the history of the region’s historic settlements and their close relationship to their surrounding landscapes, it is not possible to properly ascribe a value to the openness of the Green Belt land around them. Consideration of the value of the Green Belt requires understanding the historic significance of this open landscape. Whilst Green Belt reviews often divide the area into parcels of land to make the assessment exercise manageable, parcels should not be solely reviewed individually within their immediate context. It also is important to understand how collectively they achieve the strategic aims of the Green Belt.
Green Infrastructure
Landscape, parks and open space often have heritage interest, and it would be helpful to highlight this. It is important not to consider ‘multi-functional’ spaces only in terms of the natural environment, health and recreation. It may be helpful to make reference in the text to the role GI can have to play in enhancing and conserving the historic environment. It can be used to improve the setting of heritage assets and to improve access to it, likewise heritage assets can help contribute to the quality of green spaces by helping to create a sense of place and a tangible link with local history. Opportunities can be taken to link GI networks into already existing green spaces in town or existing historic spaces such as church yards to improve the setting of historic buildings or historic townscape. Maintenance of GI networks and spaces should also be considered so that they continue to serve as high quality places which remain beneficial in the long term.
Site Allocations
Historic England advocates a wide definition of the historic environment which includes not only those areas and buildings with statutory designated protection but also those which are locally valued and important, as well as the landscape and townscape components of the historic environment. The importance and extent of below ground archaeology is often unknown, although information in the Historic Environment Record (HER) will indicate areas of known interest, or high potential where further assessment is required before decisions or allocations are made. Conservation and archaeology staff within the relevant councils should be consulted on matters relating to archaeology, landscape/townscape and the historic environment generally.
We often find that while some of the sites in the Plan identify heritage assets as potential constraints, this is not consistently done for all sites and all heritage assets. There also can be limited information in documents on how sites might be developed, making it difficult for Historic England, and others, to assess their full impact. We are keen that allocated sites include development criteria to guide future proposals, including references to the historic environment where needed (this follows the national Planning Practice Guidance). There is a danger to both heritage assets and potential developers of allocating sites without such criteria and establishing the principle of development without guidance on the issues that need to be addressed at the planning application stage. The significance of heritage assets, and the potential impact of allocations on that significance, will need to be understood and justified. It should be noted that there are areas of archaeological interest beyond scheduled monuments and historic landscape issues beyond registered historic parks & gardens. Wider archaeological and landscape/townscape impacts are important considerations and need to be factored into site assessment. The possible cumulative impact of a number of site allocations in one location could also cause considerable harm to the historic landscape/townscape.
All sites should be scoped for archaeological potential before taking them forward to the next stage, as there is a high likelihood of archaeological sites not on the HER. Archaeological assessment and evaluation should be in line with the NPPF and best practice guidance so that impacts can be assessed at the earliest opportunity.
Assessing sites
Our advice note 3 on site allocations in local plans sets out a suggested approach to assessing sites and their impact on heritage assets. It advocates a number of steps, including understanding what contribution a site, in its current form, makes to the significance of the heritage asset/s, and identifying what impact the allocation might have on significance. This could be applied to the assessment and selecting of sites within a plan.
In essence, it is important that you
a. Identify any heritage assets that may be affected by the potential site allocation.
b. Understand what contribution the site makes to the significance of the asset
c. Identify what impact the allocation might have on that significance
d. Consider maximising enhancements and avoiding harm
e. Determine whether the proposed allocation is appropriate in light of the NPPFs tests of soundness
In assessing sites it is important to identify those sites which are inappropriate for development and also to assess the potential capacity of the site in the light of any historic environment (and other) factors. If a site is allocated, we would expect to see reference in the policy and supporting text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. Paragraph 157 of the National Planning Policy Framework requires Local Plans to provide detail with site allocations where appropriate (fifth bullet point), with the Planning Practice Guidance stating “where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interests about the nature and scale of development (addressing the ‘what, where, when and how’ questions)” (PPG Reference ID: 12-010-20140306 (last revised 06/03/2014). Paragraph 154 of the NPPF also states that only policies that provide a clear indication of how a decision maker should react to a development proposal should be included in the plan. Conservation of the historic environment is a core planning principle (Paragraph 17) and Local Plans should set out a positive strategy in this respect (Paragraph 126).
Assessment criteria
Many authorities include a distance based criteria to assess impact on the historic environment. It is important to understand the significance of any heritage assets, and their settings, that would be affected by a potential site allocation. This involves more than identifying known heritage assets within a given distance, but rather a more holistic process which seeks to understand their significance and value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms.
Heritage Impact Assessments
In order to help refine which growth allocations to take forward, we would suggest that a Heritage Impact Assessment is undertaken of each of these sites. We would refer you to our Advice Note 3 ‘The Historic Environment and Site Allocations in Local Plans.
All potential sites will need to be appraised against potential historic environment impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or intervisibility with, a potential site. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable. Cumulative effects of site options on the historic environment should be considered too.
The following broad steps might be of assistance in terms of assessing sites:
• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced
The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.
A positive strategy for the historic environment
Paragraph 126 of the NPPF requires Local Plans to set out a positive and clear strategy for the conservation, enjoyment and enhancement of the historic environment. Ideally the strategy should offer a strategic overview including overarching heritage policies to deliver the conservation and enhancement of the environment. A good strategy will offer a positive holistic approach throughout the whole plan whereby the historic environment is considered not just as a stand-alone topic but as an integral part of every aspect of the plan, being interwoven within the entire document. So policies for housing, retail, and transport for example may need to be tailored to achieve the positive improvements that paragraph 8 of the NPPF demands. Site allocations may need to refer to the historic environment, identifying opportunities to conserve and enhance the historic environment, avoid harming heritage assets and their settings and may also be able to positively address heritage assets at risk. The plan may need to include areas identified as being inappropriate for certain types of development due to the impact they would have on the historic environment. A good strategy will also be spatially specific, unique to the area, describing the local characteristics of the borough and responding accordingly with policies that address the local situation. We would expect references to the historic environment in the local plan vision, the inclusion of a policy/ies for the historic environment and character of the landscape and built environment, and various other references to the historic environment through the plan relating to the unique characteristics of the area.
Strategic policies
Strategic policies are a very important part of the plan, particularly given the need for Neighbourhood Plans to be in conformity with these policies. Paragraph 156 of the NPPF makes it clear that, ‘Local planning authorities should set out the strategic priorities for the area in the Local Plan. This should include strategic policies to deliver conservation and enhancement of the natural and historic environment including landscape.’ Therefore we would strongly advise the inclusion of a strategic policy that addresses these matters.
Site specific policies
Historic England advocates a wide definition of the historic environment which includes not only those areas and buildings with statutory designated protection but also those which are locally valued and important, as well as the landscape and townscape components of the historic environment. The importance and extent of below ground archaeology is often unknown, although information in the Historic Environment Record (HER) will indicate areas of known interest, or high potential where further assessment is required before decisions or allocations are made. Conservation and archaeology staff within the relevant councils should be consulted on matters relating to archaeology, landscape/townscape and the historic environment generally.
Site specific heritage policies may give guidance on development within or adjacent to heritage assets that demonstrate the local area’s special and distinctive character. You may wish to provide such policies for the following areas of the historic environment, along with any others that are appropriate or brought forward via the consultation process; In all cases, it should be emphasised in local policies and supporting text, that the setting of heritage assets should be considered holistically as part of the historic environment and that a consideration of setting should form part of any assessment of significance. Where any site allocation includes heritage assets or could affect their setting, this should be identified as a consideration of material weight in the consideration of subsequent development proposals equal or greater than presumption in favour of development through the site allocation process.
Setting
We expect to see appropriate references to setting in policies. As with assessing the impact of site allocations on setting, with a site specific allocation, it is important to understand the significance of any heritage asset/s, and their setting/s, that would be affected by the site allocation in order for the policy to reflect these considerations. This involves more than identifying known heritage assets within a given distance, but rather a more holistic process which seeks to understand their significance and value. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, reducing the suitability of the site allocation in sustainable development terms. We would expect to see this reflected in the policy wording and supporting text.
Archaeology
We welcome specific provision for the protection and enhancement of archaeology as well as emphasis that sites of archaeological importance can occur everywhere. We encourage clear guidance on expectations for archaeological recording and the submission of records with an appropriate public record (e.g.: Historic Environment Records) for archaeological remains that are not to be retained in situ. Where suggested sites are located in areas of known archaeological potential, weight should be given to this as a consideration in site selection and the comparison with alternate locations. We encourage close liaison with the County Archaeologist at site allocation stage.
Listed Buildings
Listed buildings include a variety of structures reflecting the areas architectural, industrial and cultural heritage. We will look for policies that carefully consider the preservation and preferably enhancement of these assets and crucially, of their setting. In some instances, a full consideration of setting may require close co-operation with adjoining districts where landscape setting may fall within the boundary of these neighbouring authorities. Where relevant, we will seek evidence of this cross-boundary co-operation in the evidence base.
