*THIS REPRESENTATION INCLUDES AN ATTACHMENT*

1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council in
support of land to the south of the former Adult Community Learning Centre ("ACL Centre"),
Rocheway, Rochford (hereby referred to as the "Site").
1.2 The Site is owned by Essex County Council ("ECC") and is currently designated as open space in
the adopted Local Plan. It is used under licence for 10 months of the year by Hambro Colts, a local
youth football team which has aspirations to relocate back to its original home in Rayleigh and is
working collaboratively with ECC to do so. The site is not used for any other purpose despite its
designation.
1.3 The New Local Plan presents Rochford District Council (RDC) with an opportunity to take a
comprehensive approach to the consideration of open space provision alongside housing and
employment strategies, considering the re-provision of existing open spaces where this would
support sustainable patterns of development, where appropriate. This should be informed by
emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
1.4 In this context we therefore consider that the Site has excellent residential redevelopment potential
taking account of its sustainable location within walking distance of Rochford town centre and the
opportunity presented by the extant planning permission for the redevelopment of the former ACL
Centre, granted under 17/00102/FUL, which would provide means of vehicle access to the Site
from the north.
Summary of representations
1.5 Taking account of the above, our representations may be summarised as follows:
● We consider the RDC should plan to meet its full objectively assessed housing need across
the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order
settlements in the hierarchy, such as Rochford;
● We consider that RDC needs to undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate.

2.0 The Site

2.1 The extent of the Site is shown on the accompanying plan at Appendix 1 of this document. The Site is currently designated as open space under adopted policy OSL1 and it falls within the Green Belt.

*PLEASE SEE ATTACHMENT FOR MAP* Above: The Site in context. Note its proximity to Rochford town centre approximately 400 metres to the west.

2.2 The Site is formed of playing fields to the south of the former ACL Centre, constructed in the mid-
1930s as a school which was later converted to its most recent use. The designated open space to the south of the ACL was therefore originally intended as a playing field for the school and not as a purpose built public space.

2.3 The Site is defined by strong physical hedgerow boundaries to its western, southern and eastern sides. Designated amenity open space at Millview Meadows is immediately to the west of the site and arable agricultural land is to the east. The Site located within easy walking distance of Rochford town centre's many services, facilities and retail offer via safe, convenient and well-lit pedestrian routes. Rochford town centre also offers regular bus routes to Southend-on-Sea and Rayleigh and mainline railway links to London Liverpool Street and London Southend Airport. The Site is considered to be sustainably located.

The playing pitches on the Site are currently used under licence for 10 months of the year by the
Hambro Colts, a Rayleigh-based youth football team, for training purposes and on matchdays. The
pitches remain unused for the remainder of the monthly schedule. The Hambro Colts temporarily
relocated from Rayleigh to the current Rocheway Site some years ago, but due to a lack of
available alternative site in the Rayleigh area, have not been able to return to their home location.
It is the club's ultimate intention to do so and is in collaboration with ECC to ensure that suitable
facilities can be delivered equitably.

2.5 Taking account of these existing constraints, we recognise that the appropriate manner for this development potential to be realised is through the new Local Plan, in full consultation with the relevant statutory bodies. This would ensure that any requirements for the quanta and location of open space re-provision may be devised in a collaborative way and in accordance with emerging evidence of need. We also propose that the Green Belt boundary is amended as part of the new Local Plan so that the Site may be included within a revised development boundary for Rochford.

3.0 The Evidence Base
Strategic Housing Land Availability Assessment
3.1 The Strategic Housing and Economic Land Availability Assessment (SHELAA), prepared in 2017,
identifies that the Site is suitable, available and that housing development is achievable. A copy
of that assessment is contained at Appendix 2 of this document.
Open Space Provision
3.2 The evidence of relevance to the Site includes the Open Space Study (2009) and Playing Pitch
Strategy (2012), both prepared by RDC in support of its adopted Development Plan. They
identified at the time of their publication that:
● The Site is one of 48 outdoor sports facilities in the District, which collectively provide a total of
1.6 hectares per 1000 population (excluding golf courses) across Rochford. This falls slightly
short of the recommended 1.8ha per 1000 population standard;
● When provision is assessed across the District by ward, the ward in which the Site is located
has an identified surplus in provision;
● There is an imbalance in geographical spread of play space provision - players tend to reside
on the western side of the District (i.e. Rayleigh and to the west of the District in Wickford and
Basildon) thus clubs travel further to the east (including Rochford) to use pitches.
● There is a shortage of mini and junior football pitches - note that during its preparation, the
Playing Pitch Strategy identified the opening of a new facility at Priory Chase in Rayleigh which includes three mini pitches and two junior pitches. As this new facility was not considered as part of the study, it is considered that this provision would contribute to the shortage - both in terms of geographical spread and type of playing space; and
● Outdoor sports facilities are one of the least visited types of open space, assessed as being only moderately needed in the District, after other types of open space such as natural and semi-natural greenspaces, amenity spaces and play space;
● The Site at Rocheway is listed in the Open Spaces Study as an "Outdoor Sports Facility" but, unlike other such facilities listed in the document, is not individually assessed. The evidence therefore provides no overall conclusion or commentary on the quality or suitability of the Site for recreational purposes at present. We would expect this to be updated and to include the Site as part of the evidence base underpinning the new Local Plan.

