Development Management Development Plan (DPD)

Support

Representation ID: 997

Received: 20/10/2010

Respondent: Savills

Generally support thrust of preferred option, as the alternative option is limited.

Comment

Representation ID: 998

Received: 20/10/2010

Respondent: Savills

Issues of water and energy efficiency should have been considered by the Council.

Comment

Representation ID: 999

Received: 20/10/2010

Respondent: Savills

Omission - It is not clear how the findings of TE2100 and CFMP2008 have been reflected both in DMDPD and CAAP, at this section states that "the level of actual risk and the areas actually remaining at risk are therefore likely to be much lower than indicated by these maps, subject to the structural integrity of the defences being maintained."
The submission drafts of the DMDPD and CAAP should include a plan delineating the flood risk areas that have been agreed with the Environment Agency.
Both Plan Documents should set out any constraints on the form of development and / or appropriate uses with the flood risk area, setting out clearly any differences within different areas of risk.

Comment

Representation ID: 1000

Received: 20/10/2010

Respondent: Savills

The commentary states that "any development proposals within areas of flood risk will require a detailed flood risk assessment, appropriate mitigation measures and agreement with the Environment Agency"
This approach and the preferred option, rather than the alternative option, need to be ratified by the Environment Agency prior to the Submission Drafts of the CAAP and DMDPD being published, given the potential conflict with national planning policy on flood risk (PPS 25 and related Practice Guidance).
This requirement to provide an FRA should be integrated into the approach (it currently is not) and form part of the overarching design policies (DM1 and Design and Townscape DPD).

Comment

Representation ID: 1001

Received: 20/10/2010

Respondent: Savills

Given the exceptional circumstances in Southend, we generally support the suggested option, rather than relying on the alternative option and sequential and exceptions tests in PPS25.
However this suggested option and the approach to considering flood risk must have the full support of the Environment Agency, before the submission Draft of the DMDPD and CAAP are published, so that discussion with the EA on a site by site basis during the life of the Plan are considered in this context.

Support

Representation ID: 1002

Received: 20/10/2010

Respondent: Savills

There are some omissions and suggested changes to the suggested option:

Support

Representation ID: 1003

Received: 20/10/2010

Respondent: Savills

There are some omissions and suggested changes to the suggested option:

Comment

Representation ID: 1004

Received: 20/10/2010

Respondent: Savills

­ No reference to "Green Grid" in suggested approach
­ Green Grid and Green Corridor should be identified in policy text and on plan
­ No reference to "Seaside Character Zones" in suggested approach
­ Seaside Character Zones should be identified in policy text and on plan
Design Briefs and Codes may not be appropriate for "all major development sites"
For clarity and monitoring purposes, a list of the key development sites for which briefs / codes are to be prepared should be appended to the Submission versions of both the DMDPOD and CAAP
All public realm works should also include consideration of flood risk (point 3)
The detailed proposal to enhance Cliff Gardens may be more appropriately included in the CAAP
Redraft as policy / proposal in CAAP

Comment

Representation ID: 1005

Received: 20/10/2010

Respondent: Savills

Microclimate

Object

Representation ID: 1006

Received: 20/10/2010

Respondent: Savills

This section of the plan may be premature, given the awaited character analysis
Options for each of the Character Areas should have been available for consideration under regulation 25
The draft policies should be written to minimise duplication with policies in the CAAP and other AAPs.
There is currently no policy basis for achieving the proposed long term outcomes for each of the Character Areas (Table 1 and Appendix 6)
The further modified boundaries of the Seaside Character Zones (following the completion of the Borough Wide Character Study in 2010) should be identified in policy text and on plan in both the Submission Draft of the DMDPD and CAAP
Table 1 - Seafront Character Zones is not currently cross references to Appendix 6 and the two elements of the Plan are particularly difficult to understand.