We also encourage a policy that addresses the potential listing over the plan period of as yet unidentified heritage assets that further demonstrate the development and activity of the town and its inhabitants.
Conservation Areas
Each local authority contains a number of designated Conservation Areas. We encourage that the local plan process provides a basis for the continued update and management of Conservation Management Plans, identifying each conservation area’s local identity and distinctiveness. These should identify features that typify and contribute to this special distinctiveness as well as allow for less tangible judgments of character, quality of place and special distinctiveness. The plan will be more robust where it directs future development to take account of the special and distinctive character of Conservation Areas, emphasising that this is a cumulative result of built form, materials, spaces and street patterns, uses and relationships to surrounding features such as the surviving historic buildings and street patterns. We would also welcome provision for any future designation of conservation areas within cities, districts and boroughs as well as specific provision for the landscape setting of different parts of the area.
Registered Parks and Gardens
It may be appropriate to specifically identify Registered Parks and Gardens as protected by any such policy. The policy should anticipate and protect any future designations.
Heritage at Risk
We recommend the inclusion of a policy basis to address Heritage at Risk. We also recommend the creation and management of a local Heritage at Risk register for Grade II listed buildings. Similarly, we welcome positive local solutions for addressing all heritage at risk, whether nationally or locally identified. The National Heritage at Risk Register can be found and searched here by local authority: www.historicengland.org.uk/advice/heritage-at-risk
Non-designated heritage assets
Historic England has published guidance pertaining to Local Listing which you may find helpful: https://historicengland.org.uk/images-books/publications/local-heritage-listing-advice-note-7/ In national policy terms, ‘non-designated heritage assets’ (including those on a local list) are recognised as having a degree of significance meriting consideration in planning decisions. Paragraph 135 of the National Planning Policy Framework states that decisions on applications affecting such assets will require a balanced judgment that has regard to the significance of the asset and any harm or loss: http://planningguidance.planningportal.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/12-conserving-and-enhancing-the-historic-environment/
Government guidance recognises that local lists and local criteria for identifying non-designated heritage assets are a positive thing and can help with decision-making: http://planningguidance.planningportal.gov.uk/blog/guidance/conserving-and-enhancing-the-historic-environment/what-are-non-designated-heritage-assets-and-how-important-are-they/ We would recommend that as a minimum a local authority has established criteria for identifying non-designated heritage assets, and ideally has a local list of assets linked to planning policies in their Local Plan. A good example is Peterborough: http://www2.peterborough.gov.uk/environment/listed_buildings/locally_listed_building s.aspx There are enough appeal cases to indicate that inspectors regard non-designated heritage assets, and something on a local list, as an important material consideration in planning decisions. In fact, where there isn’t a local list, some inspectors have been unable to give as much weight to a non-designated heritage asset. Our website contains a number of appeal cases and if you search for ‘locally listed heritage asset’ or ‘non-designated heritage asset’, you will get relevant ones: http://www.historicengland.org.uk/advice/hpg/planning-cases Robust provision for these heritage assets will increase the soundness of your forthcoming plan.
Design
We strongly encourage provision for the historic environment throughout the plan, not solely within heritage focused policies. Most particularly, we seek a specific requirement for consideration of the historic environment within the design policies of the local plan which should seek to draw on opportunities offered by the historic environment and reflect local character and distinctiveness. This should not stymie contemporary development but should require an appreciation of the significance and character of the historic environment in producing a high standard of design. We would also welcome this in relation to tall buildings policy that may come forward as part of the plan.
Landscape and Streetscape
Landscape
Landscape character assessments, particularly those accommodating major developments, can be deficient in assessing the landscape value relating to scheduled monuments and their settings. The historic environment has an important role to play in understanding the landscape. Many tracks, green lanes, field boundaries and settlement patterns are remnants of past use and provide evidence of how the landscape has evolved over time. The objective of protecting and enhancing the landscape and recognition of its links to cultural heritage can help improve how the historic environment is experienced an enjoyed.
Streetscape
Consideration of streetscape, particularly given the issues of connectivity and traffic management is an area for exploration. For streetscape improvements we would refer you to the Streets for All publications https://historicengland.org.uk/images-books/publications/streets-for-all/. These documents provide updated practical advice for anyone involved in planning and implementing highways and other public realm works in sensitive historic locations. It sets out means to improve public spaces without harming their valued character, including specific recommendations for works to surfaces, street furniture, new equipment, traffic management infrastructure and environmental improvements.
The advice draws on the experience of Historic England's planning teams in the development of highways and public realm schemes. Case studies show where highways works and other public realm schemes have successfully integrated with and enhanced areas of historic or architectural sensitivity. Please also see our advice for highways engineers and designers: https://historicengland.org.uk/advice/caring-for-heritage/streets-for-all/highway-engineers-and-designers/.
Climate Change and Renewable Energy
We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment.
Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiency-historic-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.
Historic Shopfronts
The retention of original/historic or significant shopfronts elements are often integral to the character of these buildings and that of the wider street scene. The Local Plan should highlight the importance of retaining or restoring historic shopfront features. This is both in terms of the positive contribution historic shopfronts make to the character of an area, but also the economic benefit of providing traditional and bespoke shopping units to shop owners. A good example of how historic shopfronts can positively contribute to an area both aesthetically and economically is where Derby City Council teamed up with English Heritage (now Historic England) to help restore an area of Victorian and Edwardian shops, the Strand. The restoration of a number of shops within the area has meant that a previously underused section of the city provides bespoke shopping, now sees a much larger footfall and is considered to be a National success. The council have also seen a ripple effect of surrounding properties being restored.
Enabling Development By definition within the NPPF, enabling development is development that is not otherwise in accordance with adopted policy. We are therefore of the view that a policy on enabling development is not a necessary component of a local plan document. A local plan should adequately set out a positive strategy for the historic environment without the need to include such a policy.
Monitoring
We recommend indicators to measure how successful historic environment policies are. These can include preparation of a local list, completion of conservation area action plans and management plans, reduction in the number of assets that are classified as heritage at risk.
Glossary
Glossaries should include consistent definitions for all heritage assets mentioned in the local plan. These would typically include:
• Listed Buildings
• Scheduled Monuments
• Conservation Areas
• Registered Parks and Gardens
• Registered Battlefields
• Protected Wrecks
• Non-designated heritage assets / Local Heritage Assets / Locally Listed Heritage Assets / Locally Listed Buildings
Mapping
We recommend that designated heritage assets are marked on maps, where appropriate.
Statement of Community Involvement
References should be made to the Historic Buildings and Monuments Commission (“Historic England”), not English Heritage.
Concluding thoughts
In preparation of the forthcoming Southend Local Plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups. Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites. Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

Support

New Local Plan

Representation ID: 4060

Received: 02/04/2019

Respondent: Essex County Council

Representation Summary:

ECC support the inclusion of health and wellbeing throughout this plan and the approach of underpinning this via the sustainable development goals (SDG). The use of SDG’s as a foundation supports a health in all policies approach which is key way to embed health and wellbeing throughout policies, ensuring it is considered and maximises the potential for policy to positively influence health. The inclusion of a section on creating good quality and healthy places is another positive which reinforces SBC’s commitment for this agenda. Health and wellbeing is a cross boundary issue and there is a good ongoing working relationship between SBC and ECC and wish to continue this on matters related to health and wellbeing within the environment so that Essex residents benefit from increased access to healthier places throughout Greater Essex.
Designing in health into both regeneration and new developments has an emerging evidence base with much guidance existing to do this. This includes addressing the design of homes and spaces, encouraging active environments and the application of active design principles from Sport England, addressing neighbourhoods and supporting communities through density and design, active travel where non-motorised transport is prioritised over motorised, increased access to healthier foods with a decrease on access to hot food takeaways, access to education, training and skills and supporting employment and access to NHS and health infrastructure. Much of this is addressed via the Essex Design Guide which includes a theme on health and wellbeing.

Full text:

1. Introduction
Thank you for seeking Essex County Council (ECC) comments on the Southend Local Plan Issues and Options Consultation and the supporting Integrated Sustainability Appraisal (SA). The following is ECC’s response covering matters relevant to ECC as a neighbouring authority. The response does not cover ECC as a landowner and/or prospective developer. A separate response will be made on these matters (if relevant) and that response should be treated in the same way as a response from other developers and/or landholders. ECC supports the preparation of a new Local Plan for Southend-on-Sea Borough Council (SBC) and will assist on strategic and cross-boundary matters under the duty to cooperate, including engagement and co-operation with other organisations for which those issues may have relevance. This will ensure SBC, in consultation with ECC, can plan and provide the necessary cross boundary infrastructure and services; whilst securing necessary funding.