3.3 It is possible to ascertain from the above that any historic under-provision of playing pitches in the District may have been met by the introduction of new dedicated play space in the western side of the District, thereby re-balancing an uneven geographical spread previously weighted more heavily to the east.

3.4 It is there of utmost important that RDC updates its assessment of open space provision and need as part of the new Local Plan, including all sites currently designated as open space including an assessment of the Rocheway Site.

4.0 Responses to Issues and Options Questionnaire

4.1 Taking account of the above, we set out our responses to the questions raised in the Issues and Options document which are of relevance to Rochford and to the Site.

Strategic Priority 1: The homes and jobs needed in the area
Question SP1.1 - We have a real identified need for affordable homes in the district and an ageing population, so how do we sustainably meet our need for market and affordable homes, and homes for older people and adults with disabilities over the next 20 years?
Our comments on the identified issues in respect of objectively assessed housing need:

4.2 We support RDC's acknowledgement of the district's objectively assessed housing need (OAHN) for Rochford District.

4.3 We note that RDC states that the Core Strategy housing target of 250 homes per year has been challenging to meet, due to factors beyond its control (Issues and Options document para 6.18).
The OAHN for the district is even higher than the Core Strategy figure; a range of between 331 and 362 new homes will be needed per year. If the Council is to deliver the new homes that are needed to support the employment and economic growth anticipated in the district within the Plan period as part of the wider strategy, we consider it imperative that the new Local Plan seeks to plan to facilitate growth, allowing sufficient flexibility so that it is resilient to change and/or under-delivery.
We therefore consider that the new Local Plan should plan to meet the higher 362 per annum figure. Our position in this respect is supported by the Framework, which clearly requires local
planning authorities to "boost significantly the supply of housing" (para 47) by "using their evidence
base to ensure that their Local Plan meets the full [our emphasis] objectively assessed needs".

Our comments on the identified options in respect of objectively assessed need:

4.4 The options as set out are:
A. Seek to provide as much of the district's housing need within our own area, as far as possible, given environmental and other constraints.
B. Work with neighbouring authorities to ensure that housing need across the South Essex Housing Market Area is effectively met.
C. Consider a policy requirement to deliver a percentage of new market homes on schemes to be available to residents on a first-come first served basis for a limited period of time.

4.5 Taking account of the issues highlighted above, we consider that Option A is the most appropriate; RDC should seek to provide as much of the district's housing need within its own area. If RDC were to propose that its neighbouring authorities take a proportion of unmet need, it must be satisfied that it had first passed the test set by Planning Practice Guidance, which makes it clear that under the duty to cooperate "local planning authorities should have explored all available options for delivering the planning strategy within their own planning area" (Paragraph: 003 Reference ID: 9-003-20140306). RDC notes that it is subject to environmental and other policy constraints (including Green Belt); RDC's neighbouring authorities within the South Essex Housing Market Area are subject to similar environmental and policy constraints. We are not aware of any other local authorities in this situation that have successfully demonstrated the soundness of an approach at Examination that seeks to reduce the amount of housing growth against the evidence.

4.6 RDC should therefore plan to meet its full OAHN within its own administrative boundaries as part of the new Local Plan.

Question SP1.3 - How do we plan for and facilitate the delivery of our need for new homes over the next 20 years within the district?
Our comments on the issues:

4.7 We note that the Issues and Options document identifies the settlement hierarchy as set out in the adopted Core Strategy (2011), as follows:

TIER SETTLEMENTS
1 Rayleigh;
Rochford / Ashingdon;
Hockley / Hawkwell.
2 Hullbridge;
Great Wakering
3 Canewdon
4 All other settlements

4.8 The table shows that Rochford sits within the top tier of settlements in the adopted Core Strategy.

Having regard to its sustainable location with easy access to public transport opportunities including mainline rail and London Southend Airport, range of services and amenities, we consider that the settlement hierarchy should remain the basis for spatial planning in Rochford district as part of the new Local Plan, because this has not fundamentally changed in the time since the Core
Strategy was adopted.

