Representations on the Consultative Draft LDF Core Strategy

I refer to the recent and past discussions between myself and Sam Hollingsworth, Nick Barnes and Andrew Meddle of your Department. I confirm that Sam Hollingsworth and I have today agreed that we may submit our formal Representations on the emerging LDF Core Strategy document by way of this emailed note, given that your interactive weblink service for depositing comments seems to be "frozen".

As you may recall, we act for Mr and Mrs David Poole, owners of the Lime House nursery site in Rayleigh, which was the subject of Representations made to the Replacement Local Plan in 2005 - and subsequently considered by the presiding Inspector as Objection Site, RDC ref 153.

Lime House is currently wholly contained within the designated Green Belt. The landholding comprises the remnants of former large-scale horticultural operations, an industrial park with a range of commercial tenants, a Wyevale garden centre outlet and a few houses.

The location of our clients' site wholly within the current designated Green Belt and as part of the "strategic gap" between Rayleigh (western boundary) and Rochford (on the eastern boundary) has implications on the Poole Family's future objectives to bring forward some of the landholding for new housing development, subject to the commitment in perpetuity that the remaining area should be maintained permanently as some form of public park.

We maintain that part of the Poole's landholding would be an excellent location for the development of a limited number of new houses, subject, of course, to the effective "rolling back" of the Green Belt designation from part of the subject site.

We attach, for completeness, a copy of our 2005 Representations, together with illustrative images - and when you come to assess and evaluate the comments raised here, we would refer you to the Representations made at that time. (Please refer to RDC's archive copy of the same).

We appreciate that your Council's approach to the national policy requirement of long term protection of Green Belt boundaries as a key principle of the emerging LDF, is a sound and laudable one.

We maintain however that there may well be opportunities in the Green Belt for some form of development, if well planned - and our illustrative proposals for Lime House reviewed and evaluated the context, character and appearance of the Lime House site as it appears today - comprising a privately owned site with no public access, a retail garden centre and a varied mix of industrial tenants.

If the Lime House site were developed in accordance with the master plan proposals illustrated by my clients, then we would refute the assertion of your Council that any "further reduction" in the width of the GB in this location would consequently be detrimental to the rationale of supporting the Green Belt per se. This view is misguided and fails to take proper account of site specific circumstances.

The Local Plan Inspector's report concluded, in respect of Lime House (site IV of those covered by the "Statement of Sites Subject of a Site Visit") that "...were further land needed for development this site has factors in its favour..."

We acknowledge that precise boundaries will be determined during the Allocations Development Document (DPD) process, but the sweeping negative statement the the Council "...proposes to continue its restrictive suite of policies for development in the Green Belt..." is not qualified, in our view, with a statement explaining that the GB boundaries will be reviewed in detail, in due course.

To that end, we object to the Core Strategy text above, on the basis that the text needs to be expanded to ensure that the prospect of a review of the boundaries is acknowledged and understood.

While the East of England Regional Assembly has confirmed, we understand, that a strategic review of the GB boundary will not be required until after 2021, we would argue that a review ought to take place within the lifetime of the emerging LDF. To that end, we object to the Core Strategy insofar as this is excluded.

We support the Core Strategy statement at 4.2.6 that the Council will consider releasing land where it fails to fulfill Green Belt objectives.

Finally, we also section 4.6 that explains the intended split between settlements and the hierarchy-based approach to allocating land for housing.

We trust these formal representations are clear and helpful - and we would welcome a discussion with your department.

Please provide us with an acknowledgement of receipt of these comments in due course - and keep us informed in general terms about the LDF process and consultation procedures.