Object

New Local Plan: Spatial Options Document 2021

Representation ID: 38456

Received: 03/09/2021

Respondent: Rochford District Residents

Representation Summary:

There is a failure to provide the necessary infrastructure capacity data, higher level strategy for South Essex and Essex and evidence of cooperation with other local Councils.

There is a failing deficient infrastructure of 10's of £ millions which was established by consultants engaged by ECC and referred to as GIF.

The Council has that evidence but has never discussed it in Council and apparently not included that evidence in The Evidence Base or Archive to this NEW Local Plan.

Residents have expressed disappointment that The Council has not publicly challenged the housing target for Green Belt.

Full text:

Rochford District Residents (RDR) is a Registered Political Party and has 6 District Councillors as well as a Councillor on Rayleigh Town Council.

RDR is a Stakeholder Organisation in this Public Consultation. I am Party Leader.

The Government announced changes to the National Planning Policy Framework (NPPF) on Tuesday 20 July. These changes have significant implications on the Rochford District NEW Local Plan.

Rochford District Council is now required to prepare a Local plan detailing 30-year vision. The current Spatial Options Public Consultation proposals (Vision?) are to guide development to only 2040 when it must now be 2055.

This Public Consultation is premature and flawed because the Council has acknowledged that it will not publish full Infrastructure Capacity Data until after this engagement even though each will be available in the short term.

Without correct and up to date information on provision of infrastructure and what that could look like no one can make an informed decision.

A South Essex Plan is being developed by ASELA (a quango comprising all Councils in South Essex) that will set out an overall strategy for development across the whole area. Building on this partnership working approach, a South Essex 2050 Memorandum of Understanding was drawn up in January 2018 which was signed by all partner authorities, including both ECC and Rochford District Council, that sets a joint approach across South Essex to collectively support economic growth and importantly in the context of The Rochford District NEW Local Plan, puts sustainable development across the sub-region at the centre of respective plans.

There is no Reference to GREATER ESSEX GROWTH AND INFRASTRUCTURE FRAMEWORK 2016-2036 (AECOM) and the multi million £ shortfall for Rochford District.

SO WHY HAS RDC PUT FORWARD A SPATIAL OPTIONS PUBLIC CONSULTATION ASKING RESIDENTS TO CHOOSE OR OBJECT TO SITES, VILLAGES AND TOWNS WITHOUT A PLAN FOR SOUTH ESSEX BEING AVAILABLE TO RESIDENTS?

RDC UNDERTOOK AN URBAN CAPACITY SURVEY (UCS) IN 2020 WHICH IDENTIFIES EXISTING SITES FOR AROUND 3000 HOMES BUT THIS IS NOT SPECIFICALLY DRAWN TO THE ATTENTION OF RESIDENTS SUCH THAT THE COUNCIL SHOULD ONLY BE LOOKING FOR NEW SITES AT AROUND 4200. THIS IS A MATERIAL INFORMATION DEFICIT IN THIS PUBLIC CONSULTATION..

Being a largely rural district in nature OUR growing population is exerting more and more pressures on the local highway’s network and this will continue as the population grows. The population is expected to grow to 89,494 by 2025, up from 84,815 back in 2015,an increase of 5.5%. However due to the extent of Green Belt, the District is significantly constrained in how much and where new housing can be located. Therefore, there is a relatively limited amount of policy compliant developable land available in the Rochford area.

SO INSTEAD OF PUTTING EVERY PIECE OF LAND THAT SOMEONE WANTS TO DEVELOP, WHY HASN'T RDC THINNED THIS DOWN TO WHAT IS SUSTAINABLE ON INFRASTRUCTURE AND IF THE TARGET IS NOT THEN CHALLENGE THE TARGET WITH THE GOVERNMENT LIKE SOUTHEND AND BASILDON HAVE DONE?

Residents already recognise that there are strong synergies between Rochford and the surrounding areas of Southend, Castle Point and Basildon, including in relation to transport infrastructure and economic factors. It is likely that planned growth will have an impact on the transport infrastructure in Rochford, as well as beyond on wider Essex infrastructure.