2. ECC Interest In The Issues Consultation
ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy for the existing and future population that lives, works, and visits and invests in Essex. This includes a balance of land uses to create great places for people and businesses; and that the developer funding for the required infrastructure is clear and explicit. As a result, ECC is keen to understand, inform, support and help refine the formulation of the development strategy and policies delivered by LPAs within and adjoining Essex, including the preparation of South Essex statutory Joint Strategic Plan (JSP). Involvement is necessary and beneficial because of ECC’s role as:
a. a key partner of ASELA and Opportunity South Essex Partnership (OSE), promoting economic development, regeneration, infrastructure delivery and new development throughout the County;
b. major provider and commissioner of a wide range of local government services throughout the administrative county (and where potential cross boundary impacts need to be considered);
c. a highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan; Local Education Authority including Early Years and Childcare (EYCC), Special Education Needs & Disabilities, and Post 16 education; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on public health; and adult social care in relation to the securing the right housing mix which takes account of the housing needs of older people and adults with disabilities, all for the administrative county of Essex, and;
d. An infrastructure funding partner, that seeks to ensure that the development allocations proposed are realistic and do not place an unnecessary (or unacceptable) cost burden on the public purse, and specifically ECC’s Capital Programme.
3. Duty To Co-Operate
The duty to cooperate (the Duty) was introduced by the Localism Act in November 2011. The Act inserted a new Section 33A into the Planning and Compulsory Purchase Act 2004. This placed a legal duty on all local authorities and public bodies (defined in regulations) to ‘engage constructively, actively and on an ongoing basis’ to maximise the effectiveness of local and marine plan preparation relating to strategic cross boundary matters, and in particular with County Councils on strategic matters. The National Planning Policy Framework (NPPF, February 2019) provides detail on how strategic planning matters should be addressed in local plans (paragraphs 20 to 27). Local planning authorities are expected to work ‘collaboratively with other bodies to ensure that strategic priorities across local authority boundaries are properly coordinated and clearly reflected in local plans. Specific guidance on how the Duty should be applied is included in the Planning Practice Guidance (the PPG). This makes it clear that the Duty requires a proactive, ongoing and focussed approach to strategic matters. Constructive cooperation must be an integral part of plan preparation and result in clear policy outcomes which can be demonstrated through the examination process. ECC anticipate that SBC will comply with the Duty and actively engage ECC as a key partner on strategic and cross-boundary matters, including engagement and co-operation with other organisations for which those issues may have relevance e.g. Highways England. In accordance with the Duty, ECC will assist SBC and contribute cooperatively to the preparation of a new Southend Local Plan, ECC will contribute / cooperate with SBC with the preparation of the new Local Plan. This consultation is of relevance to ECC as both a neighbouring authority and a partner within ASELA which was formed to meet the legal requirements of the Duty to support the preparation of member authorities Local Plans. There are impacts for ECC, as a neighbouring authority given the extent to which ECC bounds the SBC administrative area, and the level of proposed growth on the delivery of our statutory functions and responsibility as highway authority (and the delivery of the Essex Local Transport Plan); local education authority; Minerals and Waste Planning Authority; Lead Local Flood Authority; Public Health advisor; as well as the ECC role as a major provider and commissioner of a wide range of local government services throughout the county of Essex, many of which are accessed by those who reside in adjoining authorities, such as residents in SBC.
ECC will assist SBC and contribute cooperatively to the preparation of a new Southend Local Plan, particularly within the following broad subject areas,
• ECC assets and services. Where relevant, advice on the current status of assets and services and the likely impact and implications of proposals in the emerging Local Plan for the future operation and delivery of ECC services.
• Evidence base. Assistance with assembly and interpretation of the evidence base for strategic/cross-boundary projects, for example, education provision and transport studies and modelling, and wider work across South Essex as part of the JSP.
• Sub-regional and broader context. Assistance with identification of relevant information and its fit with broader strategic initiatives, and assessments of how emerging proposals for Southend may impact on areas beyond and vice-versa.
• Policy development. Contributions on the relationship of the evidence base with the structure and content of emerging policies and proposals.
• Inter-relationship between Local Plans. Including the emerging South Essex Joint Strategic Plan (JSP) and the Essex Minerals Local Plan 2014 (MLP) and the Essex and Southend-on-Sea Waste Local Plan 2017 (WLP).
ECC Strategic context and strategies
A range of strategies produced solely by ECC or in collaboration with the Essex borough, city and district councils, and the Greater Essex unitary authorities Southend-on-Sea and Thurrock, provide the strategic context for our response to this consultation. These are listed within ECC’s response to Question 1 (evidence) and expanded upon within Question 1.4 (Spatial Strategy). SBC will need to ensure that ECC is actively engaged under the Duty to ensure that the full range of strategic and cross boundary issues are identified and appropriately addressed as part of the evidence base and where relevant, reflected in the new Local Plan itself.
4. ECC Response To Southend Local Plan Issues And Options Regulation 18 Consultation February 2019
ECC’s response follows the format of the consultation document, with comments set against questions of relevance and interest to ECC.
Issue 1: Our Vision & Strategy For The Future – Including The Overall Vision For Southend And Strategy For Where New Development Is Allowed.
Question 1 What would you like Southend to be like in the future?
ECC supports the preparation of SBC’s new Local Plan as we recognise the importance of providing leadership on where development should take place, rather than being led by development pressures. We welcome the references to the need for cross boundary working, the need for Duty and setting the new Local Plan within the framework of the JSP. ECC would expect the new Local Plan would be positively prepared and justified based on up to date robust evidence, including the new technical evidence where necessary to support the emerging spatial strategy and site allocations.
In accordance with the Localism Act 2011, ECC will contribute / cooperate with SBC with the preparation of the new Local Plan. This consultation is of relevance to ECC as both a neighbouring authority and a partner within ASELA which was formed to meet the Duty’s legal requirements to support the preparation of member authorities Local Plans. There are impacts for ECC, as a neighbouring authority given the extent to which ECC bounds the SBC administrative area, and the level of proposed growth on the delivery of our statutory functions and responsibility as highway authority (and the delivery of the Essex Local Transport Plan); local education authority; Minerals and Waste Planning Authority; Lead Local Flood Authority; Public Health advisor; as well as the ECC role as a major provider and commissioner of a wide range of local government services throughout the county of Essex, many of which are accessed by those who reside in adjoining authorities, such as residents in SBC.

This consultation is the first opportunity for ECC to respond to SBC’s Issues and Options and specifically the emerging spatial strategy options, in broad terms, which include the option for a new cross boundary development (most likely in Rochford District) for a new large-scale GC whilst recognising the need for further detailed assessment and evidence post consultation. ECC is particularly interested in the following development areas/proposals:-
• A Southend urban extension on the Southend/ Essex boundary;
• A potential new cross boundary GC in Southend and Essex; and
• Strategic transport corridors including the potential options for an outer bypass / extension to the A127.
It is too early for ECC to provide specific and detailed spatial comments on the cross-boundary impact and opportunities for ECC infrastructure and services arising from this consultation either individually or cumulatively; and taking into account the emerging Local Plans for Rochford District and Castle Point Borough Councils. There is, however, a clear list of strategic cross boundary issues that need to be explored and progressed between SBC and ECC as plan preparation continues and ECC would expect to be engaged by SBC under the Duty to inform the development of SBC’s preferred spatial strategy, supporting site allocations (including evidence), governance and delivery mechanisms/models (including legal and financial) following this round of consultation. This will then enable ECC to identify the individual and cumulative issues and opportunities for our services, especially if the preferred spatial strategy is for ‘shared growth’ in the neighbouring authority area of Rochford DC.
ECC would wish to become much more actively engaged by SBC, than it has been at present, to be able to fully participate from the beginning with the exploration / development of the implications and opportunities, in respect of ECC infrastructure and services. ECC expectations under the Duty are expanded upon under Question 1.4, Issues 10 and 12 and throughout our response.
With reference to technical evidence and 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. The Association of South Essex Local Authorities (ASELA) and the emerging evidence base that has/is being commissioned for the respective ASELA work streams including transport, infrastructure and industrial work streams, as well as the JSP evidence base. For example, it is recommended that SBC take into consideration the wider functional economic market area of South Essex and forthcoming evidence, such as the South Essex Employment Land Availability Assessment and the South Essex Tourism Study.
2. The Essex Recreation and Avoidance Mitigation Strategy (RAMS).
3. A range of relevant strategies produced either solely by ECC or in collaboration with the Essex borough, city and district councils, and the Greater Essex unitary authorities including SBC, is listed below. This has been provided as ECC evidence for context and consideration to inform our ongoing discussions under the Duty on cross boundary infrastructure matters:
Economic Growth
• Essex Economic Commission, January 2017
• ECC Grow on Space Feasibility Study – Executive Summary (Oct 2016) (attached)
• ECC Grow on Space Feasibility Study Final Report (Oct 2016) (attached)

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
• ECC Sustainable Modes of Travel Strategy (August 2016) (SMOTS)
• Essex Cycling Strategy November 2016
• Essex Highways Cycle Action Plans by district (2018)
• ECC’s Passenger Transport Strategy – Getting Around In Essex 2015.
