Comment
Issues and Options Document
Representation ID: 36223
Received: 29/01/2018
Respondent: S. A. Skinner
Sustainability Appraisal Document
Section 3211 Distribution Strategy
Option C,D & E
Page 12/13
If I understand National Planning Policy correctly, there is a presumption in favour of protecting the green belt from development other than in exceptional circumstances.
No attempt whatsoever has been made to argue that there are exceptional reasons for releasing green belt land to provide new residential development in the Rochford District, in the discussion of Distribution Strategy options in this document. The argument seems to be that there would be Section 106/CIL advantages to releasing land to extend the existing settlement areas - but this in no way amounts to exceptional circumstances. How then, can it be seen as compatible with National Planning Policy?
Surely the gains from 106/CIL Agreements would need to be of outstanding value in terms of providing new community facilities (e.g. public open space) before any justification could begin to be made for there being exceptional reasons for releasing green belt land? This document does not suggest in any way that the gains from such agreements would be outstanding.
It seems to me that only something like being able to crease a new large country park for Rayleigh, Hullbridge and Rawreth would amount to something of such outstanding value (both in terms of community facilities and of giving added protection to a large area of green belt), that it might be argued it amounted to exceptional circumstances.
There is no mention in this document of whether new development should be distributed as evenly as possible throughout the District, or concentrated in particular areas, but this is a key question that needs to be considered. If Option E was pursued, for instance, it would have a disproportionate impact on whatever area of the District it was to be located in.
29th January 2018
Sustainability Appraisal Document
Section 3243 Open Space and Recreation & Table 3: Greenways Options & Table 14: Tourism & Rural Diversification Options
There is a tendency for public open spaces to become marooned inside the urban envelope, which limits their value as wildlife habitat/recreational facilities. For instance, although Sweyne Park is a large open space, it is now completely surrounded on all sides by residential developments, so it is cut off from other open spaces/open countryside. Anyone visiting Sweyne Park can't easily go on to visit any nearby open space, although, of course, it does act as a valuable green lung for residents living around it.
Where, however, there are open spaces which are still at least partly joined to opening countryside, or where two open spaces are close enough to be linked together (by a wildlife corridor, greenway or even just a narrow footpath, for instance) greater emphasis should be placed on establishing/protecting these links before additional development or changing land use make it impossible. The need to do this should be reflected in the policies concerning open space provision.
That it is possible to do it has been proved by the expansion of the Cherry Orchard Jubilee Country Park, that now links through to Grove Wood on the edge of Rayleigh, and has a pedestrian link to Hockley Woods.
In terms of green tourism, there is an obvious benefit where visitors are able to walk/cycle from one open space through to another open space. It can expand the experience on offer into a half-day visit, or even an all-day visit.
Promoting the visiting of open spaces/leisure facilities/heritage sites could be improved. For instance, within Rayleigh Town Centre there is the Windmill, Rayleigh Mount, the Town Museum and the Dutch Cottage all within walking distance of one another, as well as the playspace at King George V Playing field, but little is done to link them all together on a visitor trail. If the Council is serious about promoting tourism, it needs to up its game in this report. Again, the need to emphasise the connectivity of facilities/attractions should be saying "you've visited this place, now go on to .......", with a little arrowed maplet showing how to get there. This might benefit local residents who may not be aware of all the open spaces/leisure facilities in their area, as well as visitors to the District.
29th January 2018
Sustainability Appraisal Document
Section: Table 19, Sustainable Travel Options
Option: D
One of the disadvantages of adding extensions to existing residential areas by releasing green belt land for development is that each extension takes the new housing further out from the centre of the village/town, and yet most of the community facilities (High Streets, shopping areas, railway stations, etc.) will inevitably be at, or relatively near, the centre.
Apart from the fact that this has a negative affect on promoting community spirit, as the new residents feel cut off from the centre and isolated on the edges, it makes them much more dependent on having some form of transport, because the centre is no longer within easy walking distance.
Although car ownership may be high, traffic congestion is an increasing problem on the road network, so the alternative of some form of public transport provision is important. (Use of the private car also tends to encourage residents on the edges of residential area to head towards out of town facilities rather than supporting their local High Street, for instance). For this reason, I support Option D of requiring schemes of less than 50 new homes to have a travel plan, in addition to the existing requirement for schemes of over 50 homes.
One way of encouraging cycling would be to insist that each new development must include a cycle path along its spine road as well as a separate footway. This would make it safer for children to take up cycling from a young age (as well as making it safer for pedestrians). Trying to provide cycleways on the existing road network is incredibly difficult because they were never designed in the first place to keep cyclists separate from other traffic, but it is a simple thing to include a cycleway at the edge of a new road, it just requires a bit more space being used.
