Background

In accordance with their representations to the Core Strategy, Countryside Properties are supportive of the proposals for the provision of additional employment land to the west of Rayleigh, but we consider that such provision should be made to the north of London Road as part of a comprehensive mixed-use development, not to the south of London Road (or at Michelins Farm).

Representations

In our view, the most appropriate location for new employment development west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. In our original submissions to the Core Strategy, we advanced a number of arguments to support this position, including:

* It is inherently more sustainable in principle to provide for an integrated mixed-use scheme, rather than segregated residential and commercial areas;
* The viability of providing the new employment land is increased as part of a mixed-use scheme, since the costs of infrastructure (including roads, drainage, and utilities) is shared;
* There is more than sufficient land north of London Road to deliver a mixed-use scheme - there is less certainty that the scale of development required could be successfully provided south of London Road;
* To be attractive to new business, a high quality business park of sufficient size will be required - there is more land north of London Road to achieve this;
* There are advantages in terms of public transport accessibility/viability in serving a business location alongside a residential location (greater patronage and two-way passenger flows);
* It is difficult to see how the Green Belt boundary south of London Road could successfully be changed to allow for a large scale employment area, without either creating a ribbon of development along London Road, or an isolated incursion not linked to the existing community;
* Countryside Properties has particular experience in successfully delivering mixed-use schemes, including the creation of modern, flexible business space.

In the light of the above, we do not support the potential employment sites E13, E14, E15, or E16, all of which lie to the south of London Road.

In addition to the general observations above, we note that in relation to the particular sites E13-E16 the following additional points:

* All of these options utilise to some extent of other land already in commercial use. This raises two significant questions: Is the land proposed genuinely available, given the existing uses, and is the land genuinely additional employment land, or simply a replacement of existing jobs?
On the first question, it appears to us that each of these options is based upon land in multiple ownership, and where there are existing businesses/tenancies which together may make the land impossible to bring forward in a comprehensive way.

On the second question, although the existing commercial uses may not be allocated for businesses purposes as such, there are long-standing commercial uses on the site that are an existing source of employment. All four options E13-E16 appear to be premised upon the loss of the existing commercial uses, and therefore any net increase in allocated employment land would need to take in to account the extent of existing land lost.

* Notwithstanding the above, none of the options presented are of sufficient scale to provide for the extent of employment land required under the Core Strategy. The four options vary between a minimum of 2.65 ha and a maximum of 5 ha. The Core Strategy identified a need for 2 ha for office use and 6 ha for the relocation of Rawreth Lane Industrial Estate, making a minimum of 8 ha. In our view (and notwithstanding our concerns regarding practicality), relocating Rawreth Industrial Estate would require more than 6ha - the existing estate is already over-crowded, as the extent of on-street parking demonstrates, allows no scope for businesses to expand, and the existing layout does not provide the quality of environment that the Council would rightly expect (and which new businesses would demand) from a new commercial park.

In our view, around 10 ha is a more realistic land-take for replacing Rawreth Lane Industrial Estate, making around 12 ha of land in total to be found west of Rayleigh to support the employment proposals of the Core Strategy. This scale of development cannot be found south of London Road (or at Michelins Farm).

E17 is the only option put forward to the north of London Road, and clearly therefore on the basis of the above, we feel this option warrants further consideration, albeit in isolation it would still not be large enough to accommodate the full employment land requirement (if Rawreth Lane Industrial Estate is to be redeveloped).

There is however potential to increase the size of site E17, whether by extension to the north (whilst still avoiding areas of flood risk), or by extension to the east, as part of or linking in with the proposed new residential neighbourhood. The potential to integrate with the proposed residential uses is a major advantage of land to the north of London Road, compared to the options proposed for south of London Road.

We note that the description of site E17 states that it is detached from any residential settlement, though it is not clear whether or not this is put forward as a point in its favour or against. It is of course a similar distance to Rayleigh as the most of the options south of London Road, but moreover has the potential to integrate with the proposed new residential development north of London Road, whilst still enabling good access to the highway network for commercial vehicles.

There is no reason why commercial uses should be separated from residential uses, and indeed planning policy at all levels extols the virtues of mixed-used development in sustainability terms. Our view is very strongly in favour of having commercial uses integrated with residential uses as part of a comprehensive mixed-use masterplan, that protects residential amenity whilst still promoting ease of access. Sites that are "detached" should not be favoured over sites that have the potential to create strong mixed-use neighbourhoods.

Turning then lastly to E18, we do not consider this to be a suitable site for commercial development.

Although it may be possible to enhance the existing sub-standard access to the site from the A127/A1245 slip road, the site is removed from the residential communities that the employment would serve, and there is no realistic prospect of accessing the site by public transport or by non-vehicular modes. This is an isolated site in the countryside, accessible only by car, where development would be contrary to advice in PPG13 regarding location of development attracting large numbers of trips and sustainable travel.

As an isolated development site in the heart of the countryside, development here would also have significant adverse impacts on the strategic purposes of the Green Belt, introducing an expanse of commercial development in a highly prominent location between the A127, A1245, A130 and Southend-Liverpool Street railway. This is not development that would be compatible with the retention of the site in the Green Belt, and it would therefore result in a release of Green Belt land in the heart of an area of strategic Green Belt significance.

In summary, in our view the most appropriate location for new employment land west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. The employment land provision could include all or part of E17, or alternative locations north of London Road.