1.0 Introduction
1.1 These representations have been prepared on behalf of Essex Housing, Essex County Council’s in-house development arm, in support of the release of Land to the south of the former Adult Community Learning Centre (ACL Centre), Rocheway, Rochford (hereby referred to as the “Site” or the “Rocheway Site”) from the Green Belt and allocation for residential development.
1.2 The site is owned by Essex County Council (ECC) and is currently designated as existing open space in the adopted Local Plan. The Site has been used under license for 10 months of the year by Hambro Colts FC, a local youth football team. However, at the end of the 2020/1 football season the Colts relocated to a different ground in Hullbridge, which means that the Rocheway
Site is now without a community sports user and is not open for general public use.
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.
1.4 In this context, we therefore consider that the site has excellent residential redevelopment potential taking account of its sustainable location within walking and cycling 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.
1.5 Coupled with this, we propose that the loss of the existing vacant playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location

2.0 Background to 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.
2.2 The Site is formed of playing fields to the south of the former Adult Community Learning Centre site (“ACL Centre”), constructed in the mid-1930s as a school which was later converted into its use as an ACL Centre. 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 open 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.

Planning History
2.4 The ACL Centre site directly to the north of the Site is subject to a planning consent, granted under 17/00102/FUL in March 2018 by Rochford District Council, for the redevelopment comprising a 60 dwelling Independent Living Residential Care Home (Class C2) and 14 dwelling houses (Class C3). The development is being implemented.
2.5 An extract from the approved layout plan is shown below. It includes a proposed spine road that would provide access to the dwellings to the west and the Independent Living scheme to the east. The access road extends through the site to its southern boundary with the playing fields.

[see document for image]

2.6 The development is phased to enable delivery of the 14 residential dwellings prior to the delivery of the C2 scheme. As part of this approach it was necessary for a displacement car park facility to be provided for the playing fields so that the future use of the playing fields would not be prejudiced. Therefore, application 17/00807/FUL was submitted to and in November 2017
approved by Rochford District Council for the provision of a car park and area for demountable buildings for use as a changing room to serve the playing field. This planning permission is subject to conditions, amongst others, requiring that:
● The car park area in its entirety should be constructed and operational prior to the commencement of the Phase 2 development on the former ACL Centre site.
● The demountable buildings forming the changing room and W.C facilities should be provided and made available for use prior to the beneficial use of the car park

2.8 From the above it is possible to confirm that the delivery of the displacement car park and changing facilities on the playing field land is triggered by the commencement of the Phase 2 part of the development on the ACL site.
2.9 The Phase 2 part of the development is yet to commence. The facilities consented under 17/00807/FUL are therefore yet to be delivered onsite.

