Whilst our particular interest is in the residential allocation for South Canewdon, there are a number of areas where we consider that RDC's own policies have been unlawfully disegarded resulting in the ASD failing the appropriate tests of soundness. We urge the Council to delay the submission of this document and reconsider the contents of the ASD in light of our comments.

Despite the ASD making it clear that the Core Strategy must be adhered to and that the ASD is part of a suite of policy documents (the Development Plan) that are used in part to implement the objectives of the Core Strategy this is simply not the case as currently proposed. As stated in paragraphs 1.22 and 1.26 which state respectively that:
"...the Allocations Document will have to conform to the Core Strategy."

and

"The Core Strategy, as the main planning policy document of the District's Local Development Framework, has a key role to play in delivering all of the above. The Allocations Document will address the Sustainable Community Strategy priorities primarily through aiding the delivery of the Core Strategy."

Para 1.28 continues by stating that:

"National planning policy in the form of the National Planning Policy Framework or NPPF, has also shaped the production of the Allocations Document."

This cannot however be the case when the ASD is set to fail the moment it is implemented.

The ASD fails this crucial conformity test by the proposals within the document being contrary to key objectives of the Core strategy to ensure the appropriate delivery of housing within the district. The sites chosen, the high infrastructure costs and the unrealistic programme described is not achievable, thus the ASD fails on this point alone. RDC has requested that where amendments are sought, the proposed changes are provided. In this instance, this is not possible as we are seeking that the Council revert back to the NPPF and amend multiple sections of the ASD in order to ensure that it adheres to the NPPF and the Core Strategy by being realistic about the delivery of the residential allocations it is proposing.

The proposed allocations and in particular South Canewdon does NOT adhere to the Core Strategy Key Diagram. The location of the proposed allocation sits directly to the WEST of Canewdon. It therefore does not comply with the Core Strategy as it must, in order to be found as being sound by the Inspector. We therefore urge the Council to reconsider this particular allocation. Sites to the east of Canewdon, that are no more south than the proposed allocation were dismissed in part for not being "south of Canewdon". There is clear inconsistencies in the decision making by RDC.

We provide further details under the specific policy of our concerns regarding the Canewdon allocation and how this in many ways is contrary to the Core Strategy and NPPF, resulting in the ASD being viewed as unsound.


Consultation

Mr Stacey is an active member of the Canewdon community and it is evident that very few people knew of the current consultation. There has been very little advertising by Rochford District Council and although extended to 8 weeks, there has been much less active consultation, if any, unlike the "Discussion and Consultation Document Feb 2010" which included a presentation/meeting with each of the villages.

These meetings previously undertaken by Officers of RDC during early 2010 allowed the local community to voice their opinion, however it is not evident from researching the evidence used by RDC that these meetings and their outcomes have indeed been taken into account. No record appears to exist of the items discussed, the principal point being the desire of the local community to protect the setting of the village church. It is our understanding that at this meeting the local community voted in favour of the then option SC1 to the south of Anchor Lane and specifically voted AGAINST development in the location that is now being proposed.

A direct response from RDC on this particular point is essential to ensure that they have taken on board the views of the local community. Until RDC can demonstrate that the appropriate level of consultation has taken place and that the views of the local community has been taken into account, the submission of the ASD must be delayed.

We do not agree that it was appropriate for the Council to consult on the "options" available for the allocations and then not consult the community further until the current "submissions" stage. It is requested that information is provided as to the consultation that took place in respect of the Council's "preferred options" and the response from the community, as we do not believe that the appropriate level of consultation has taken place.