• A127 Statement of Common Ground between the London Borough of Havering; ECC and the South Essex authorities (including TC)
ECC Minerals and Waste Planning
• Essex Minerals Local Plan 2014
• Essex and Southend-on-Sea Waste Local Plan 2017
Please note that these are Statutory Local Development Plans and should be included and referred to within Figure 2 “Hierarchy of strategies and plans related to Southend”.
ECC Flood and Water Management
• ECC Sustainable Drainage Design Guide 2016
ECC Education
• ECC Local and Neighbourhood Planners’ Guide to School Organisation
• 10 Year Plan - Meeting the demand for school places in Essex 2019-2028
• Essex Early Years and Childcare Strategy 2015-2018
ECC Infrastructure Planning
• ECC Developers’ Guide to Infrastructure Contributions (2016)
• Joint Municipal Waste Management Strategy for Essex (2007 - 2032)
Greater Essex
• Essex Design Guide 2018
• Greater Essex Growth & Infrastructure Framework (2016)
• Emerging Essex Coast Recreation Avoidance Strategy (RAMS)
Q1.1 Is there anything missing from the key messages (Figure 8), and why should it be included.
As set out in response to Questions 1 and 1.4, SBC is the Minerals and Waste Planning Authority for Southend Borough, however, whilst there is recognition of the Essex and Southend on Sea Waste Local Plan 2017, there is no reference to or consideration of the requirements in respect of the sustainable use of minerals as a resource, as set out in the NPPF. Please refer to Questions 1.4, 10.4 and 12.5.
Q1.2 Do you disagree with any of the key messages (Figure 8), if so which ones and why?
“Connected and Smart” – In respect of the comments ‘getting around however I chose’ and the “commitment to parking”, it is suggested that these are reconsidered within a wider strategy as a commitment to improving public transport and managing demand private transport with ‘an effective parking strategy” as an alternative approach to better support these goals.
Spatial Strategy
Q 1.4. How should Southend develop in the future in seeking to deliver 18,000 – 24,000 new homes and 10,000 – 12,000 new jobs, please select from one of the options stating your reasoning.
As set out in response to Question 1, ECC support the preparation of new Local Plan and welcome the references and approach to identify cross boundary issues and the need for close partnership working with adjoining local authorities, which includes ECC’s role as an infrastructure and service provider. ECC also supports the approach to progress the new Local Plan within the framework of ASELA, their respective work streams and the preparation of the JSP. If SBC is to meet the housing need in full (in compliance with the NPPF) and, based upon evidence that this is likely to require a new cross boundary GC within Southend and Rochford with additional implications and opportunities on the delivery and provision of ECC infrastructure and services, ECC would want and expect both SBC and RDC to work closely together and with this Council in a close working partnership to help shape and inform the strategic growth proposals and options and continue to do so throughout the delivery phases of work. ECC would expect SBC to seek to maximise their housing delivery within their administrative SBC boundary, however note that the Issues and Options states SBC cannot meet its Objectively Assessed Housing Need in full and that this is a strategic cross boundary planning matter to be explored under the Duty with neighbouring authorities including ECC as a key partner. This Council expect SBC to actively engage ECC as a key partner under the Duty and close partnership working, from the beginning as proposals evolve in the preparation of their new local plan. ECC is a neighbouring authority and the extent to which ECC bounds the SBC administrative area, any level of planned growth is likely to have either an indirect or direct impact on both SBC and ECC as infrastructure and service providers. This is especially so if SBC is to meet housing and employment needs in full. This is particularly the case in respect of ECC’s role as either a neighbouring authority, or potentially as a host authority, if SBC is to meet its housing and employment needs in full through the development of a new cross boundary GC part located within Rochford District (Spatial Strategy Option 3).
Therefore, ECC would want and expect to be a party to any discussions on both the future plan making arrangements; shaping the strategic growth proposals; as well as the governance and delivery models/mechanisms. This is to ensure the full range of issues and options can be considered by all parties and to maximise developer contributions towards meeting the infrastructure and affordable housing costs. ECC would expect to be engaged as an active partner on any relevant evidence being prepared and for this to take into account the policies, strategies and evidence listed in response to Question 1.
ECC welcome the approach to progress the new Local Plan within the framework of ASELA and the JSP and seek clarification on how the Local Plan and will align with the JSP with the same twenty year plan period and the neighbouring Local Plans in Castle Point Borough Council and Rochford District Council areas. ECC will continue to contribute/co-operate with SBC to address cross boundary strategic planning and infrastructure matters, through the wider South Essex arrangements and bodies, including ASELA and the emerging South Essex 2050 Ambition work and preparation of the JSP; the A127 Task Force; and the OSE.
Given the above, ECC would expect SBC to engage ECC on the following potential cross boundary implications and cumulative issues and opportunities arising from a concentration of growth and development near the boundaries of Southend/Essex, in respect of all three spatial strategy options. Specific cross boundary matters include:
a. How SBC is to meet their Objectively Assessed Housing Need in full.
b. Southend urban extension on the Southend / Essex boundary.
c. Potential new cross boundary GC in Southend and Rochford/Essex.
d. Strategic transport corridors including the potential options for an outer bypass / extension to the A127.
e. Cross boundary partnership working with SBC and RDC to lead and shape future growth proposals.
f. Cross boundary partnership working with SBC and RDC in respect of infrastructure planning, provision, funding and delivery mechanisms; to maximise developer contributions towards meeting the infrastructure and affordable housing costs
ECC is also interested in any proposals which may have an impact on strategic transport corridors for Essex residents and businesses connectivity within Greater Essex, to London and beyond; and would also expect to be engaged on these matters under Duty.
Set out below are additional specific comments by ECC services in addition to the cross-boundary matters identified above. Further specific comments are provided as appropriate in response to subsequent consultation questions.
Infrastructure Planning. ECC seek cross boundary engagement, in the exploration of a new GC, in respect of infrastructure provision, including but not limited to schools, childcare, highways, waste and recycling, employment and skills. This should include exploration of delivery mechanisms, legal and financial contributions (including S106 and S278 agreements and CIL), having regard to ECC Developers’ Guide to Infrastructure Contributions (2016) (ECC’s Developers’ Guide), and the expectation that each new home planned for should be contributing at least £35,000 towards the required infrastructure needed. This is necessary to maximise developer contributions towards meeting infrastructure and affordable housing costs.
Infrastructure is critical to support sustainable growth and it will be critical to make sure that the right infrastructure is in the right place at the right time, to accommodate the new jobs and homes needed in the future. Any new settlement should be at a scale to secure the necessary infrastructure. The new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. Given the importance of infrastructure provision and funding (all funding streams) and delivery evidence is considered as part of the assessment of all spatial options. This is to ensure the preferred strategy is viable, deliverable and sound. The approach in developing a potential Garden Community should be based upon the principles set out in the Government’s Garden Community’s prospectus, the Town and Country Planning Association’s Garden City Principles as well as the International Garden Cities Foundation and their application in our own supporting design guides, including the Essex Design Guide which sets out Guidance on Garden Communities, Planning for Health and an Ageing Population etc.
Housing Provision. ECC note and support SBC using the Government’s standard methodology for housing to meet its need in full. ECC welcome the references to provision of Specialist Housing, including Independent Living for Older People and Adults with Disabilities within the Local Plan.
Economic Growth. It is recommended that consideration is given to the wider economic functional economic market area of South Essex and SELEP strategies, when considering spatial options and allocations, including connectivity and transport; recognising the wider supply chain and employment impacts on surrounding areas. ECC recommend consideration is given to ECC economic evidence including “Grow-on Space”; as well as the wider ASELA “Industrial Strategy” work stream requirements and JSP evidence which are likely to have a spatial dimension.
Transport and Highways. It is recommended that SBC as highway authority undertakes and shares the required highway and transportation assessments, mitigation and provision arising from the spatial strategy and new developments, including impacts on both the local and wider highway and transportation network. SBC will need to continue to work with ECC through the Duty and ASELA to address cross boundary matters and identify required transport infrastructure, ECC would expect to be actively engaged as the host Highway Authority if any developments / improvements are identified within the Essex Highway network. This will include the approach to highway modelling to maintain the strategic transport network in Southend, South Essex and Greater Essex.
It is recommended that SBC make reference to the A127 Task Force which has representation from all South Essex authorities, including SBC. The A127 Task Force will oversee much of the public affairs interaction between the Councils and Government to ensure that the route is seen as strategic and as a potential candidate for re-trunking in order to bring about the long-term improvement required for an area of South Essex with over 600,000 residents. The planning and design work for any improvement of this scale will of necessity require a short-term, medium and long-term phasing. In the short-term ECC has important plans for certain junctions on the route including a significant upgrade of the A127/A130 Fair glen interchange which will become increasingly important for traffic routing from mid and north Essex to south Essex including most likely accessing the A13 and the Lower Thames Crossing. ECC will be looking to plan for the future improvements to the A13 to build up a cohesive plan with both Southend and Thurrock. Whilst the A13 and A127 are the main focal points ECC would be looking to work collaboratively with SBC and other councils in the area on the impact on the A130 and connections to mid Essex; as well as on appropriate transport solutions for urban extensions or new developments on the edge of Southend or extending into the ECC area.