3.0 Responses to the Spatial Options Questionnaire
Hierarchy of Settlements
Question 5 – Do you agree with the Settlement Hierarchy presented?
If not, what changes do you think are required?
3.1 Yes, we agree with the Settlement Hierarchy. It suitably recognises the availability of services and connections within each of the settlements and appropriately categorises them into tiers based on how the towns and villages perform in relation to both sustainability and employment.
3.2 Rochford is identified as a Tier 2 settlement and we consider this is appropriate in light of the range of services and community facilities it offers, and its overall sustainability. It would therefore be appropriate for a commensurate level of the District’s growth to be directed to Rochford town.
Spatial Strategy Options
Question 6 – Which of the identified strategy options do you consider should be taken forward in the Plan?
3.3 As a general comment, we note that the Council correctly identifies that the minimum number of homes it should be planning for over a 20-year period is the 7,200 homes arrived at using the standard method. However, this is the minimum number of homes that needs to be planned for and the Council will need to carefully consider whether a higher housing requirement is
necessary to support economic growth, infrastructure improvements or address the needs arising from neighbouring authorities.
3.4 In particular it will be important for the Council to work closely with Southend Borough Council (SBC) which has a minimum housing requirement of 1,180 new homes per annum using the standard method. As the Council will be aware, SBC set out in its latest consultation that even
with Green Belt release, it is only able to deliver around 20,000 new homes to meet its total requirement over the plan period of 23,620 homes. It is clear that SBC will need support from Rochford and other neighbouring boroughs to meet its housing needs in full. Rochford District Council should therefore plan for a level of housing growth that meets both their own needs as
well as the unmet needs of SBC.
Strategy Option 1 – Urban Intensification – we do not support this option.
3.5 In light of our comments above, this option must be ruled out as it fails to meet the needs of Rochford, let alone neighbouring areas.
3.6 This option alone would not provide the necessary quantum of land to meet the identified housing need. This strategy requires the least use of greenfield land and, by definition, would involve no further release of land from the Metropolitan Green Belt. We recognise that focusing purely on brownfield and under-utilised land provides opportunities for infill development, however this does
not allow for the necessary larger scale development options, would fail to deliver new infrastructure, and is not a sufficient option to provide the unit numbers and infrastructure Rochford requires.
Strategy Option 2 - Urban Extensions – we support option 2a insofar as it is relevant to the growth of Rochford town.
3.7 Option two is split into two sections. Section 2a focuses urban extensions in main towns. Option
2b looks to deliver urban extensions dispersed to settlements based on hierarchy.
3.8 Option 2 provides significantly better opportunities to deliver the housing and infrastructure
targets than Option 1. Option 2a ensures development is focused in sustainable locations where transport connections are established and sustainable to support the development, including Rochford town. New urban extensions focussed on the main towns in Option 2a gives the opportunity to provide additional services and facilities and provide improvements to existing
infrastructure to support the new development in addition to the existing communities.
3.9 Insofar as this option is relevant to Rochford town, we support the proposals in Option 2a to direct growth to suitable deliverable sites in and on the edge of Rochford.
3.10 We would be unsupportive of Option 2b if it would result in large scale development being directed to less sustainable locations in the district, such as the Tier 3 settlements, at the expense of suitable alternative locations in higher tier settlements such as Rochford town, including the Site at Rocheway. This would not be justified and a Plan based on this approach would therefore be unsound.
Strategy Option 3 - Concentrated Growth – we do not support this option.
3.11 A strategy option that seeks to deliver the whole local plan requirement for housing in a concentrated development (or concentrated developments) runs the very serious risk of being undeliverable. Too often local plans focus allocations on a small number of large strategic sites that inevitably come forward later in the plan period, or worse, fail at Examination. Whilst such
sites can be an important part of housing supply, their allocation should not be to the detriment of deliverable small and medium sized sites, such as the Site at Rocheway.
3.12 A clear example of the risks of concentrated growth is the North Essex Authorities, where three new Garden Communities were proposed to deliver a proportion of housing across three local authorities later into the Plan period. In 2020, following the Examination, the Inspector concluded that two of the three garden communities were not viable and therefore not deliverable, leaving the authorities without 37,500 planned new homes for the Plan period and beyond.
3.13 Another current local example of this is in Maldon, whose Local Plan (adopted in 2017) places a
substantive reliance on the large-scale Garden Suburbs. The latest 5-year housing land supply statement confirms that the supply of housing arising from these allocations is falling below the previously anticipated trajectories. This means that the Council cannot currently demonstrate a 5-year supply of housing.
3.14 We therefore consider that this option runs the very serious risk of non-delivery and is unlikely to be capable of being found sound at Examination.
Strategy Option 4 – Balanced Combination – We support this option insofar as it relates to the allocation of suitable available Greenfield sites on the edge of Rochford town.
3.15 Option 4 provides a balanced approach, allocating a variety of sites both in terms of size and location which would have far greater potential to deliver a wide mix of housing types and style whilst also ensuring homes come forward consistently across the whole Plan period.
3.16 This Option also increases the opportunities for small and medium sized housebuilders to deliver
homes in the District. It provides good opportunities for sustainable growth within Rochford with an appropriate scale of development based on the settlement hierarchy. This option is not restrictive on the location or scale of development.
3.17 Based on the response set out above we are supportive of Options 2a or 4 insofar as they direct
proportionate levels of growth to the higher order settlements in the hierarchy, including Rochford
town. Our support for either of these two options is conditional on the proposed allocation of the
Rocheway Site, which is suitable, deliverable and sustainably located.
Open Spaces and Recreation
3.18 Our responses to Open Spaces and Recreation questions are in the context of the current designation of the Rocheway Site in RDC’s Allocations Plan as an area of Existing Open Space.
Question 38 – With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
3.19 We support Option 3 as suggested by RDC which proposes to “embed a hierarchy approach into policy that seeks to prioritise and direct investment to the most important recreational facilities, including potential hub sites and key centres”. This would ensure that the funding and resource is appropriately directed to the most important, larger, locations where they are needed the most, to enable the provision and maintenance of higher quality facilities in the district in areas of high
utilisation. Coupled with this, we would support the rationalisation of low value playing pitch sites
that are rarely used and/or are without appropriate ancillary facilities, such as the Rocheway Site. As the landowner of the Rocheway Site, Essex County Council is also prepared to make a financial contribution towards the creation, improvement of, or extension to an existing multi-pitch hub site or key centre as identified in the Local Plan, to ensure that there is no net loss of pitch space.
