Plaistow and Ifold Parish Council seeks to act in the capacity of critical friend to ensure that the Local Plan is fit for purposes and expertly drafted to avoid confusion in its future application.

It is the Council’s view that the following matter(s) should be addressed to ensure the Plan is sound i.e., justified, effective and consistent with national policy.

In general terms (strategic matters) the Plan, as worded, risks confusion and unsoundness in terms of its use of language for ‘landscape’ and how it applies ‘landscape’.

• The Plan should adhere to the European Landscape Convention definition of Landscape. This is adhered to by Landscape professionals and Protected Landscapes, and is required in terms of plan-making (https://www.gov.uk/government/publications/european-landscape-convention-guidelines-for-managing-landscapes).

• This definition is even more important because policy and supporting text appears to switch between terms such as ‘rural setting’, ‘countryside’ and ‘natural landscape’. Whilst countryside is defined in planning terms, the others are not, and their use within the Plan is inconsistent. The foundation of the Plan and its understanding of the different areas is ‘landscape character’ and so it is this which the policies are seeking to conserve and enhance. The landscape evidence upon which the Plan relies (the Capacity Study 2019) is all about landscape character, which is how landscape is understood in planning terms. Therefore, the Plan should refer to “conserving and enhancing landscape character”, or “ensuring no adverse effects upon landscape character”. This will ensure the Plan links directly back to its evidence base and avoids confusing terminology in the policies themselves.

• The relationship between landscape character and other areas of policymaking is not yet joined-up.

• The Plan’s evidence for landscape uses the Landscape Character Assessment method. This is the accepted way to understand landscape for planning (Policy and DM). However, the Capacity Study (2019), does not cover the whole District. Yet assumptions about landscape appear to be made in areas where there is no evidence. For example, in the Sustainability Appraisal’s (SA) assessment of the site at Crouchlands Farm, there is no landscape evidence to support the finding that the landscape would be benefitted by a development. Indeed, the opposite is considered to be the case. This calls into question other aspects of the SA, which might also be founded upon an incomplete landscape evidence-base.

Given the Plan’s aspiration to maintain the landscape quality, particularly in the North of the Plan Area, this quality is found through landscape character assessment, which is the evidence-base. In order to meet the Plan’s own ambition, the policies, and supporting text, must be consistent and refer to landscape character too, which, in the North of the Plan Area happens to be rural.