Allocations Submission Document

On behalf of Rawreth Parish Council I confirm that this letter is a formal response and representation of the Councils views with regards to the Allocations submission Document.
This Council believes the LDF Core Strategy, Allocations Submission Document is unsound on two counts. The two counts are detailed below, together with supporting facts and examples. In addition there appears to be no acknowledgement of previous consultations and publication of responses was delayed 12 months after publication of preferred Site Allocations, Policy GB1.

Count 1. Preference and proposed use of Green Belt land over land previously used or brown field sites: Policy ED4 Core Strategy Preferred Options Future Employment Options. GB1 Core Strategy Preferred Options. ENV3 Core Strategy Preferred Options Flood Risk. PPS25 Development & Flood Risk)
Within the Development Management DPD - Preferred Options Document 3.1 clearly states under PPG2, the most important aspect of the Green Belt is its openness. In addition, PPG2 also states within the five purposes of not including land within the Green Belt :

To check the unrestricted sprawl of large built-up areas
To prevent neighbouring towns from merging into one another
To assist in safeguarding the countryside from encroachment
Our first example of unsoundness is the proposed Housing at " Land North of London Road, West of Rayleigh (Rawreth)" vs land previously put forward in the "Call for Sites" at: Hambro Nurseries Rawreth, Former nursery land at Weir Farm, Rayleigh and the Site of Garden Centre and former nurseries in Eastwood Road.

Our second example is the proposed housing in " Hullbridge, Malyons Farm (Rawreth)" vs the at land at NSEC Lower Road Hockley" which was also put forward in the "Call for Sites". All the Sites given in our examples were put forward in the "Call for Sites" and all this land is previously used or brown field land which would provide hundreds of sustainable houses with good access to present infrastructure all falling within PPG2. However they have all been rejected by Rochford District Council as not acceptable.

Our third example is the relocation of Rawreth Industrial Site to a Greenbelt site on the A129 next to Swallows Aquatic Centre vs brown field land at Michelins Farm, adjacent to the A127, put forward in the "Call forSites".

Our fourth example is the erosion of Green Belt and the coalescence of two conurbations, Wickford/Shotgate and Rayleigh, entirely contrary to Green Belt Policy GB1 and H1. If smaller, more appropriate brownfield sites were used, as put forward in the "Call for Sites", this erosion and coalescence would not take place.

This Council believes this document to be UNSOUND as due consideration has not been given to more appropriate sites that clearly fall within PPG2.

Count 2. This Council believes there is an absence of an overall effective Transport Risk Assessment and Traffic Impact Statement which would clearly show the effects of present and future housing on traffic flow on the existing inadequate road network. (Policy T1 & T2)

At the Public Examination in 2010,conducted by the Government Planning Inspector, both this Council and the public were assured that adequate infrastructure would be looked at when the Essex County Council Local Transport Plan was reviewed in 2011. In 2012 ECC explained that " the current Essex Local Transport Plan was developed in line with Department for Transport Guidance and which provides the framework within which transport programmes can be developed."

In the Development Management DPD, Preferred Policy Options Document Rochford District Council's Vision states " The Highway Authority will look at solutions to congestion issues across the District to ensure the highway infrastructure becomes "fit for purpose". Without the risk assessments, congestion issues have not been addressed and the necessary documentation therefore, is not in the Evidence Base which makes the document unsound.


In Minutes of Rochford District Council 27/11/2012 officers advised that "the Highways Authority was looking strategically at the cumulative effect of traffic impact through the Local Transport Plan" and, in addition, " the emerging community infrastructure levy should facilitate strategic highways improvements" yet, there is still no Traffic Impact Assessment of the District within the Evidence Base. DM28
As a Council we know from day to day that the overall highways infrastructure within the District cannot cope with present traffic flow and, therefore, believe that without major infrastructure improvements the situation will become intolerable.
RDC stated in its Public Consultation that to be "SOUND" the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements consistent with sustainable development.

ECC stated in December 2012 "every strategic development proposal is accompanied by a transport assessment agreed with the Highway Authority which will consider the impact of proposed development on the highway network to ensure a comprehensive approach accounting for present traffic conditions and future traffic growth".

Right from the beginning of the Local Development Framework, all the documents within and including the Rochford Core Strategy state clearly "in order for development to be sustainable it must meet the needs of the present and future in terms of highways and traffic impact" and quotes "Improvements must be made to East/West routes"."RDC must ensure there are adequate highway infrastructure improvements to serve new developments and to mitigate their impact".

We believe that this Allocations Submission Document is not "SOUND" on the two Counts as detailed.

One, that the Highway Authority has not objectively assessed the developments and infrastructure requirements taking account of present traffic and future traffic growth. Evidence Base is essential for the "SOUNDNESS" of this document and a Traffic Impact Statement has not been provided within this Base.

Two, the preference and proposed use of Green Belt land over land previously used or brown field sites is contrary to GB1 and, therefore, renders the document UNSOUND.