3.20 We would therefore support the review of open spaces which do not feature within the list of hub sites and key centres, including those that are rarely used and without appropriate ancillary facilities, so that the case for rationalisation can be suitably planned for in the event such a course of action is deemed appropriate as part of the wider Local Plan proposals.
3.21 Land to the south of the former ACL Centre, Rocheway, is currently unused by the community
following its vacation by the Hambro Colts football club in 2021. This is not picked up in RDC’s Playing Pitch Strategy, which was published in 2018 and is now already three years old. The Hambro Colts were the sole users of the Site but now that it is vacant, following their move to alternative grounds in Hullbridge, the future of the Rocheway Site is uncertain. It would therefore be inappropriate for the Rocheway Site to be identified as a facility of “local importance” until an update to the Playing Pitch Strategy is undertaken in line with its own recommendation1 , which identifies that “without any form of review and update within this time period [three years] it would be difficult to make the case that the supply and demand information and assessment work is
sufficiently robust.”
3.22 The Rocheway Site is comprised of grass pitches and, in an era of challenging public sector budgets, their ongoing maintenance without a user in the community is an unnecessary burden.
This is compounded by the fact that local authorities, including Essex County Council as landowner of the Rocheway Site, are not eligible for Grass Maintenance Fund grants2
.
3.23 The Playing Pitch Strategy acknowledges on page 7 that “as the resources to improve grass pitches are limited, an increase in 3G provision could help to reduce grass pitch shortfalls through the transfer of play....”. The Local Football Facility Plan (LFFP) for Rochford, [repared by Knight, Kavanagh and Page (KKP) with support from local partners including The FA, Essex County FA,
Football Foundation, Rochford District Council, Sport England and Active Essex, was published in 2018. The purpose of the LFFP is to enable investment in football facilities to be accurately targeted. The LFFP is the go-to document for football facility investment in Rochford and aims to:
● create a network of 3G Artificial Turf Pitches;
● improve grass pitches;
● develop and improve changing rooms and pavilions; and
● develop small-sided football facilities, particularly for informal football.
3.24 The LFFP identifies eight priority projects for potential investment. Prioritisation has been
informed by local partners with the rationale of selecting sites in the poorest condition, that were most well utilised or of strategic focus to improve Local Authority pitches. These include:
● John Fisher, Rayleigh;
● Ashingdon Recreation Ground;
● Fairview Playing Field, Rayleigh;
● Great Wakering Recreation Ground;
● The Warren, Rawreth;
● Hullbridge Sports Association;
● Apex Sports Ground, Hockley; and
● Rochford Recreation Ground.
3.25 It should be noted that the Rocheway Site does not feature as a target for future investment within the LFFP.
3.26 In line with the conclusions of the Playing Pitch Strategy, we consider that where there are low value playing pitch sites that are rarely used and/or are without appropriate ancillary facilities, such as the Rocheway Site, they should be rationalised, coupled with a contribution towards the creation, improvement of, or extension to an existing multi-pitch hub site or key centre as identified in the Local Plan.
Question 40 – Are the listed potential hub site and key centres the
right ones? Are there other locations that we should be considering?
3.27 In line with our response to Question 38 above – yes, we agree that the hub sites and key centres referred to in the table are correct. We do not consider that “all other facilities” should be identified as being of local importance until the 2018 Playing Pitch Strategy has been updated to reflect changes of circumstance on sites that have occurred in the past three-year period, in line
with its own recommendations. This specifically affects the Rocheway Site, which is no longer with a user in the community and should not automatically be subject to continued designation as open space in light of this change in circumstance.
Question 41 – With reference to your preferred Strategy Option, are there opportunities for growth to help deliver improvements to open space or sport facility accessibility or provision?
3.28 Yes, there is an opportunity to allocate the Rocheway Site for residential development, which is
now without a community sports user, to help deliver improvements to sport facility provision onthe hub sites and/or key centres in Rochford. This approach would deliver tangible planning benefits because the Rocheway Site is in a highly sustainable location near to the core of
Rochford town centre. It would therefore be extremely well suited to residential development.
Coupled with this, financial contributions collected as a result of the allocation and development of the Site could be directly used to help fund (and expand upon the scope of) the planned improvements to hub sites and key centres as identified in the Local Football Facility Plan for Rochford. This would provide a clear planning benefit that would accord with Sport England guidance and NPPF paragraph 99, which requires the “loss from the development to be replaced by equivalent or better provision in terms of quality and quantity in a suitable location”.
3.29 For ease of reference an extract from Figure 45 of the consultation document showing the sites
put forward for the development in and around Rochford is shown below.
[see document for image]
3.30 It may be seen that the Site is identified as an area of “Other Open Space”. Without a user of the playing pitches on the Site, it is of no benefit to the community in this retained use as it is not open for public use. It should therefore be re-allocated for residential development, as part of a wider strategy involving contributions from its development to help fund improvements to other
nearby sports facilities.
Question 42 – Are there particular open spaces that we should be
protecting or improving?
3.31 Yes, we consider that Millview Meadows in Rochford should continue to be protected and identified for improved accessibility, on the condition that an allocation for residential development of the adjacent Rocheway Site is key to unlocking these improvements.
3.32 Millview Meadows is a 4.5 hectare park located directly adjacent to the west of the Rocheway Site. The park is identified on the satellite image below
3.33 The most up-to-date evidence base that audits the quality of this park is RDC’s 2009 Open Space Study. It is identified as an “Amenity Greenspace” with the following description:
“Poor accessibility (situated between houses), no information sign identifying the area, pathway around open space, grass area with planting, some seating and bins provided, broken fence to rear of playing field, no lighting”.
3.34 The only formal means of access to Millview Meadows is via a narrow alley between two residential properties at Spindle Beams to the west, as correctly described in the Study. Access is convoluted and tortuous for any visitor who does not live in the adjacent estate.
3.35 The accessibility of Millview Meadows has not increased since 2009 despite its relative quality and maintenance staying the same. In light of its size and proximity to existing and future potential residents in the core of Rochford town, Millview Meadows is severely let down by its lack of formalised access point(s).
3.36 RDC notes that feedback from the Issues & Options consultation was clear about the importance of residents having access to well-maintained and accessible open and green spaces. The Rocheway Site offers the significant potential to improve access to this underused and underappreciated local park. But access improvements that maximise the benefit of this existing
local resource can only be delivered as part of a masterplanned approach involving the residential development of the adjacent Rocheway Site.

