New Local Plan

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.
Issues and Options
Natural England has considered the issues relevant to our remit and the natural environment. Where possible we have answered the questions put forward, however our general comments are as follows:
South Essex Joint Local Plan
Natural England acknowledges Southend-on-Sea’s position within the wider ‘South Essex Joint Local Plan’. It is understood that this is progressing, however still in the early stages. This strategic approach to development across Essex is supported by Natural England and we await consultation on these matters as appropriate in the future.
Section 1 – Vision & Spatial Strategy
Natural England supports the overall aims of the Southend Local Plan. In the context of the natural environment, the Local Plan should seek to protect and enhance, endorsed through robust and strongly worded policies at both a strategic and local level. This is reflected within policies 20, 170, 171 and 174 of the National Planning Policy Framework (NPPF) 2019, which advocates that the planning system should seek to deliver ‘environmental gains’ and a move from a ‘net loss of biodiversity to achieving net gains for nature’.
It is understood that three options have been put forward for the spatial strategy of development within the Borough to provide 18,000-24,000 new residential dwellings. These options differ in terms of their impacts, for example ‘Option 1’ seeks to deliver all development within existing built up areas; it is recognised that towns and larger villages offer sustainable locations for development and limit the use of greenfield or ‘Best Most Versatile’ (BMV) land, however within existing built up areas there is also likely to be a limit to the capacity for additional on-site green infrastructure. Therefore whilst Natural England does not have specific comment on these options, when determining appropriate ‘allocated sites’ for development, the impacts, both positive and negative will need to be weighed to ensure the Local Plan is achieving the aim of enhancing the natural environment and is not resulting in significant harm. Natural England advises that the Plan’s vision and emerging development strategy should address impacts and opportunities for the natural environment with particular emphasis on designated environmental assets.
We recommend that the Plan Vision should also include a commitment to protect and enhance other aspects of the natural environment, in accordance with the NPPF, including geodiversity, local landscape and Best and Most Versatile land. Additionally, the Vision should also recognise the need for plan policies to contribute to mitigation and adaptation to climate change.
Section 2 – Planning for growth and change 4 – Promoting Southend as a major resort
4.1 – Allocate and promote new sites for additional tourism/leisure developments in the central seafront area or elsewhere in the Borough. Where do you think these should be focussed?
Natural England understands that Southend-on-Sea is a tourist destination, with the coast providing an important role in Southend’s local economy, supported through access to and use of the coast (and the wider natural environment). Whilst there may be a need as a tourist destination for development of facilities etc. to ensure there is capacity, Natural England is concerned that in some locations, increased recreational pressure may have significant impacts to both national and internationally designated sites. Such impacts include habitat trampling, bird disturbance, noisy/disruptive water activities etc. The Benfleet and Southend Marshes Special Protection Area (SPA), Ramsar and the Thames Estuary Special Protection Area (SPA), Ramsar are examples of designated sites within the area of the Southend Local Plan which are vulnerable to this type of disturbance impact.
Wider development of the coast should be subject to further consideration in the context of the Habitats Regulations (both alone and in-combination) and through the Local Plan’s accompanying Sustainability Appraisal. Whilst Natural England understands the importance of tourism, there should be careful consideration of the location of such development, reflected within the emerging Local Plan policies and accompanying assessments (i.e. HRA and SA).
4.4 – Improve accessibility to the central seafront areas for all users. How best do you think this could be achieved?
Natural England would take this opportunity to highlight the ongoing work on the England Coast Path. Natural England is charged with implementing the England Cost Path, which is due for completion as a whole project by 2020. However, the formal opening of the route is likely to be later due to unavoidable delays in the legal process. This new record-breaking long-distance trail will eventually allow people to walk around the whole English coast. Work on the Southend sections of the Path is currently underway and our team of coastal path advisers, and Natural England would seek to achieve Policy support for the Coast Path in Southend-on-Sea Borough Council’s Local Plan. The two stretches under development within the Borough are Tilbury to Southend and Southend to Wallasea Island. Publication is expected later in 2019, allowing everyone a chance to comment on the preferred route (developed in full consultation with many parties). The ultimate decision on the routes lies with the Secretary of State.
The England Coast Path is possible because of the Marine and Coastal Access Act 2009. As well as a long-distance walking route, there may be areas of ‘spreading room’ beside the route where people can explore, relax and admire the view. The act also means that for the first time, where existing footpaths erode into the sea, a replacement route can be quickly put in place – securing people’s right to walk around the coast forever. The new path will avoid certain areas such as private houses and gardens, major ports and in some locations, areas that are important for sensitive species. Designing the route as part of the England Coast Path will bring more support for local services like shops, hotels and pubs through increased visitor spending where additional visits are made, and therefore aligns well with the Council’s proposed approach to tourism. In this Year of Green Action, it also connects people with nature and has major benefits in improving health and well-being. The Coast Path may potentially present challenges in certain locations, where access to the coast may cause recreational disturbance to some of the interest features of sites designated for their nature conservation interest. The Path will be subject to the rigorous tests of the Habitats Regulations, and will therefore seek to achieve consistency in its approach to safeguarding sensitive features of these sites as any other plan or project. We would be pleased to discuss this with you in more detail should you wish.
6 – Providing for a sustainable transport system
Natural England acknowledges that with increased development there will be greater infrastructure requirements across the Borough. We would take this opportunity to comment on potential air quality issues as a result of increased vehicular movements.