29th January 2018
Sustainability Appraisal Document
Section 3211 Distribution Strategy
Option C,D & E
Page 12/13
If I understand National Planning Policy correctly, there is a presumption in favour of protecting the green belt from development other than in exceptional circumstances.
No attempt whatsoever has been made to argue that there are exceptional reasons for releasing green belt land to provide new residential development in the Rochford District, in the discussion of Distribution Strategy options in this document. The argument seems to be that there would be Section 106/CIL advantages to releasing land to extend the existing settlement areas - but this in no way amounts to exceptional circumstances. How then, can it be seen as compatible with National Planning Policy?
Surely the gains from 106/CIL Agreements would need to be of outstanding value in terms of providing new community facilities (e.g. public open space) before any justification could begin to be made for there being exceptional reasons for releasing green belt land? This document does not suggest in any way that the gains from such agreements would be outstanding.
It seems to me that only something like being able to crease a new large country park for Rayleigh, Hullbridge and Rawreth would amount to something of such outstanding value (both in terms of community facilities and of giving added protection to a large area of green belt), that it might be argued it amounted to exceptional circumstances.
There is no mention in this document of whether new development should be distributed as evenly as possible throughout the District, or concentrated in particular areas, but this is a key question that needs to be considered. If Option E was pursued, for instance, it would have a disproportionate impact on whatever area of the District it was to be located in.
29th January 2018
Sustainability Appraisal Document
Section 3243 Open Space and Recreation & Table 3: Greenways Options & Table 14: Tourism & Rural Diversification Options
There is a tendency for public open spaces to become marooned inside the urban envelope, which limits their value as wildlife habitat/recreational facilities. For instance, although Sweyne Park is a large open space, it is now completely surrounded on all sides by residential developments, so it is cut off from other open spaces/open countryside. Anyone visiting Sweyne Park can't easily go on to visit any nearby open space, although, of course, it does act as a valuable green lung for residents living around it.
Where, however, there are open spaces which are still at least partly joined to opening countryside, or where two open spaces are close enough to be linked together (by a wildlife corridor, greenway or even just a narrow footpath, for instance) greater emphasis should be placed on establishing/protecting these links before additional development or changing land use make it impossible. The need to do this should be reflected in the policies concerning open space provision.
That it is possible to do it has been proved by the expansion of the Cherry Orchard Jubilee Country Park, that now links through to Grove Wood on the edge of Rayleigh, and has a pedestrian link to Hockley Woods.
In terms of green tourism, there is an obvious benefit where visitors are able to walk/cycle from one open space through to another open space. It can expand the experience on offer into a half-day visit, or even an all-day visit.
Promoting the visiting of open spaces/leisure facilities/heritage sites could be improved. For instance, within Rayleigh Town Centre there is the Windmill, Rayleigh Mount, the Town Museum and the Dutch Cottage all within walking distance of one another, as well as the playspace at King George V Playing field, but little is done to link them all together on a visitor trail. If the Council is serious about promoting tourism, it needs to up its game in this report. Again, the need to emphasise the connectivity of facilities/attractions should be saying "you've visited this place, now go on to .......", with a little arrowed maplet showing how to get there. This might benefit local residents who may not be aware of all the open spaces/leisure facilities in their area, as well as visitors to the District.
29th January 2018
Sustainability Appraisal Document
Section: Table 19, Sustainable Travel Options
Option: D
One of the disadvantages of adding extensions to existing residential areas by releasing green belt land for development is that each extension takes the new housing further out from the centre of the village/town, and yet most of the community facilities (High Streets, shopping areas, railway stations, etc.) will inevitably be at, or relatively near, the centre.
Apart from the fact that this has a negative affect on promoting community spirit, as the new residents feel cut off from the centre and isolated on the edges, it makes them much more dependent on having some form of transport, because the centre is no longer within easy walking distance.
Although car ownership may be high, traffic congestion is an increasing problem on the road network, so the alternative of some form of public transport provision is important. (Use of the private car also tends to encourage residents on the edges of residential area to head towards out of town facilities rather than supporting their local High Street, for instance). For this reason, I support Option D of requiring schemes of less than 50 new homes to have a travel plan, in addition to the existing requirement for schemes of over 50 homes.
One way of encouraging cycling would be to insist that each new development must include a cycle path along its spine road as well as a separate footway. This would make it safer for children to take up cycling from a young age (as well as making it safer for pedestrians). Trying to provide cycleways on the existing road network is incredibly difficult because they were never designed in the first place to keep cyclists separate from other traffic, but it is a simple thing to include a cycleway at the edge of a new road, it just requires a bit more space being used.
29th January 2018