Peggle Meadow rear of 193 Southend Road Rochford

I refer to the above and write on behalf of my client Mr G Marshall in response to the Consultation.

Many of the details of my client's land at Peggle Meadow were detailed in our response to the Submission Core Strategy (SCS), and a copy of that response is attached for ease of reference. For the reasons set out in that response, we object to both the Submission Core Strategy, and to the noninclusion of my client's land within the draft Allocations DPD.

In the Preferred Options Core Strategy, it was indicated that the Peggle Meadow land was not included for reasons of flood risk and coalescence, and sustainable transport was also mentioned. In our recent agreed Statement of Common Ground for the CS Examination, it was agreed that the developable part of the site was in flood zone 1; that the rail station opposite
was almost complete; that the site was in walking distance of local employment; and that earlier drafts of the Core Strategy did not recognise a strategic gap between Rochford and Southend, notwithstanding the fact that the proposed allocation includes a green space buffer between potential development and the Borough boundary.

Appendix 1 to the current consultation states with regard to site 33 that:

"This site is reasonably well related to Rochford centre and services, and is within close proximity to the new railway station and London Southend
Airport."

Whilst we dispute the word 'reasonably', it does at least acknowledge that the site is locationally acceptable. However, we are disappointed at the least by some of the other comments in appendix 1, which are in our view misleading at best.

With regard to the character of the site and loss of views into or out of the site, Peggle Meadow is entirely screened from outside views by mature tress and existing housing, and therefore there are minimal views in or out, shown by the
aerial photograph in the response to the SCS. The adverse score should be removed. In spite of its name, the site is an overgrown former smallholding with a number of redundant and decrepit buildings, and the loss of this
character is a positive, not a negative.

With regard to the objectives of promoting more sustainable transport choices and promoting accessibility to jobs, shopping, leisure facilities and services by public transport, cycling and walking, it is somewhat surprising that
a site on a main bus route, opposite a new rail station, and which would facilitate the completion of a key element of a strategic cycle network, should not record a score. As you know, SUSTRANS support the development
of our site as essential in securing this link, and you have agreed this in the Statement of Common Ground.

Appendix 1 in relation to this site concludes by saying that site 33 is not situated within a proposed strategic location for housing in the emerging Core Strategy, as there is a need to avoid the coalescence of Rochford / Ashingdon with Southend. It goes on to state that the site would not contribute fully to the housing targets as specified within the Core Strategy Submission Document. Aside from the fact that the concern over coalescence is disproved by both the master plan contained in our SCS response and the lack of identification of a strategic gap in this location, is the point about meeting housing targets.

At the Inquiry into the last Local Plan, we put forward a case that the Local Plan did not look forward far enough, and that promises of an early review via the LDF would not be timely enough to avoid the Council getting into
problems over housing delivery. The recent flurry of applications and appeals are a consequence of this. The consistent case put forward by the promoters of these schemes is that the release of Green Belt land is required to meet the District Council's strategic housing requirement, including maintaining a 5
year supply of housing land as required by Para 54 of PPS3, and that the Council cannot demonstrate 5 years' supply of deliverable housing land for the purposes of PPS3 without reliance upon new sites to be confirmed through
the LDF process.

The Core Strategy seeks to address the strategic housing requirements set out
in the East of England Plan 2008 up to 2025. The EEP sets a housing requirement of 250 dwellings per annum (2006 to 2021), with this annual rate to be continued beyond 2021 in advance of a review. This figure is expressed
as a minimum.

The SCS identifies a need to release land to accommodate some 3,790 dwellings between 2006 - 2021 in addition to sites already with permission or the subject of previous allocations in the Local Plan The SCS identifies a need
for 751 dwellings to be released on Green Belt land to meet requirement to 2015.

As set out in our previous representations, the Council is relying heavily on short term delivery from larger housing sites many of which also rely on the relocation of employment areas. Even the Hall Road site will not meaningfully deliver until 2013 according to their own evidence.

In addition to this, the EEP 2008 is being reviewed to extend the period to 2031
and this process was begun in Autumn 2009. Growth scenarios 1-3 would involve some 5,000 net additional dwellings being required between 2011 and 2031 in Rochford, whilst scenario 4 envisages 8,000 net additional dwellings in Rochford. The EEP Review will inevitably require additional housing to be provided in the District that is beyond that anticipated in the current Annual Monitoring Report and beyond that anticipated in the SCS which is premised on delivering 4,600 dwellings up to 2021 plus an annualised rate of 250 dwellings per annum in the period 2021 to 2026.

The revision of Green Belt boundaries must be based therefore on ensuring a flexible projection of growth to ensure that GB boundaries transcend development plan timescales and can endure in accordance with PPG2 para 2.12. This factor has not been taken into account either in the SCS or in the current consultation in ensuring that Green Belt boundaries will not need
to be altered at the end of the plan period, or whether land should be safeguarded.

The Council's cautious approach in being slow to follow regional guidance and planning for the bare minimum has caused the current shortfall, and the Council should consider allocating land such as that at Peggle Meadow which can be developed swiftly, as well as planning properly the delivery of larger sites, perhaps by reserving those with particular problems of delivery
such as west of Rayleigh.

We look forward to being involved in further drafts of the allocations document, but hope that weight is given to the above.

For further details see paper copy.