I object because the RDC Sustainability Appraisal 2017 is not objective, is self-contradictory and FAILS to show that the proposed development options are sustainable. It is unfit for purpose.

The study states (para 1.2) it "identifies, describes and evaluates' the likely significant effects of implementing 'the plan, and reasonable alternatives' ". Basically it doesn't do any of these and there are no statistics to support any arguments (for or against). Little/no such evidence has been provided, meaning that the study is inadequate and lacks hard, objective evidence.

There a complete absence of information on the key measures e.g.:
no statistics on highways
no statistics on health
no statistics on education
no baseline or projections based on existing plans.

Consequently, there is little/no evidence of sustainability e.g. on Transport & Movement it specifies:
"Promote sustainable transport use and reduce the need to travel. Will the option/ proposal help to:
Reduce the need to travel through sustainable patterns of land use and development?
Encourage modal shift to more sustainable forms of travel?
Enable transport infrastructure improvements?
Facilitate working from home and remote working?
Provide improvements to and/ or reduce congestion on the existing highway network?"
However, the Appraisal is self-contradictory in this regards. It presents 4 options from the Issues & Options report, two which (para 3.2.3.1 options B&C) which are piecemeal enhancements to existing minor roads which will not achieve any of the above.

Importantly, despite the paucity of objective information, RDC refused a request to add a copy of ECC's Growth & Infrastructure Framework 2016-2036 report (https://www.essex.gov.uk/Documents/GIF.pdf). This report was prepared for ECC in February 2017, by AECOM consultancy (i.e. the same consultancy as prepared the SA. Its is inconceivable that RDC have no statistics on such issues as above, or could not get them from ECC. Their omission therefore must be regarded as a deliberate omission in order to deny information for public scrutiny. RDC's refusal to publish the ECC study further underlines their efforts to cover-up key statistics.

The report shows there is a very significant funding gap across Essex:
"a remaining funding gap estimate of over £4.4 billion at 2016 prices".
"Delivering the necessary infrastructure to support that growth from now to 2036 is estimated to cost at least £10.4 billion in 2016 terms. This represents an estimate of capital delivery costs only"
"In particular the growth in journeys by road and rail has not been matched by sufficient government investment to enhance the network. The framework has identified that major transport projects need to secure £26.5 billion (regional) and £5.5 billion (cross-boundary) funding. These projects currently have a funding gap of around £11 billion
"Pressure on the existing health and social care sector is acute and will continue to grow
Education demand will expand considerably over the next twenty years driven by the scale of housing growth planned. A number of new secondary schools will need to be built, in addition to those required by population growth and policy changes. The limitations of the Community Infrastructure Levy (CIL) make it impossible to secure sufficient funding from developers, particularly to cover the full cost of building new secondary schools".

Other big infrastructure deficits are Adult Social Care (often forgotten as an infrastructure need), water, energy and flood defences. The Evidence published so far also does not include a Green Belt Assessment , a Critical Assessment of cumulative Traffic Flows, Education and Health provisions.

RDC's SA study, in October 2017, was also undertaken by AECOM, but ignores their own findings in the earlier ECC study. Given the significant issues identified in the published ECC report, it is strange that the concerns they raised therein have been ignored!

It has also been revealed that the District's main strategic road, the A127 has congestion and air quality issues, undermining ECC Highway's strategy of directing through traffic on to it. Indeed, the Issues & Options document proposes improving minor roads across the district to accommodate the extra traffic - this is contrary not only to existing ECC Highways policy but also to the aims (as detailed above) of the Sustainability Appraisal! The SA is therefore self-defeating!

There is also no long-term legacy for future generations and no guarantee that the utilities can provide the necessary infrastructure.

Furthermore the council has blocked residents attempts to obtain relevant information essential to the consultation. As noted above, the council refused to add the ECC report, a highly relevant document, to the evidence based. It also refused a Freedom Of Information request for details of the problems on the A127 - the district's main strategic highway. How can the council hold a public consultation while suppressing key information?

The RDC sustainability study is designed to prevent objective assessment and relies largely on subjective measures. Attempts to obtain relevant information has been blocked and the SA is not fit for purpose, cannot be relied upon and should be re-undertaken including actual, meaningful evidence.