Thank you for inviting Basildon Borough Council to provide comments as part of Rochford District Council's consultation on its Regulation 18 New Local Plan Issues and Options Document and Draft Sustainability Appraisal (SA) of the Rochford Local Plan 2017. Please accept this letter as the response of Basildon Borough Council to the consultation.

Rochford District Council is in the first stages of consultation on the review of their current Local Development Plan, to ensure that the policies are robust, effective and up-to-date, in accordance with the Planning and Compulsory Purchase Act 2004.
Basildon Borough Council acknowledges that this is the first stage of consultation on the new Local Plan for Rochford, and that a number of issues and options are being considered. It is acknowledged that the Local Plan consultation document does not identify specific sites, and that more detailed planning policies will evolve as each consultation stage on the new Local Plan progresses. In view of this, Basildon Borough Council has considered the consultation documentation, its role as a neighbouring planning authority, and strategic and cross boundary matters which are covered by the Duty to Cooperate, and wishes to make a series of observations which Rochford should take into consideration when it prepares the draft version of its Local Plan.

SP1.1: Objectively Assessed Need (OAN)

Consideration has been given to the approach Rochford District Council has taken in determining its OAN for housing. It is clear from the evidence that the need identified within the Rochford District Issues and Options Report reflects more up-to-date national household projections, as required by the Planning Practice Guidance (PPG), taking into account matters such as economic growth and the need for affordable housing, and is informed by an up-to-date SHMA. A robust approach has been taken in considering the housing need within Rochford district, and no objection is being raised as to how the OAN figure has been calculated.
In relation to meeting its OAN, Rochford District Council is seeking to provide as much of the district's housing within the area, as far as possible, against the identified need, and given environmental and other constraints. Rochford District has also highlighted a commitment to work with neighbouring Local Planning Authorities (LPAs) to ensure that the housing need across the South Essex Housing Market Area is effectively met. In view of this, Basildon Council supports Rochford Council's intention to meeting its own needs, and to work effectively with neighbours to ensure that the need for housing in the South Essex Housing Market Area is collectively addressed. Basildon Borough Council will continue to support more effective joint working with Rochford as their new Local Plan emerges, in line with the Duty to Co-operate.
The aspiration to provide Rochford District residents with the opportunity to access a
percentage of new market homes on schemes as a priority is also noted. Basildon
Borough Council will recommend that any supporting policy requirement in relation to meeting the housing needs of residents should be backed with reasonable justification and evidence, in line with national policy and guidance.
Finally, attention is drawn to the emerging Basildon Borough Local Plan. Since the
Basildon Borough Draft Local Plan consultation in 2016, significant matters of principle in relation to the Basildon Local Plan have been considered and resolved. As a consequence, Basildon Council through several decision making processes, has taken the position that some changes should be made to either the Local Plan, or the process of preparing the Local Plan, in order to ensure it is sound. One of these changes arises from the fact that the suite of sites identified for inclusion in the Basildon Borough Local Plan does not meet the identified need for housing of between 19,440 and 19,720 homes. This gives rise to an unmet housing need, which when delivery issues are taken into account is around 4,000 homes for the plan period up to 2034. Following Basildon Borough Council's Infrastructure Growth and Development (IGD) Committee Meeting on the 16 January 2018, and in order to ensure that the Basildon Borough Local Plan is sound in regard to this matter, it has been recommended that assistance is formally sought from other LPAs in the Housing Market Area, to help Basildon Borough to meet its unmet housing need.
Basildon Borough Council therefore formally requests that Rochford District Council
considers whether they can assist in meeting some of Basildon Borough's unmet need in the Rochford District Local Plan.

SP1.5: Gypsy, Travellers and Travelling Showpeople

A need for 15 Gypsy and Traveller pitches up to 2018 was identified in the Rochford
District Core Strategy 2011. The Issues and Options Report however recognises the
recent changes made to legislation relating to Gypsies, Travellers and Travelling
Showpeople. Following the change in definition of Gypsies, Travellers and Travelling
Showpeople, a further Essex-wide Gypsy and Traveller and Travelling Showpeople
Accommodation Assessment (G&T and TS AA) was commissioned to understand the
implications for plan-making. A need for Gypsy and Traveller pitches was identified, but there was no need for Travelling Showpeople plots. The assessed need for Gypsy and Traveller pitches in Rochford District up to 2033 within the emerging G&T and TS AA 2017 for Rochford District could however still be met through the 15 pitch site allocated in the current Allocations Plan Policy GT1. This means that Rochford District can demonstrate a land supply up to 2033 (including a five year supply) for all Gypsy and Traveller households within the district, regardless of whether they meet the 2015 Planning Policy for Traveller Sites (PPTS) definition or not. Basildon Borough Council supports the approach Rochford District are taking in ensuring that their evidence base is up-to-date.

However, while the G&T and TS AA establishes a need for the plan period of 2013-2033, Rochford District's new Local Plan looks forward to 2037. It is therefore unclear how the Gypsy and Traveller needs for Rochford District will be met in the remainder of the plan period (2033-2037), and further evidence of this should be provided. Rochford District Council should carry out further work to re-assess the Gypsy, Traveller and Travelling Showpeople needs up to 2037, and should the need for pitches change in light of this, Rochford District Council should seek to update the Rochford Local Plan accordingly to continue to meet their full objectively assessed needs for Gypsy, Traveller and Travelling Showpeople.

There is also a concern that no acknowledgement has been made of the fact that there may be unmet needs arising from Greater Essex authorities for the provision of accommodation for Gypsies, Travellers & Travelling Showpeople within the Rochford Issues and Options Report, which is considered to be a shortcoming. Basildon Borough Council has agreed to work with Chelmsford City Council, Harlow District Council and Colchester Borough Council on behalf of the Essex Planning Officer's Association to develop a protocol for unmet Gypsy, Traveller and Travelling Showpeople need, should this situation arise in any local planning authority in Greater Essex. It is envisaged that this work will be carried out in 2018. Rochford District Council should therefore recognise and support the principle of this approach going forward, to ensure that there will be a technical approach in place to support any neighbouring authorities with any potential unmet Gypsy, Traveller and Travelling Showpeople need in the future. This is to ensure that a fair process is applied throughout Essex, and ensures compliance with the Duty to Cooperate.

SP3.1: Highways Infrastructure

The Rochford Issues and Options Report sets out different options for managing traffic in and around Rochford District. The report recognises that the A127 has known capacity and congestion issues. Consequently, Rochford Council has proposed to work with Essex County Council and Southend-on-Sea Borough Council, to develop a transport model for South Essex, which will cover the length of the A127. Basildon Borough Council supports this approach. Rochford Council's commitment within paragraph 8.18, to continue to work with neighbouring local authorities and the Highway Authority to promote strategic and more localised improvements to the highway network is also noted. This initiative is supported by Basildon Council. In particular, reference was made within paragraph 8.18, to the potential for a new link road from the A127 at Pound Lane/Cranfield Park Road to link to the A130 in Rochford District.

It should be noted that the proposed grade separated junction on the A127 at Pound
Lane, with the new link road to the A130 was identified within the Policy TS2 of the
Basildon Borough Draft Local Plan 2016 as part of the provision for new and improved transport infrastructure, essential to mitigate the impact of future housing and economic growth in Basildon Borough. It is expected that this junction will serve the development proposed at East Basildon and South Wickford, improve access to the A127 enterprise corridor, reduce pressure at the A132 Nevendon Interchange and Fairglen Interchange, as well as freeing up capacity for local traffic. This junction will therefore provide significant benefits for both the strategic and local road network. However, this proposal is substantially more expensive at around £130m, and raises issues around development viability.

The proposed improvement to highway infrastructure will therefore require support and funding from neighbouring authorities, to supplement developer contributions from the Department for Transport and South East Local Enterprise Partnership. As Rochford District communities could potentially benefit from the provision of the proposed grade separated junction on the A127 at Pound Lane, with the new link road to the A130, Basildon Borough Council formally requests that Rochford District Council should account for part funding of this junction within the new Local Plan for Rochford. As part of the transport modelling to support the Rochford Local Plan, and also within the Rochford Local Plan itself, Rochford District Council needs to also consider its relationships with neighbouring authorities when allocating growth locations. Basildon Borough is most likely to be affected if growth is concentrated to the west. It is therefore important that Rochford District Council ensures collaborative engagement and continual working between local planning authorities, with the highway authority, and with transport providers to ensure that strategic transport links are capable of accommodating the additional transport pressures that are likely to arise as a result of future population growth, particularly to the west of the Rochford District area.

SP3.2: Sustainable Travel

The main road linking Basildon Borough with Rochford District is the A127, which is well documented to experience capacity challenges, particularly in peak periods. Rochford District Council should ensure that new development have accessible services, and enables people to reduce the need to travel by private car, as much as possible, particularly as the district experiences high levels of car ownership and high levels of outcommuting. In addition, the South Essex Economic Development Needs Assessment (EDNA) 2017 identifies the A127 Enterprise Corridor as an important employment location in South Essex. The role of this corridor will be retained and grown, with the aim of attracting new investors to the corridor. Enhanced public transport connectivity between towns in Rochford District and this employment area in Basildon Borough should therefore be sought by Rochford District as part of the strategy for improving sustainable travel choices across the District and into South Essex.

SP4.3: Open Space and Outdoor Sports and Recreation

Basildon Council welcomes the opportunity to work with Rochford District Council and other neighbouring authorities in South Essex, to prepare more strategic level evidence of needs across the sub-region for open space, sports and recreation, in line with national policy, and to identify ways to improve connectivity between green spaces through the provision of green corridors.

Duty to Co-Operate

In order for the Rochford District Local Plan to be found procedurally sound, it will need to take account of a broader range of issues and opportunities affecting neighbouring areas and the wider region, considering and addressing strategic cross-boundary issues.
Attention is drawn to the joint-working that is underway in South Essex, which aims to deliver a more coordinated planning, regeneration and investment agenda to benefit the combined local communities. It is expected that the development of a Joint Strategic
Planning and Infrastructure Framework (SPIF) would set the strategic growth objectives for South Essex and provide the "effective mechanism" required to determine how unmet development needs from individual local authority areas would be met.
Building on this foundation, it is also relevant to mention the South Essex 2050 which is a unified long-term place vision for the South Essex area, with the addition of Brentwood Borough Council. This work, due to conclude in early 2018, is expected to determine how the work on the Joint SPIF and its inter-relationships to South Essex Local Plans will be prepared and managed in the future, and could accelerate the conditions needed to deliver the shared housing & job ambitions, enabled by significant improvements to transport & other infrastructure.
This shared support demonstrates that LPAs across the region have been engaging
constructively and actively, to maximise the effectiveness of Local Plan preparation in the context of strategic cross-boundary matters, and contribute to fulfilling the requirement for Local Planning Authorities to work together under the "Duty to Co-operate", as set out in the Localism Act 2011.
Basildon Borough Council is satisfied with the degree of engagement with regard to the Rochford District New Local Plan, and welcomes the opportunity to continue to work with Rochford District Council and other neighbouring authorities in the region on the content of the new Local Plan and its approach to strategic, cross-boundary matters such as housing growth, employment growth, and infrastructure provision through the Duty to Cooperate.

General Observations

It is noted that some of the evidence base, which will inform and support Rochford District Council's emerging Local Plan, is still underway. Some of this has been commissioned jointly with other LPAs, including Basildon Council. While it is not possible for Basildon Council to comment on the forthcoming evidence at this time, Basildon Borough Council will continue to work with Rochford District Council in the preparation of any joint evidence base work to ensure that it is comprehensive and appropriate for what the Local Plan will cover.

Rochford District Council should further identify options, strategic growth areas and
policies informed by up-to-date evidence and, through publication of a draft Local Plan, invite further representations from LPAs and other stakeholders.

Basildon Borough Council welcomes further engagement with Rochford District Council to ensure that the observations raised in this response are duly considered and to continue working together on strategic planning priorities through the Duty to Co-operate.

Draft Sustainability Appraisal of the Rochford Local Plan

Basildon Borough Council has reviewed the content of the Draft Sustainability Appraisal of the Rochford Local Plan, and can confirm that on this occasion, Basildon Borough Council has no comments to make, as it covers all the matters you would expect to see in such a document.