Object
Rochford Core Strategy Development Plan Document - Schedule of Changes
Representation ID: 26099
Received: 25/10/2010
Respondent: Mr Stephen Rayner
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
I/we wish to register the following objections and comments regarding the above document:
1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from government policy.
- Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release. This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.
- The older component of our population is said in the Council Paper to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.
- The two proposed new industrial sites will also be on Green Belt land.
- There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?
2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
- There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
- Have the alternatives been properly evaluated and evidenced?
This lack of consultation and inconsistency means the proposals are unsound.
3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?
4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
* There is no evidence that the consolidated impact of all the various developments on highways has been assessed.
* Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.
* No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.
5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring reguarly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Flovial flood risk.
The Core Strategy is therefore unsound.
6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
* Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
* The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
* In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.
7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.
I/we wish to register the following objections and comments regarding the above document:
1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from government policy.
- Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release. This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.
- The older component of our population is said in the Council Paper to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.
- The two proposed new industrial sites will also be on Green Belt land.
- There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?
2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
- There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
- Have the alternatives been properly evaluated and evidenced?
This lack of consultation and inconsistency means the proposals are unsound.
3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?
4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
* There is no evidence that the consolidated impact of all the various developments on highways has been assessed.
* Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.
* No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.
5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring reguarly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Flovial flood risk.
The Core Strategy is therefore unsound.
6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
* Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
* The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
* In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.
7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.