Our comments on the options:
4.9 The realistic options as set out are:
A. Increasing density within the existing residential area - which would require an
amendment to the current density policy.
B. Increase density on allocated residential sites
C. Several small extensions to the existing residential area.
D. A number of fewer larger extensions to the existing residential area.
E. A new settlement.

We consider that option D is the most appropriate method of meeting RDC's housing needs.
Taking account of the district's spatial and environmental characteristics, existing settlement
hierarchy and structure, several fewer larger extensions to existing sustainable settlements
including Rochford provide the only realistic method of delivering on the scale required to meet
RDC's full OAHN.
4.11 Our reasoning for this approach is because options A and B would drastically alter the character
of existing settlements and residential land allocations to the extent that would be damaging to
existing character and environmentally. Furthermore these options would be ineffective in meeting
the scale of OAHN the Plan needs to accommodate over the next 20 years.
4.12 We do not consider that Option C would deliver sufficient CIL or s106 receipts to enable the
cumulative impacts of several small extensions to existing residential areas to be adequately mitigated. This would create larger problems for the future, which would be unsustainable and fail to address the key priorities identified in the consultation document.

4.13 Option E would require such substantial infrastructure and funding to make development both acceptable and deliverable and this would seriously inhibit the ability of development to deliver other planning policy objectives, such as affordable housing provision. In any event, we do not consider that the district displays the type of spatial characteristics that could allow it to successfully accommodate a new settlement under Option E.

4.14 This means that the only reasonable option is Option D. The Issues and Options document acknowledges that larger extensions to existing residential areas of sustainable settlements, such as Rochford, can contribute more to improving existing infrastructure and deliver new infrastructure through s106 agreements and CIL to mitigate the impact of any scheme. We agree with and support this approach.

Strategic Priority 4: Supporting Health, Community and Culture

Question SP4.3 - How do we plan to meet the needs for open space, sports and recreational facilities across the district over the next 20 years?
Our comments on the identified issues:

4.15 We note and support RDC in updating its evidence on the demand for playing pitches and that this is needed to inform the planning of future provision. We also support the collaboration with neighbouring authorities on a strategic scale because this would capture trends of movement to and from areas of open space that might otherwise remain unidentified. It is evident from the existing evidence base (refer to section 3 of this document above) that it is not possible for RDC to make informed (and therefore sound) decisions on spatial planning matters without first having a full appreciation of the quantum and quality of all existing open space within the District, including the Rocheway Site.

We also consider that the updated evidence should form part of a comprehensive strategy that considers housing and economic development needs in the round. This is particularly important because as Rochford is a Green Belt authority, it falls to be considered under Framework paragraph 84 in which RDC will need to consider the need to promote sustainable patterns of development as part of a Green Belt Review. Furthermore, Framework paragraph 74 allows the replacement of existing open space with equivalent or better provision in terms of quality and quantity in suitable locations.

4.17 Where under-utilised open space exists in sustainable locations, it would be inappropriate for RDC to overlook the development potential of such sites if such opportunities were considered alongside proposals for their re-provision in more suitable locations, where appropriate.

4.18 The policy approach to this is supported by National Planning Policy Framework paragraph 158 which, in respect of plan-making, says that "local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated and that they take full account of relevant market and economic signals." Furthermore, paragraph 70 says that planning policies and decisions should ensure an integrated approach to considering the location of housing, economic uses and community facilities and services."

4.19 We consider that RDC should use the Local Plan Review to comprehensively consider its approach to the provision and location of open spaces so that opportunities for their use and participation in sport may be maximised. Such an approach would enable new development to be delivered in the most sustainable locations, boosting the health of the community, therefore delivering a range of wider sustainability objectives.
Our comments on the identified options:
4.20 The options set out are:
A. Retain, and where necessary update, the existing overarching policy on open spaces.
B. Retain, and where necessary update, our current policy on existing open space.
C. Retain, and where necessary update, our current policy on new open space.
D. Retain, and where necessary update, our current policies.

4.21 We consider that RDC should pursue option B. We recognise the value of designated existing open space but the policy must be updated where relevant to properly reflect the most up-to-date evidence of identified local need. This should take account of shifts in patterns of development, take account of new development and changing trends in use of open space, including playing pitches. Crucially the evidence needs to fully assess in quantitative and qualitative terms the quality of all presently designated open spaces across the district, including the Rocheway Site.

4.22 The designated open space at the Site on Rocheway is only used by one youth football team under licence for 10 months of the year. It is not used by any other group at any other point despite its open space designation. If the existing youth football team were to relocate to premises better suited to its requirements, coupled with an emerging RDC open space strategy that enables the re-apportionment of open space where evidenced, this would present an excellent opportunity for the Site to be re-allocated for residential development; in a sustainable location. This would make
best use of underutilised land and would promote sustainable patterns of development. We recognise and would support the reapportionment of designated playing pitches undertaken in full collaboration with Sport England.

