Stambridge Mills page 56: This site is said by RDC to be deliverable in the next 3 years. It is located within flood zone 2 and 3 of the River Roach and must be subject to sequential testing as per PPS25. It has been acquired by Inner London Group who specialise in local authority partnerships, healthcare, key worker and other homes provision. However, there are no proposals for the site via a planning application or a site allocation.

Suitability - The Environment Agency claim in their objection at to the Submission Core Strategy, that the site is in a flood zone 3. PPS25 expects the sequential test to be carried out. The test is that it must be demonstrated that there are no reasonably available sites in areas of lower flood risk probability that would be appropriate to the type of development proposed. Stambridge Mills fails as a consequence since the site allocations document includes many other site development options that are sequentially preferable.

The Environment Agency object in the Core Strategy Examination that the site cannot fulfill the Exception Test in their submissions on the Core Strategy. Rochford Dc maintain that it is a site that is exceptionally required. However, in PPS25 policy terms it should not be necessary to move to the exception test as part of the assessment since there are more acceptable sites elsewhere which are sequentially preferable. If it were necessary to move to the exception test it would be only appropriate to accept development in Flood Zone 3 if there was a clear sustainability benefit taking into account the need to avoid social and economic blight. Stambridge Mills has a severe visual impact but that is not relevant. The aim of reducing the impact on the Green Belt is also irrelevant in the context of the PPS25 sequential approach. Stambridge Mills is separated from the built up area of Rochford by open agricultural fields designated as Green Belt. There are no sustainability reasons for encouraging the development of high density housing in this location. The site cannot integrate with the residential area and most journey's would be by car. Stambridge Mills is separated from the nearby main employment area to the south by the water course. PPS3 and the preference for brownfield land is not cart blanche for all brownfield sites to be brought forward irrespective of the environmental harm and this is noted at paragraph 38 and reinforced at paragraph 41 of PPS3. Stambridge Mills should not be included as a development option and reference of it should be removed.