This also extends to any changes or alterations to Southend City Airport which has the potential for significant impacts on the natural environment. It is noted that air quality and noise issues have already been identified as a potential concern and on this basis Natural England would anticipate further assessment through the Local Plan’s accompanying HRA and SA. Natural England is aware that increasing flight numbers over Holehaven Creek Site of Special Scientific Interest (SSSI) have been noted as causing disturbance to Thames Estuary and Marshes SPA features (such as non-breeding black tailed godwits). In terms of air quality, consideration should be given to these issues in the context of both aircraft movements and increased road traffic and there are a number of designated sites of international and national importance within scoping distance for the HRA and SA. For reference, the zone of influence for both road traffic and aircrafts may differ and may not be restricted to proximal designated sites.
Section 3 – Creating good quality and healthy places 9 – Enhancing our Natural Environment
9 – How best do we protect and enhance our environment in the face of increasing growth and development pressures?
The Local Plan will approach development within the district at a strategic level, whereby wider consideration can be made in terms of the necessary local plan requirements for the natural environment across the plan area as a whole. This strategic level provides greater opportunity to consider the issues at hand, how these interlink and how they can be addressed moving forwards. Natural England would expect that an assessment of the appropriateness of sites would be undertaken, as mentioned previously in this letter. The plan should clearly set out the criteria for selecting and allocating sites, particularly focussing on those with the least environmental value, for instance, avoiding designated sites and landscapes, BMV land, areas at risk of flooding/coastal erosion.
The following designated sites and environmental considerations fall within the area of the Southend Local Plan:
• Benfleet and Southend Marshes SSSI, SPA, Ramsar
• Foulness SSSI, SPA, Ramsar
• Outer Thames Estuary SPA
• Essex Estuaries SAC
• Leigh NNR
• Areas of ancient woodland (such as near Leigh-on-Sea) – the plan area is directly adjacent Great Wood & Dodds Grove SSSI
Please note that this is not a comprehensive list, but indicates some of the key sites that require further consideration in the local plan context. A full assessment of all relevant sites and the potential impacts of the Local Plan should be made through the appropriate mechanisms.
We suggest that key issues / threats should be considered at this early stage in the plan, particularly changes in water quality / resources, air quality and increased recreational pressure.
Natural England is also aware that Southend-on-Sea BC is committed to the developing Essex Coast Recreational Disturbance Avoidance and Mitigation Strategy which looks to mitigate for recreational impacts ‘in-combination’ with other plans and projects across the Essex coastal designated sites. The entirety of the Local Plan area will fall within the Zone of Influence for this strategic solution, therefore all residential development coming forward will need to be considered in the context of this issue. The level of required mitigation will be dependent on the scale of individual developments, however Natural England’s guidance on this matter is set out in our letter to the participating Local Planning Authorities dated 16 August 2018 (reference 244199).
It would be expected that this commitment would be reiterated through a relevant planning policy and Natural England would suggest this be through an overarching requirement, capturing both allocated development and any windfall that will otherwise not have a site specific policy requirement. The mitigation for these impacts at present includes a combination of on-site measures within development boundaries, and off-site measures at the coastal designated sites. In highly developed areas where there may be a limit to on-site capacity, such as on site green infrastructure, consideration should be given to whether there is scope to provide this strategically, to ensure sufficient mitigation is being sought. Natural England would be happy to discuss this further when the spatial strategy approach has been determined.
9.2 – 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?
Green infrastructure is a key consideration in terms of the natural environment, but also in ensuring that the Borough’s designated sites are ecologically robust. Green Infrastructure provides multiple functions and Natural England would be supportive of a strategic approach to green infrastructure, ensuring good ecological connectivity and high quality networks across the plan area.
Natural England would welcome a dedicated green infrastructure policy requirement through the Local Plan with consideration of what existing green infrastructure availability, where is this located in the wider context and how can this be improved to the benefit of both the natural environment, connectivity within the borough through improved footpaths and cycleway, the use of Sustainable Drainage (SUDS) etc. Consideration of the green infrastructure (GI) network should include designated sites including SSSIs, SPAs, SACs and Ramsar sites, local wildlife sites and Habitats and Species of Principle Importance, in accordance with Paragraph 109 of the National Planning Policy Framework (NPPF). The plan should take a strategic approach to the protection and enhancement of the natural environment and aim for a net gain for biodiversity considering opportunities for enhancement and improving connectivity. The plan should seek to contribute to the objectives and targets of the local Biodiversity Action Plan, Rights of Way Improvement Plans and Green Infrastructure Strategy.
This is also consistent with the approach of ‘Net Gain’ which has been further established through the recent iterations of the NPPF. Natural England would encourage the council to consider the current position on net gain with an aim of incorporating this into policy, particularly where considering large scale site specific allocations.
9.3 – 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 most sensitive coastal habitats?
Natural England would welcome and support the consideration and development of a strategic approach to GI. Our comments on GI and the Essex RAMS are as above, however we would reiterate the importance of GI as a buffer and form of mitigation.
9.4 – Any other issues/comments
Natural England expects the plan to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The Local Plan should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The Local Plan should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.
10 – Planning for Climate Change
Natural England would promote the consideration of the Essex and South Suffolk Shoreline Management Plan (2010) (SMP) within the Local Plan with the aim of integrating, supporting and implementing the policies of the SMP within the relevant Epochs.
This concludes Natural England’s comments based on the information available at this stage. We look forward to receiving further consultation on the draft plan and supporting HRA & SA/SEA as appropriate. Please note that Natural England may expand upon these comments or raise issues not referenced within this response when the chosen ‘vision’ of the plan and locations of potential allocated sites have been identified.