In response to this strong synergy, we understand that consultants have been commissioned by Essex County Council to look into this and to produce fresh evidence in order to understand more deeply the existing transport infrastructure and future development, in line with the Duty to Co-operate requirement guiding Local Plan development.

Contained in this work there will be an assessment of sustainable travel levels in Rochford District and this is composed of three constituent areas; non-motorised users (walking and cycling),buses and rail services.

SO WHY HAS RDC CONSULTED WITHOUT THE ECC EVIDENCE? IF THAT EVIDENCE WAS AVAILABLE THEN THE COUNCIL WOULD HAVE TO CONCLUDE THAT THE 7200 TARGET IS IMPOSSIBLE TO DELIVER WITHOUT CAUSING SIGNIFICANT DAMAGE TO THE DISTRICT.

Each site for potential housing development put forward to Rochford District Council by landowners and developers has been scored by RDC to ascertain the level of accessibility and unsurprisingly those sites with higher scores are predominantly within or proximate to settlements.

The higher scoring sites are predominantly close by to a rail station or town centre where bus facilities are also nearby.

WHY HAS ROCHFORD DISTRICT COUNCIL NOT RECOGNISED THIS IN ITS PUBLIC CONSULTATION ON SPATIAL OPTIONS AND COME UP WITH SOMETHING ELSE BECAUSE SURELY THE EXISTING INFRASTRUCTURE CANNOT COPE WITH THIS HOUSE BUILDING STRATEGY WITHOUT WRECKING OUR LIVES AND OUR BUSINESSES?

SOUTHEND BOROUGH COUNCIL (SBC) IS UNDERSTOOD TO BE PLANNING FOR A NEW SETTLEMENT IN THE FOSSETTS FARM AREA OF 7000 HOUSES. THIS HAS NOT BEEN DRAWN TO THE ATTENTION OF RESIDENTS. A SIGNIFICANT PROPORTION OF THE RESIDUAL 4200 HOMES (after UCS 3000) COULD ADDITIONALLY BE PLACED IN THE SAME AREA BY RDC ON CALL FOR SITES AVAILABILITY WITH A NEW ROAD PROPOSED BY SBC.

Please see the published RDC form for nominating sites which establishes criteria for approval of Nominations to Call for Sites.

Residents have brought to each other's attention that in respect two large sites, CSF045 (Belchamps) and CS194 (Rectory Road, Hawkwell) it is alleged that landowners do not wish to sell. In respect of CFS045 a Councillor has an email from Trustees.

On that basis neither should be under consideration unless RDC has nominated the sites itself as candidates for Compulsory Purchase. There is no evidence of the latter.

One wonders if there are any more sites that should not have been approved by RDC in accordance with its published criteria and policy.

A Conservative Councillor, a Member of The Planning Policy Committee has written in public about this public consultation " IF THERE IS NO LOCAL PLAN IT WOULD BE A FREE-FOR-ALL FOR DEVELOPERS TO BUY UP LAND WITHOUT HAVING TO GET PLANNING APPROVAL FROM THE LOCAL AUTHORITY."

That claim was also made throughout the Core Strategy.

Did that happen in Castle Point? Unarguably - NO.

Residents have expressed through a Petition their disappointment that The Council has not publicly challenged the housing target imposed by The Government and gained a reduction given that most of the target will be on green belt. Southend and Basildon Councils are challenging The Government. Castle Point Council has failed to deliver any local plan over the last 10 years or so but RDC has delivered several thousand homes against the background of a failing deficient infrastructure of 10's of £ millions which was established by consultants engaged by ECC and referred to as GIF. The Council has that evidence but has never discussed it in Council and apparently not included that evidence in The Evidence Base or Archive to this NEW Local Plan. This is unacceptable.

Residents are finding it very difficult to engage with this Public Consultation because it is unclear what they are asked to address; Strategy or Individual sites? The Volume of questions and the complexity of the online presentation was evidently not reviewed and tested by The Council before The Public Consultation was approved.

There is a failure to provide the necessary infrastructure capacity data, higher level strategy for South Essex and Essex and evidence of cooperation with other local Councils.