ECC acknowledge the need to work with and for SBC to actively engage with ECC and other relevant stakeholders to deliver these joint transport priorities, and ECC will aim to ensure that emerging plans and strategies remain consistent.
ECC recommend that consideration is given to the potential Crossrail 2 eastern branch. The concept for Crossrail 2 to be extended into south Essex is at an early stage however it may influence where future development is located.
Sustainable Transport. It is recommended that greater emphasis is placed on promoting integrated sustainable transport; and encourage the use of sustainable travel plans; suitable linkages for pedestrians and cyclists, and passenger transport options in new developments (particularly if a new GC is progressed) and the connectivity between housing and employment areas and to ensure an integrated transport package of solutions are developed particularly in respect of its relationship and connectivity to South Essex, Essex and London. This includes the potential for the authorities to collectively consider extending the South Essex Active Travel (SEAT) initiative, beyond the 3 year government funded programme; which paved the way for sustainable transport initiatives for Local Plan proposals to build on.
It is also recommended that reference is made to the opportunity for close working on new evidence for the Local Plan, neighbouring Local Plans and the JSP; to collectively improve connectivity between conurbations and employment areas in South Essex with a network of transit routes as a real alternative to private vehicles to facilitate a modal shift. This could be by either conventional bus or bus based rapid transit; to complement rail networks in the area and include further exploration of the principles and delivery of a South Essex Rapid Transport (SERT) system, with all interested partners, as previously considered by ECC, SBC and Thurrock Council highway authorities to provide a bus based rapid transport system for South Essex.
Minerals and Waste Planning. SBC is the local Minerals and Waste Planning Authority with the responsibility to make local plans for and to determine minerals and waste related developments. However, the Local Plan is silent on these matters and ECC consider it necessary for SBC to provide a holistic approach to meet the growth requirements, which fully considers and integrates the minerals and waste infrastructure and capacity requirements. This includes sustainable development of the strategic growth options; to include consideration of prior mineral extraction and the provision of waste management within employment areas, as well as safeguarding mineral resources and waste management infrastructure. This is considered necessary to comply with the NPPF (chapter 17), the National Planning Policy Statement for Waste (2015) and the adopted Essex and Southend on Sea Waste Local Plan (2017). ECC, as the statutory minerals and waste planning authority for the two tier area, would expect any proposals within Essex (i.e. outside of SBC administrative area) to comply with the Essex Minerals Local Plan (2014) (MLP) and the Essex and Southend on Sea Waste Local Plan (2017) which form part of the Statutory Local Development Plan and a material consideration for that area.
Flood and Water Management. ECC welcomes the inclusion of reference to flooding and flood risk management. ECC would expect to be engaged on any development on the Southend/Essex boundary, to ensure that any development does not increase flood risk within either area. Any site located on the Essex boundary or discharging into Essex should comply with the ECC Sustainable Drainage Design Guide 2016 (ECC SuDs Guidance) and be subject to consultation with the ECC as Lead Local Flood Authority (LLFA). Any development outside of SBC administrative area should wholly comply with ECC’s SuDs guidance and the guidance relating to surface water flood risk outlined within the relevant district or borough local plan.
Education. ECC notes that SBC is the local education authority and will need to make the necessary education provision arising from any new developments. SBC will need to work with ECC to identify potential cross boundary matters for Primary and Secondary School provision arising from any new developments on the Southend/Essex boundary, especially if Option 3 is selected, which will require cross boundary working. In respect of Special Education Needs and Disabilities (SEND), pupils within Southend Borough take up Essex places and ECC would expect SBC to refer to and plan enough SEND provision to meet any increasing demand in the future.
Early Years and Childcare. ECC seek reference to EYCC provision within the new Local Plan.
Post 16 Education and Skills. ECC seek reference to post 16 education and support the ongoing close working arrangements between Further Education (FE) colleges across South Essex (including SBC) to provide and deliver cohesive curriculums. It is envisaged there will be an increase in cross boundary movements of post 16 student travel with the rationalisation of curriculum delivery across the South Essex colleges. It is recommended that consideration should be made to support both FE Establishments to construct a sustainable student travel strategy. ECC would expect to be engaged as part of the ongoing close working to develop opportunities for achieving local labour and a skills legacy; and that reference is made to ECC’s engagement with the Essex Planning Officers’ Association on the relationship between post 16 education and skills with local plans and planning applications.
Customer Services. ECC seek reference to libraries and their role in the provision of public services and that ECC would expect to be engaged by SBC on this matter in respect of any new developments on the Southend/Essex boundary which will require close cross boundary working.
Public Health. ECC welcome the inclusion “health and wellbeing” throughout the Issues and Option Plan and as the approach to underpin sustainable development. ECC consider Health and Well-being to be a cross boundary issue and would expect to be engaged as part of the ongoing close working so that Essex residents benefit from increased access to healthier places throughout Greater Essex.
Environment. ECC welcome the inclusion of “green infrastructure” including environment as a cross boundary matter and will continue to work with SBC
In respect of Ecology, ECC seek clarification on the preparation of a Habitat Regulations Assessment or Appropriate Assessment and recommend that ecology is reconsidered to include reference to residential growth impacts on European habitats with reference to the Essex RAMS.
Sustainability Appraisal. ECC welcome the Interim Integrated Impact Assessment, which provides a good high-level appraisal at this early stage of plan preparation, however seek reference to minerals planning related developments and the Essex Minerals Local Plan. In moving forward, it will be necessary to identify more detailed alternatives / options as evidence emerges. In progressing the new Local Plan, it is recommended that the SA factors in and is aligned with the SA of the JSP, specifically the strategic growth locations and in terms of any cross-boundary options and trans-boundary / cumulative effects, as that Plan (and SA) progresses.
Section 2 – Planning For Growth & Change
Issue 2: Housing – Including New Housing, Conversions, Affordable Housing, Self-Build.
Q2. How best do you think we should provide for our future housing needs?
Please see ECC’s response to Questions 1; 1.4 and 2 to 2.7; in addition to the following.
ECC note that this is the first stage in the preparation of the new Local Plan set within the framework of ASELA and the preparation of the JSP, and the approach to explore potential Spatial Strategies including the identification of broad strategic development options through the Local Plan. ECC supports this approach in principle and the ongoing close working with Southend, the South Essex authorities including ECC to ensure strategic infrastructure planning across administrative borders. In addition, ECC seeks clarification on how the new Southend Local Plan will be progressed in alignment with the JSP. ECC acknowledges the sensitive nature of the Borough and the need to balance growth with retaining local character. In developing the new Local Plan and preferred strategy, SBC (with Partners) will need to be satisfied that it has identified its preferred spatial strategy, which includes significant Green Belt release, based on a range of proportionate evidence. In so doing, SBC will need to demonstrate that it has considered all reasonable locations for future growth against the relevant criteria and demonstrate that the most appropriate sites have been identified for allocation.
ECC notes the South East Essex Growth Location Assessment provides an initial assessment of potential broad locations for growth and recognise that further detailed studies are to be undertaken, including land outside SBC’s administrative area. ECC would expect to be an active party any the assessments of sites/broad locations in on the border/within Essex for their suitability and infrastructure requirements. Any studies and proposals would need to be in accordance with ECC policies, strategies and standards for that area (see Question 1) as statutory infrastructure and service provide within the two tier area. There may be further sites with potential implications on the strategic road and rail networks which could affect the connectivity of Essex residents and businesses to London and beyond; and would expect SBC to consider these matters with ECC through close working under the Duty and in the preparation of the JSP.
ECC consider infrastructure to be critical to support sustainable growth and it will be critical to make sure that the right infrastructure is in the right place at the right time, to accommodate the new jobs and homes needed in the future. Any new settlement should be at a scale to secure the necessary infrastructure. The new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. Given the importance of infrastructure provision and funding (all funding streams) and delivery evidence is considered as part of the assessment of all spatial options. This is to ensure the preferred strategy is viable, deliverable and sound. The approach in developing a potential new GC should be based upon the principles set out in the Government’s Garden Community’s prospectus, the Town and Country Planning Association’s Garden City Principles as well as the International Garden Cities Foundation and their application in our own supporting design guides, including the Essex Design Guide which sets out Guidance on Garden Communities, Planning for Health and an Ageing Population.
Q 2.4 Secure a proportion of affordable/ special needs housing on development sites. Do you think we should retain the current policy, seek a higher proportion of affordable housing or provide for a different policy approach/ solution?
ECC welcome the inclusion of housing provision for older people and people with specialist needs and would anticipate that SBC would seek to identify inclusive and sustainable locations, based upon technical evidence, including for example access to services and public transport.
Q 2.6 In terms of the layout and design of housing should we go beyond mandatory building regulations to ensure new homes are highly accessible and adaptable? In what circumstances should this be applied? Should a proportion of new housing on major development sites (10 homes or more) be built to accommodate wheelchair user needs? If so what proportion should this be?
ECC recommend consideration is given to the Essex Design Guide 2018, in respect of place making and the type and quality of new communities. This is particularly relevant to any potential new GC being considered under Question 1.4 (Spatial Strategy Option 3) and 12.4 below.
Issue 3: Securing A Thriving Local Economy – Including Job Numbers, Business Premises And Employment Sites.
Q3. How best do you think we can retain and promote employment in Southend?
Economic Growth. ECC welcome the ongoing cooperation with SBC to support the development of policy-level interventions with regard to economic infrastructure and ensuring that it aligns and supports the opportunities as identified in the Essex 2050 vision as well as the development of the JSP. ECC also recommend that the Local Plan seeks to ensure that policy responses also align with the SELEP Strategic Economic Statement, the forthcoming SELEP Local Industrial Strategy and the forthcoming South Essex Productivity Strategy.
Furthermore, given the high proportion of small businesses in Southend Borough, growth of these businesses will require additional Grow-On Space, which ECC’s “Grow on Space” study (2016) found to be in short supply across Essex, and this may impact on the wider south Essex Functional Economic Market Area; including the South Essex Grow-On Space Study; and the South Essex Land Availability Assessment.
Skills and Training. ECC welcome the references to the Economic Development Needs Assessment (EDNA) and the recommendation to support and investment for education, skills and training; and support SBC’s ongoing close working with ECC and partners to develop opportunities for achieving local labour and a skills legacy. Future economic opportunities can be stimulated by ensuring new developments require a form of skills and employability training plans. This would enable a range of mitigation activities, in both the construction and end-use phases of development, to increase employment prospects and skills levels. This could include work placement opportunities, apprenticeship opportunities and school or college outreach. ECC is working with the two-tier authorities across Essex through the Essex Planning Officers’ Association (EPOA) on the relationship between post 16 education and skills with local plans and planning applications, to embed Employment and Skills Plans to secure planning obligations and contributions to support increased skills levels, increased employment, employability and skills levels for residents, mitigating the impact of new developments.
Highways and Transportation. ECC welcome the reference to and recognition of the need for strong infrastructure connections and continued adequate investment into road and digital infrastructure and the public transport network is regarded as essential for supporting economic development and employment activities across South Essex. However, recommend that greater emphasis and consideration is placed on the role and importance of integrated sustainable transport solutions, including for example passenger transport improvements to access the airport and other commercial sites. Please refer to Questions 1, 1.4, 3, 4.4, 5 and 6 – 6.5.
Q3.1 Should we focus new jobs to the town centre, London Southend Airport and associated Business Park and the northern Southend corridor, including Temple Farm and Stock Road?
Please see ECC’s response to Questions 1 and 1.4; this is considered be cross-boundary matters for further engagement with ECC under the Duty.
Q3.2 Should we concentrate on promoting digital, cultural and creative industries; healthcare technology; advanced manufacturing and engineering; and tourism sectors?
Please see ECC response to Question 3
Q3.6 How can we best meet the needs of Small and Medium Sized Enterprises and the need for move-on accommodation as small firms grow?
Please see ECC response to Question 3.
Issue 4: Promoting Southend As A Major Resort – Including Visitor Attractions And Enhancing Tourism
Q4.4 Improve accessibility to the central seafront areas for all users. How best do you think this could be achieved?
Highways and Transportation As set out above in response to Questions 1.4 and 3 above, ECC recommend greater emphasis is placed on the role and importance of integrated sustainable transport and exploring alternative transport solutions such as passenger transport to promote intra and inter urban trips; park and ride schemes to improve access to the sea front and other tourist centres; and access by rail.
Q4.5 Seek further enhanced links between the central seafront and town centre to improve services and facilities. How best do you think this could be achieved?
Please see ECC response to Q4.4
Issue 5: Providing For Vibrant And Attractive Town Centres – Including Shops, Leisure Facilities And The Future Of Our High Streets
Q5. How best can we ensure that our town centres are successful, vibrant and attractive places in the face of changing retail demands?
Highways and Transportation. Please refer to ECC’s Highway and Transportation response to Question 4 and 4.4 above and Issue 6 below (Sustainable Transport). The approach is noted, however recommend that consideration is given to the need to make proper allowance for retaining and improving Passenger Transport access as part of the package of solutions to reduce the need for cars in the town centre.
Issue 6: Providing For A Sustainable Transport System – Including Transport, Access And Parking
Q6. How best do you think we can improve the transport system serving Southend?
Please see ECC’s Highway and Transportation; and Sustainable Transport response to Questions 1, 1.4, 3, 4.4, and 5 which apply to Issue 6 and questions.
ECC has the following additional comments. ECC acknowledge the need to work with and for SBC to actively engage with ECC and other relevant stakeholders to deliver these joint transport priorities, and ECC will aim to ensure that emerging plans and strategies remain consistent. Specific reference should be made to the ongoing joint transport projects (see Question 1 and Question1.4) and including A127 Task Force, significant upgrade of the A127/A130 Fair glen interchange; the A127 and A13 Route Management Strategies; A127 Air Quality Management Plan (between the Fortune of War and Rayleigh Weir). Whilst the A13 and A127 are the main focal points ECC would be looking to work collaboratively with SBC and other councils in the area on the impact on the A130 and connections to mid Essex, as well as on appropriate transport solutions for urban extensions or new developments within Southend or on the Southend/Essex boundary, or extending Essex.
ECC agree that significant improvements are needed to the transport network, however emphasise that sustainable modes of travel should be prioritised, for both the existing and any new developments. ECC would welcome the opportunity to work collaboratively with SBC and other councils in the area on the impact of any urban extensions or new developments on the edge of Southend or extending into the administrative area of ECC, including evaluation of the relative benefits and dis-benefits of any transport mitigation measures, which could include an outer bypass. ECC would expect this evaluation to consider the relative merits of all modes of transport, with an aim to minimise additional private vehicle movements.
ECC has reviewed the Sustainable Transport Topic Paper – and seek collaborative working with SBC in respect of the following aspects
• Transport Projects “An Access, Parking and Transport Strategy” and a reviewing of the Southend Local Transport Plan”.
• ECC note the distance to train stations for the Eastwood and Belfairs areas (and the area around Southend Hospital) and wish to work with SBC to retain and improve sustainable linkages from Rayleigh to Southend through these areas.
• ECC note the aspirations to explore potential of the River Thames as a transport resource, and this will be of particular interest for the Canvey area.
• ECC wish to explore the potential for Bus Rapid Transport for any large-scale new developments e.g. in Rochford, linking to central Southend / employment / leisure areas / stations / airport (see Question 6.3 and reference to SERT).
• ECC can confirm that Tourist traffic has a significant impact on the Essex strategic road network (mainly the A127) and would welcome engagement in respect of options to mitigate this.
Q6.1 Seek to make further improvements to the A127. What do you think these should be?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
ECC has commenced a refresh of the 2014 “A127 A Corridor for Growth – an Economic Plan” (the A127 Route Management Strategy) jointly prepared with SBC. ECC are working with the South Essex authorities (including SBC) and the London Borough of Havering on this, through the A127 Task Force.
In respect of Air Quality, there are issues along the A127 within Essex (between the Fortune of War and Rayleigh Weir) which need to be addressed in the short term, and ECC is working with the respective Borough and District Authorities.
Q6.2 What do you think should be done to create improved access if a new settlement is built north of Fossets Farm, Garon Park and Bournes Green Chase (see figure 9)?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
Q6.3 How should we provide for enhanced sustainable transport provision in the town in the form of rail, bus, park and ride, cycling and pedestrian facilities? What do you think these should be and what should be prioritised?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
It is recommended that greater emphasis is placed on promoting integrated sustainable transport; and encourage the use of sustainable travel plans; excellent suitable linkages for pedestrians and cyclists, and passenger transport options in new developments (both housing and employment) to existing settlements both within the Borough and cross boundary(particularly if a new GC is progressed); and connectivity between housing and employment areas to ensure an integrated transport package of solutions are developed particularly in respect of its relationship and connectivity to South Essex, Essex and London. This should be developed in partnership, especially with neighbouring authorities.
This includes the potential for the authorities to collectively consider extending the South Essex Active Travel (SEAT) initiative, beyond the 3 year government funded programme; which paved the way for sustainable transport initiatives for Local Plan proposals to build on.
In respect of passenger emphasis, it is recommended that greater emphasis and importance is placed on bus services and to improving the access, quality, reliability and scale of the bus network to help mitigate the well advised impacts of traffic growth including increased bus priority measures. These should be explored further in partnership working with local operators, developers and neighbouring authorities, including ECC.
ECC recommend reference and consideration is given to the opportunity for close working on new evidence for the Local Plan, neighbouring Local Plans and the JSP; to collectively improve connectivity between conurbations and employment areas in South Essex with a network of transit routes as a real alternative to private vehicles to facilitate a modal shift. This could be by either conventional bus or bus based rapid transit; to complement rail networks in the area and include further exploration of the principles and delivery of a SERT system, including bus rapid transport (see Q 6 and 6.1), with all interested partners, as previously considered by ECC, SBC and Thurrock Council highway authorities to provide a bus based rapid transport system for South Essex.
ECC suggest consideration is given to ECC’s Sustainable Modes of Travel Strategy which enables the ECC and partners to co-ordinate the provision of services and infrastructure, to enable accessibility to places of employment and education for all.
Q6.4 Provide for park and ride facilities to serve Southend. Where do you think these should be and in what format?
See ECC response to Question 6.3. ECC wish to be engaged in these options.
Q6.5 How do you think technologies such as the internet, electric and driverless cars will affect how we travel over the next 20 years?
Please see ECC’s Highway and Transportation and Sustainable Transport responses to Questions 1, 1.4, 3, 4.4 and 5 which apply to Issue 6 and questions.
Section 3 – Creating Good Quality And Healthy Places
Issue 7: Facilitating Good Design, Healthy Living And Built Heritage – Including Design Issues, Amenity, Heritage And Conservation
Q7. How best do we ensure healthy communities and development is appropriate and of a quality design, whilst ensuring we enhance our built heritage assets?
Public Health. ECC support the inclusion of health and wellbeing throughout this plan and the approach of underpinning this via the sustainable development goals (SDG). The use of SDG’s as a foundation supports a health in all policies approach which is key way to embed health and wellbeing throughout policies, ensuring it is considered and maximises the potential for policy to positively influence health. The inclusion of a section on creating good quality and healthy places is another positive which reinforces SBC’s commitment for this agenda. Health and wellbeing is a cross boundary issue and there is a good ongoing working relationship between SBC and ECC and wish to continue this on matters related to health and wellbeing within the environment so that Essex residents benefit from increased access to healthier places throughout Greater Essex.
Health and wellbeing is a key part of the NPPF 2018 with an aim of spatial planning being to support creating healthy places. Designing in health into both regeneration and new developments has an emerging evidence base with much guidance existing to do this. This includes addressing the design of homes and spaces, encouraging active environments and the application of active design principles from Sport England, addressing neighbourhoods and supporting communities through density and design, active travel where non-motorised transport is prioritised over motorised, increased access to healthier foods with a decrease on access to hot food takeaways, access to education, training and skills and supporting employment and access to NHS and health infrastructure. Much of this is addressed via the Essex Design Guide which includes a theme on health and wellbeing.
ECC recommend the use of a Health Impact Assessment (HIA) tool. This would then enable the local authority and NHS to assess against whether places are supporting health and wellbeing. This could be through the application of health impact assessments (as supported by the Essex Planning Officer’s Association and advised within the MHCLG guidance on plan-making) at an agreed local level. In addition, the assessment of active environments could be made via the Active Design Principles checklist. An HIA is designed to highlight the positives of development and maximise these whilst ensuring that any unintended impacts are either removed or mitigated against. The review of an HIA allows for recommendations for mitigation to be made.
If SBC (and RDC) progress the option of a new cross-border GC, ECC would expect to work in collaboration with health and wellbeing partners including Southend Public Health and NHS partners from the Mid-Essex and South Sustainability Transformation Partnership (STP) to ensure that impacts to health and wellbeing service provision are considered. This would also include access to NHS infrastructure led by the STP estates team. This collective approach would support the wider health and wellbeing system to ensure sustainable delivery of services to meet need. ECC can advise that if this option is progressed that early engagement with health partners occurs to ensure that health and wellbeing is ‘designed’ in to master-planning for this development so to allow for local evidence based need and supporting strategies and policies to be included (as above).
Q7.3 Should we seek to limit the proliferation of new fast food outlets close to locations where children congregate such as schools, community centres and playgrounds or where there is an overconcentration of existing premises? Are there other ways of tackling this issue?
ECC support the restriction of new fast food takeaways as an option within the plan and suggest this be addressed through either avoiding over-proliferation, over clustering and addressing this with a targeted approach to areas of deprivation due to the links between obesity and deprivation and also (so to support addressing childhood obesity), limiting access around schools via either a restriction zone or limiting time these premises can trade (i.e. immediately after school or lunchtimes). Further detail on healthier food environments can be found via the role of health and wellbeing in plan-making guidance from MHCLG.
Historic Environment. ECC suggest that the heading and content under “Natural and Built Heritage” is expanded to the “Natural, Historic and Built Environment” to ensure that the new Local Plan specifically acknowledges and refer to archaeology (in addition to the reference to scheduled monuments).
Issue 8: Providing Community Services And Infrastructure – Including Utility, Health, Education, Sports And Leisure Facilities And Digital Infrastructure
Q8. How best can we provide for our future community needs to secure a sustained high quality of life and well-being having regard to future growth?
Please see ECC’s response to questions Q1 and 1.4, in addition to the following:
Customer Services. ECC would expect SBC to include the provision of Library services within any future community needs and for these to be secured as part of any future growth. It is likely the new developments will affect the current service ECC offer, the stock held at the sites and the partner services they currently host. In respect of a potential new cross boundary GC this will increase demand for the current ECC Library service, the registration service (which is hosted in libraries to register births and deaths) and blue badge assessments. This is considered to be a cross boundary matter and ECC would expect SBC to engage RDC on this option under the Duty, including developer contributions. In respect of Library provision, ECC has consulted on, and are currently analysing the feedback on the draft future library services strategy that propose the service will be delivered, according to need, through a range of physical and online services:
• enhanced eLibrary services to make it easier for customers to access library materials anywhere, anytime from their own devices;
• a network of libraries across the county, run by Essex County Council alone or in partnership with other groups or organisations;
• outreach to bring some library services and activities out to communities according to need, such as running a children’s story time in a village hall;
• mobile libraries, which currently serve 217 stops around the county but could see more stops added depending on need; and
• Home Library Service, where volunteers bring books and other loan items to people in their own homes.
Q8.1 Are there any specific issues regarding educational provision that you consider need to be addressed with respect to new development?
Please see ECC’s response to Q1 and 1.4; in addition to the following specific comments.
Education. ECC note that SBC is the LEA for Southend and have no comments at this early stage in the preparation of the Local Plan other than ECC would expect SBC to determine how they mitigate their own impacts. ECC wish to be engaged with the Local Plan as it progresses, with the identification of growth locations, for consideration of cross boundary impacts on Essex school provision under the Duty.
Early Years and Childcare. The Local Plan recognises that educational facilities are almost to capacity and also makes recommendations around further education however there is no reference to EYCC provision. To ensure ECC provides a sufficient number of childcare places, a clear understanding of cross border developments will be needed to plan accordingly. ECC consider this to be a cross boundary matter and wish to be engaged by SBC under the Duty, in the identification of the new EYCC requirements arising from new housing and employment growth locations on the Southend/Essex border, as the Local Plan progresses.
Special Education Needs and Disabilities. ECC note that there is no reference to SEND provision; whilst there are pupils within Southend that take up Essex places. ECC consider this to be a cross boundary matter and would expect SBC to plan for sufficient special needs provision through the new Local Plan to meet increasing demand.
Post 16 Education. Please see ECC response to question 1.4. ECC consider this to be a cross boundary matter and would expect SBC to refer to and make provision for Post 16 Education with the new Local Plan; and ECC wish to be engaged in the process.
Q8.2 How do you consider that health issues should be addressed in the Local Plan? How can new development encourage healthy lifestyles?
Please see ECC’s Public Health comments in response to Questions 1, 1.4 and 7 and 7.3.
Q8.4 As part of planning approvals should we ensure that all developments deliver quality broadband infrastructure and connectivity?
ECC would anticipate that SBC would require the provision of digital infrastructure in accordance with NPPF. ECC Superfast Essex, work with Essex borough, city and district authorities and require provision of digital and broadband infrastructure policies within new Local Plans, to support new developments.
Issue 9: Enhancing Our Natural Environment – Including Green Space, Habitats And Wildlife, Landscape
Q9. How best do we protect and enhance our environment in the face of increasing growth and development pressures?
LLFA. ECC would anticipate that the natural environment should be maintained and where possible improved as part of any new development. ECC anticipate that flood risk management would have a key role in providing green and blue infrastructure corridors throughout Southend, in particular, linking areas of habitat across the boundaries of adjacent administrative areas. ECC notes SBC is the LLFA for Southend with their own policies addressing the management of surface water as part of new developments; ECC suggest that these are as closely aligned as possible with ECC, to help provide consistency for developers working within/across both LLFA areas. ECC therefore seek wording to acknowledge the importance of SuDS provision in developing the natural environment.
