Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
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Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy CS1: Central Seafront Policy Area Development Prinicples
Representation ID: 2868
Received: 14/12/2016
Respondent: Natural England
Natural England support the statement in point 1.i.i.ii "safeguard, and where appropriate, enhance the biodiversity of the foreshore and respect the European designations". We welcome the recognition of the environmental importance of the foreshore as reflected in point 1.a. "an assessment of the scale, character, location and impact of the proposal on existing facilities and environmental designations, including protected green space". We also support point 3c c. regarding the "integration of the open spaces of the seafront and foreshore with the 'green grid' to create a series of linked, functional green spaces" in order to relieve recreational pressure on designated sites.
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Object
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy CS1: Central Seafront Policy Area Development Prinicples
Representation ID: 2869
Received: 14/12/2016
Respondent: Natural England
Legally compliant? Not specified
Sound? No
However within Policy CS1 there are the following matters which we raise as unsound:
1. We note that the Policy states "restricting development south of the sea wall" which we view does not provide sufficient protection for the international, European and national designated sites in accordance with paragraph 118 of the NPPF.
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Comment
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy CS1: Central Seafront Policy Area Development Prinicples
Representation ID: 2870
Received: 14/12/2016
Respondent: Natural England
Point 3.d. describes use of creative lighting and we refer you to our previous advice relating to Policy CS6 (2011) that new lighting should be arranged as to avoid direct illumination of the foreshore or excessive glare when viewed from the foreshore. This is to avoid potential impact on designated areas and the species they contain, in accordance with paragraph 118 of the NPPF. In addition, light pollution can have negative impacts on local amenity and nature conservation (especially bats and invertebrates).
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Object
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy CS1: Central Seafront Policy Area Development Prinicples
Representation ID: 2871
Received: 14/12/2016
Respondent: Natural England
Legally compliant? Not specified
Sound? Not specified
Point 4i. Opportunity Site (CS1.1): Southend Pier. As the pier crosses the Benfleet and Southend Marshes designated site, we would have concerns that future proposals to alter the structure (such as undertaking work to deck timbers), or widening the pier (as recently considered in order to facilitate a transport system) would have the potential to impact on the designated site.
NOTE: Point 4i. Opportunity Site (CS1.1): Southend Pier. We would advise that the Plan incorporate measures to reduce potential impacts on the important high-tide roost of wintering turnstone Arenaria interpres at the northeast corner of the pier-head. For example a recent new building close to this slipway was carefully designed to minimise overshadowing the slipway and was given a 'turnstone-friendly' rough-surfaced curved roof.
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Support
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy CS2: Nature Conservation and Biodiversity
Representation ID: 2872
Received: 14/12/2016
Respondent: Natural England
Natural England welcomes the inclusion of our previous advice from 26 January 2016 within point 1.a. of the Policy to "ensure that all development proposals within the Central Seafront Area are accompanied by a Habitats Regulations Assessment and associated documentation to ensure there will be no adverse effect on the European and International foreshore designations (SPA and Ramsar) either alone or in combination with other plans or projects".
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Support
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy CS2: Nature Conservation and Biodiversity
Representation ID: 2873
Received: 14/12/2016
Respondent: Natural England
We also welcome the aspiration in point 1.e. of the Policy to link open space within a Southend 'green grid' (see CS1) and we support point 1.f to satisfy the need to make visitors and residents aware of the significance of the SSSIs through interpretation at a high-quality visitor facility.
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Object
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy CS2: Nature Conservation and Biodiversity
Representation ID: 2874
Received: 14/12/2016
Respondent: Natural England
Legally compliant? Not specified
Sound? No
It is our view that Policy CS2 as presented however is not consistent with National Policy:
1. It does not clearly set out criteria to firstly avoid, then mitigate and, as a last resort compensate for adverse impacts on biodiversity. The Southend on Sea Development Management Document (July 2015) also does not refer to the avoidance-mitigation-compensation hierarchy (see paragraph 118 of the NPPF).
2. It does not make a clear distinction between the protected sites hierarchy of international, national and local sites. A clear distinction should be made between the protected sites hierarchy of international, national and local sites in order to ensure consistency with paragraph 113 of the NPPF. There are descriptions of 'designated sites', 'international and European designated sites'. Nationally designated sites are not described at all.
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Support
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy DS4: Flood Risk Management and Sustainable Drainage
Representation ID: 2875
Received: 14/12/2016
Respondent: Natural England
Natural England welcomes this policy requiring Flood Risk Assessments and the widespread adoption of SuDS techniques.
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Object
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy DS4: Flood Risk Management and Sustainable Drainage
Representation ID: 2876
Received: 14/12/2016
Respondent: Natural England
Legally compliant? Not specified
Sound? Yes
We note that climate change appears in Policy DS4 as well as in other places throughout the document; the main focus of attention relates to Flood Risk management. Whilst we recognise the intentions of paragraph 97 with regard mitigation of climate change by tree planting, we would advise that the SCAAP include a separate Policy on climate change, to cover both mitigation and adaptation, in accordance with paragraphs 94 and 156 of the NPPF. This Policy could focus on measures to assist biodiversity to adapt, and include green infrastructure measures to assist people to adapt (principally to extreme high temperature events, extreme high/low rainfall events, and for coastal areas, sea level rise and extreme storm surge events). For example, using tree planting to moderate heat island effects and SuDS to address flooding. For more information, see PPG on Climate Change.
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
Object
Southend Central Area Action Plan (SCAAP) - Revised Proposed Submission 2016
Policy CS3: The Waterfront
Representation ID: 2877
Received: 14/12/2016
Respondent: Natural England
Legally compliant? Not specified
Sound? No
Natural England draws your attention to our advice on 17 October 2011: "any new or enhanced marine facilities as referred to in point 1.b may potentially need to be restricted to seasonal usage if [there will be no unacceptable impact upon navigation, biodiversity, flood risk or the special character and designations]". The seasonal restriction relates to avoidance of potential impacts on the interest features of Benfleet and Southend Marshes Special Protection Area / Ramsar in accordance with paragraph 118 of the NPPF.
Thank you for your consultation on the above which was received by Natural England on 03 November 2016.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
Context
We responded on 11 July 2011 on the Draft Southend Central Area Action Plan and associated HRA Screening Report (our ref 27040) and supplied comments online to the Central Area Action Plan - Proposed Submission on 17 October 2011 (our ref 33069). We also responded on 26 January 2016 on the Preferred Approach Option 2015 (our ref 176229).
While you have provided a Representation Form, we are providing comments below in the same format as that form in order to expedite this response:
