Policy DM2 - Low Carbon Development and Efficient Use of Resources

We generally support the ambitions of the Council set out in policy DM2. Given the pressures on water resources in the region, we particularly support the measures to increase water efficiency in new development and promote retrofitting in existing development. It is also pleasing that the multiple benefits of urban greening have been acknowledged in the supporting text such as absorbing rainfall, filtering pollution and promoting biodiversity. Given the highly urbanised nature of the Borough, it will be necessary for developers to consider innovative measures to achieve this such as green/ brown roofs and walls.

We are however disappointed that the part of the policy addressing waste efficiency in the Issues and Options consultation has been removed (point 5 of I&O policy DM4). The Development Management DPD provides an opportunity to promote the consideration of waste as early as possible during the development design phase to ensure that minimal volumes of waste arise during the construction of the development, and the demolition at the end of its life. Developers should also be encouraged to consider how they will incorporate recycled/recovered materials into the building programme, including the use of secondary and recycled aggregates, and re-use of any on-site demolition waste. It is unclear why this part of the policy has been removed. We note that the Sustainability Appraisal has also raised this concern.

Full representations can be seen within the letter submitted by email and post.

There are considered to be tensions between the wording of Policy DM2 and the introductory text, in particular paragraph 2.14.

In light of changes to the definitions contained within the Code for Sustainable Homes, the importance of ensuring the DMDPD does not simply repeat the requirements of other legislation.

I would like to advise you that the Council do not wish to object to the document proposed for submission.

The Council in particular welcomes the development principles identified for Character Zone 1: Two Tree Island, Leigh Marshes and Belton Hills in Table 1. The Council are of the view that the maintenance of the Green Belt in this location is very important and consistent with national policy set out in PPG2.

The Council also welcomes the approach to employment distribution set out in Policy DM10 and Table 6. The direction of jobs towards easily accessible locations including Southend Central Area, London Southend Airport and existing employment areas along the A127 Corridor is important for residents of Castle Point, as Southend-on-Sea is a key employment location in the Thames Gateway South Essex sub-region.

Further to the comments above, I would like to offer some suggestions in respect of this document that may prove useful to you in moving forward:

a) It is agreed that water efficiency should be a requirement for new development in south Essex. The Code for Sustainable Homes includes water efficiency as a mandatory requirement at each level. I would therefore query why policy DM2 part 2 requires water efficiency at part (iii) when Code for Sustainable Homes requirements have already been set out in part (ii).

b) It is agreed that an appropriate split between the different tenures of affordable housing should be sought. However, it may be prudent, given the recent changes in the definition of affordable housing, that part 2(ii) of policy DM7 is amended to provide the flexibility to enable Affordable Rented units to be sought also.

c) It is queried as to why external storage for bicycles is not sought in respect of non-self contained accommodation in Policy Table 5. It is considered that student and nurses' accommodation is most often provided within close proximity of the study/work place and other services and facilities, and therefore the provision of cycle storage will promote more sustainable transport movements by these occupants.

I trust these comments are of assistance to you in moving forward with the Development Management DPD. Should any queries in respect of these representations arise through the examination process, we would be happy to deal with them through written representations. Officers will however attend the examination, if required, in order to support any consideration of the sub-regional context.

We generally support the ambitions of the Council set out in policy DM2. Given the pressures on water resources in the region, we particularly support the measures to increase water efficiency in new development and promote retrofitting in existing development. It is also pleasing that the multiple benefits of urban greening have been acknowledged in the supporting text such as absorbing rainfall, filtering pollution and promoting biodiversity. Given the highly urbanised nature of the Borough, it will be necessary for developers to consider innovative measures to achieve this such as green/ brown roofs and walls.

We are however disappointed that the part of the policy addressing waste efficiency in the Issues and Options consultation has been removed (point 5 of I&O policy DM4). The Development Management DPD provides an opportunity to promote the consideration of waste as early as possible during the development design phase to ensure that minimal volumes of waste arise during the construction of the development, and the demolition at the end of its life. Developers should also be encouraged to consider how they will incorporate recycled/recovered materials into the building programme, including the use of secondary and recycled aggregates, and re-use of any on-site demolition waste. It is unclear why this part of the policy has been removed. We note that the Sustainability Appraisal has also raised this concern.

We generally support the ambitions of the Council set out in policy DM2. Given the pressures on water resources in the region, we particularly support the measures to increase water efficiency in new development and promote retrofitting in existing development. It is also pleasing that the multiple benefits of urban greening have been acknowledged in the supporting text such as absorbing rainfall, filtering pollution and promoting biodiversity. Given the highly urbanised nature of the Borough, it will be necessary for developers to consider innovative measures to achieve this such as green/ brown roofs and walls.

We are however disappointed that the part of the policy addressing waste efficiency in the Issues and Options consultation has been removed (point 5 of I&O policy DM4). The Development Management DPD provides an opportunity to promote the consideration of waste as early as possible during the development design phase to ensure that minimal volumes of waste arise during the construction of the development, and the demolition at the end of its life. Developers should also be encouraged to consider how they will incorporate recycled/recovered materials into the building programme, including the use of secondary and recycled aggregates, and re-use of any on-site demolition waste. It is unclear why this part of the policy has been removed. We note that the Sustainability Appraisal has also raised this concern.

Full representations can be seen within the letter submitted by email and post.

There are considered to be tensions between the wording of Policy DM2 and the introductory text, in particular paragraph 2.14.

In light of changes to the definitions contained within the Code for Sustainable Homes, the importance of ensuring the DMDPD does not simply repeat the requirements of other legislation.