Ecology. ECC seek clarification and reference to Habitat Regulations Assessments and/or Appropriate Assessment within the preparation of the new Local Plan. ECC consider this to be of relevance given the area of the new Local Plan lies within the Zone of Influence for the Essex RAMS being prepared collaboratively by Essex Authorities (including SBC). ECC anticipate there will be a need for an Appropriate Assessment, and that the new Local Plan and any housing allocations to be developed with proportionate financial contribution towards delivery of mitigation measures at the coast in perpetuity to avoid recreational disturbance, to comply with the Essex RAMS policy to meet the legal requirements of the Habitats Regulations and in compliance with the NPPF
Q9.1 Work with other stakeholders, funding bodies and developers to identify opportunities to promote and enhance the natural environment, and incorporate net gains for biodiversity in new development?
Please see ECC’s response to Questions 1 and 1.4, including relevant strategies and evidence, including but not limited to ECC SuDS (2016); the Essex Design Guide (2018) and in particular the emerging Essex RAMS. ECC support a positive approach to the role and provision of Green and Blue Infrastructure; and suggest this includes links to the neighbouring authority areas and respective studies including the South Essex Green Infrastructure Strategy and the emerging Green Essex Strategy, being prepared by the Essex Green Infrastructure Partnership
Q9.2 Seek to enhance the borough’s network of green infrastructure using developer contributions for the management of green and open spaces and introduction of pocket parks?
Overall ECC welcome the approach and suggest consideration is given to the Green Essex Strategy. ECC welcome the opportunity to engage with SBC in this project, especially in if there is a new cross boundary GC.
Q9.3 In liaison with adjoining local authorities seek to provide new country park and open parkland facilities (including from developer contributions) as part of strategic development sites, including where they help mitigate pressure on some of the more sensitive coastal habitats?
Please see ECC’s response to Questions 1, 1.4, 9, 9.3 and 12 below (regarding ECC’s Developers Guide to Contributions). ECC anticipate that SBC would explore this further with RDC and ECC as a cross boundary matter under the Duty.
Issue 10: Planning For Climate Change – Including Energy Efficiency, Flooding And Coastal Change, Agricultural Land
Q10. How best do we plan for the future impacts of climate change?
Please see ECC response to Questions 1 and 1.4; as well as the comments below which apply to Issue 10 Questions 10.1 – 10.6.
LLFA. ECC is the neighbouring LLFA and would expect SBC to ensure that any development on the Southend/Essex boundary to not increase the flood risk within either authority area. ECC consider this to be a cross boundary matter and to be explored with ECC under the Duty. ECC would expect that any site located on the boundary of Essex or discharging into Essex should comply with Essex SuDS Guide and ECC should be consulted on any such developments as the neighbouring LLFA. In respect of any development within the Essex LLFA area (i.e. outside the administrative boundary of SBC), these should wholly comply with the Essex SuDs Guide and the guidance relating to surface water flood risk outlined within the relevant district or borough’s local plans. In respect of the Blue /Green Infrastructure Topic Paper, supporting the Issues and Options Consultation, ECC is concerned that there is no consideration of the numerous ordinary watercourses that cross Essex. While there are too many to be individually addressed, ECC would expect the report to acknowledge that the quality and volume of the water in these features will have an impact on more recognised downstream features. ECC consider the references focusing solely on flood risk within the Central Seafront Area, to be too specific as all areas of new development should be managed to ensure that, as a minimum requirement, flooding doesn’t get worse. Where possible, ECC recommend that betterment is sought whenever possible, in particular in areas of existing flood risk. This approach is critical for any cross-border development or development that takes place within ECC’s administrative boundary. ECC would encourage SBC to take a similar approach within their own administrative area to help provide consistency for developers working in both areas.
Q10.2 Require mitigation and adaptation measures to deal with the increase in average temperatures and greater rainfall, including tree planting and urban greening?
See ECC response to Question 10.2 above.
Q10.3 Support renewable and low carbon energy schemes, including photovoltaic (PV) panels, biomass plants and electric vehicle charging points?
Please see ECC’s Highways and Transportation, and sustainable Transport comments in response to Q1, 1.4, 3, 4.4, 5 and Issue 6. In particular consideration should be given to improving passenger and public transport as part of encouraging a modal shift in transport.
Q10.5 Should we balance the need to retain the best and most versatile agricultural land for food security against future needs for housing and local services?
Minerals and Waste Planning. As stated in response to Question 1 and 1.4, SBC is the MWPA, for the borough however the Issues and Options is largely silent on mineral planning issues and there is no explanation for excluding these statutory obligations, from consideration.
Section 5 – Deliverability
Issue 12: Ensuring That The New Local Plan Is Delivered – Including Priorities For Delivery, Infrastructure Delivery, Community Infrastructure Levy
Q12. How best do you think the Local Plan can be effectively delivered in the face of limited resources?
Please see ECC response to Questions 1, 1.4, and Issue 6. ECC consider this to be a cross boundary matter and would expect SBC to engage with ECC in respect of any developments on the Southend/Essex border and/or in Essex under the Duty.
Infrastructure provision and funding. ECC anticipate that the new Local Plan would include clear policies for the full provision, enhancement and funding of infrastructure arising from planned development. Mechanisms would include planning obligations, the use of a Community Infrastructure Levy (CIL), and the ability to negotiate specific contractual obligations for major strategic sites, and any new cross boundary Garden Settlement would be in accordance with the Garden City principles defined by the Town and Country Planning Associations Garden City Principles (or subsequent updated guidance) and the wider definition of sustainable development outlined in the NPPF. This is to ensure the delivery of sustainable development is in accordance with the NPPF. ECC welcomes the recognition that infrastructure is critical to support sustainable growth and to make sure SBC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future and the acknowledgement of ECC’s role in the provision of local and strategic infrastructure. ECC wishes to be proactively engaged with the assessment of the spatial options and site allocations, given the importance of infrastructure provision and funding, which will vary depending upon the spatial strategy and site allocations, with their respective individual and cumulative infrastructure requirements; impacts and opportunities on the delivery of ECC service areas.
Q12.1 Continue to work in partnership with the private, public and voluntary sector plus neighbouring authorities to secure funding for key infrastructure projects?
Please refer to ECC response to Questions 1, 1.4 and Q12, ECC consider this to be a cross boundary matter and would expect SBC to engage with ECC under the Duty. ECC agrees that Infrastructure is critical to support sustainable growth and it will be essential to ensure SBC has the right infrastructure, at the right time, to accommodate the new jobs and homes needed in the future. ECC welcome the acknowledgement of ECC’s role as a neighbouring authority working in partnership with SBC, ASELA and partners in the provision of Local and Strategic infrastructure.
ECC wish to explore and understand the potential implications of the nature and scale of developments on financial contributions, given the pooling of contributions under the CIL Regulations and hence potential viability and delivery issues which will be vary for each of the spatial options.
As stated in response to Questions 1.4 and 10, the new Local Plan should emphasise the need to provide infrastructure (secured through developer funding) as part of any new development proposals, to ensure the new plan is both viable and deliverable. The necessary infrastructure funding (including all funding streams) and delivery evidence needs to be fully considered as part of the assessment of the spatial strategy to ensure the preferred strategy is viable, deliverable and sound.
Q12.2 Set out priorities for project delivery. What do think these priorities should be and how should any phasing be applied?
See ECC response to Questions 1, 1.4 and 12.
Q12.3 Increase the Community Infrastructure Levy tariffs to fund future projects?
See ECC response to Question 1, 1.4 and 12.
Q12.4 Through Garden Communities key principles ensure land value capture and long-term stewardship for the benefit of the community, to provide and coordinate the necessary infrastructure?
Please refer to ECC response to Questions 1, 1.4, 2 and 12- 12.3. ECC would expect GC principles to be applied, as set out in response to Question1 and 1.4. ECC consider this to be a cross boundary matter and would expect to be actively engaged by SBC as a key partner under the Duty through close working from the beginning as the proposals evolve in the preparation of the new local plan.
Q12.5 Do you have any other issues/ comments?
Sustainability Appraisal. See ECC response to Questions 1 and 1.4.
ECC seek reference to and consideration of the Sustainable Use of Minerals Resources (NPPF Chapter 17) and the Essex Minerals Local Plan 2014.
Subject to the above, ECC welcome the general approach however suggest the Integrated Impact Assessment (IIA) will need to identify more detailed alternatives / options once the Plan’s evidence base emerges. This will crucially need to factor in realistic site options within the Plan area. An approach to including the findings of the JSP Sustainability Appraisal, specifically strategic growth locations, will need to be factored into the narrative of the IIA.
With respect to Table 1 IIA Objectives and the framework for the appraisal of the Plan, it is suggested more could be included at the next stage regarding how impacts will be identified and how these translate to the individual site assessments.
South East Essex Growth Location Assessment
ECC wish to be engaged by SBC and partners in the next stage of this study having regard to ECC’s response to the Issues and Options consultation.