Strategic Priority 5: Protecting and Enhancing our Environment

SP5.1 - How do we balance protection of the district's Green Belt that meets the five Green
Belt purposes, against the need to deliver new homes and jobs across the district, and the wider South Essex area?

Our comments on the issue are as follows:

4.23 We note that the Local Plan document identifies the Green Belt as a planning designation that is given to land, which can include both greenfield and brownfield land in areas with potentially varying landscape quality (paragraph 10.5). We also note that the document acknowledges the national commitment to increase the number of new homes (paragraph 10.12). It would be posible to balance these competing objectives by ensuring that a fully up-to-date evidence base is in place to support the new Local Plan. This should include a Green Belt Review of all such designated land within the district, a process which the Framework facilitates.

4.24 The Framework enables the review of Green Belt boundaries through the preparation or review of a Local Plan (paragraph 83). It also advises local planning authorities to take account of the need to promote sustainable patterns of development when drawing up Green Belt boundaries
(paragraph 84). Furthermore, it says that local planning authorities should consider the consequences for sustainable development of channelling development towards urban areas inside the Green Belt boundary, towards towns and villages inset within the Green Belt or towards locations beyond the Green Belt boundary (paragraph 84).
4.25 We consider that the competing objectives of Green Belt protection and delivery of new homes and jobs across the district can be reconciled as part of the new Local Plan process, but to do so requires the right evidence in place; this should include a Green Belt Review.
Our comments on the options:
A. Retain the existing policy on broad Green Belt principles in the Core Strategy.
B. Amend the current Green Belt policy in the Core Strategy.
C. Do not have a policy on the Green Belt.

4.26 We support Option B; Core Strategy Policy GB1 (Green Belt Protection) needs to be updated to take account of and adequately plan for the district's FOAN, as identified through the evidence base. To reconcile the issues of Green Belt protection and the need to deliver growth, the new Local Plan must be accompanied by an integrated approach to evidence base; it must contain a Green Belt Review as part of that process; this has not yet been undertaken by RDC. A Green
Belt Review would enable RDC to assess land parcels against the five Green Belt purposes:
● to check the unrestricted sprawl of large built-up areas;
● to prevent neighbouring towns merging into one another;
● to assist in safeguarding the countryside from encroachment;
● to preserve the setting and special character of historic towns; and
● to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
4.27 Only once the Green Belt Review is complete, RDC may then come to an informed view on how it intends to deliver sustainable patterns of development. Under Framework paragraph 182, this is fundamental to the test of soundness.

5.0 Summary

5.1 These representations have been prepared on behalf of Essex Housing, Essex County Council, in support of the Land south of the former Adult Community Learning Centre, Rocheway, Rochford.
5.2 The site is currently designated as open space in the Local Plan but it is only used by one youth football team, Hambro Colts, who have aspirations to relocate back to a suitable site closer to their original home in Rayleigh. The Colts are in collaboration with ECC to enable them to do so.
Allocation of this underused, yet sustainably located, parcel of land for residential development would enable Rochford District Council to:
● Promote sustainable patterns of development in the New Local Plan; and
● Plan for open space and playing pitch provision in a comprehensive manner, taking account of
emerging evidence of need, housing and employment growth.
5.3 Our review of RDC's evidence base of relevance to open space provision reveals that it needs to be fully updated as part of the new Local Plan process and that its scope needs to include all sites currently designated as open space. The evidence underpinning the adopted Development Plan suggests that this is presently not the case. Only with a comprehensive assessment of such provision could RDC make fully informed, robust and therefore sound planning policy decisions on the District's growth.
5.4 In conclusion we therefore consider that:
● RDC should plan to meet its full objectively assessed housing need across the Plan period, within its own administrative boundaries;
● This should take place via the allocation of large scale extensions to existing higher order settlements in the hierarchy, such as Rochford;
● RDC should undertake a Green Belt Review to assist in the identification of land parcels that do not perform a strong Green Belt function, such as the playing fields south of the former ACL Centre, Rocheway;
● RDC needs to take a comprehensive approach to the assessment of open space provision as part of its Local Plan review. This means considering open space provision alongside housing and employment strategies, considering the re-provision of existing open spaces where this would support sustainable patterns of development, where appropriate. This should be informed by emerging evidence and in consultation with the relevant statutory bodies, including Sport England.
● The Site is considered favourably in the SHELAA in which it is defined as suitable, available and that development would be achievable.