Planning for Complete Communities
Question 57a - Do you agree with our vision for Rochford and Ashingdon? Is there anything you feel is missing?
3.37 Yes, we agree with RDC’s vision for Rochford and Ashingdon. In particular, we note that the Vision Statement says that “its town centre should be reimagined to become a more sustainable and vibrant space whilst retaining its historic character. It should make the most of its proximity to key employment sites and London Southend Airport to significantly grow its economic potential and the range of jobs it provides for.”
3.38 The Vision is appropriate given the Tier 2 status of these two settlements. The best way of ensuring that the Vision is realised is by allocating suitable available deliverable sites for residential development on the edge of Rochford. Land south of the former ACL Centre,
Rocheway is capable of delivering residential development that would maintain the town centre’s
vibrancy and make the most of its proximity to key local employment sites.
Question 57b - With reference to Figure 45 and your preferred Strategy Option, do you think any of the promoted sites should be made available for any of the following uses? How could that improve the completeness of Rochford and Ashingdon?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare,
allotments, other]
4. Other
3.39 We consider that promoted site CFS050 should be allocated for housing. CFS050 is the Land south of the former ACL Centre, Rocheway.
3.40 The proposed development is market led residential housing. As CFS050 is a greenfield site, it is
capable of accommodating a policy compliant quota of affordable housing and infrastructure provision. As the Site’s promoter is also the landowner, Essex County Council, we can ensure that, if allocated, the loss of the existing vacant playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location, in
accordance with Sport England guidance.
3.41 There are few comparable sites in Rochford which offer such an opportunity to maximise the potential to enhance the completeness of the town. Land south of the former ACL Centre would enhance the completeness of Rochford
3.42 The NPPF states at paragraph 142 that when drawing up Green Belt boundaries, the need to
promote sustainable patterns of development should be taken into account. At paragraph 105 the NPPF states that “the planning system should actively manage patterns of growth in support of [sustainable transport] objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine
choice of transport modes”.
3.43 Allocation of this site for development would substantially improve the completeness of Rochford
because it is located within a highly accessible location very close to the town centre. This is perfectly encapsulated within the Walkability Map extract below, which shows that the Site is within the only part of the town where the highest scoring walking completeness area (shown by the yellow shading) overlaps with the open countryside to the east. A lack of any residential
development in this location would fail to capitalise on this excellent location which can help meet
RDC’s strategic objectives

[see document for image]

3.44 Further residential development to the eastern side of the town centre would capitalise on this location’s high walkability and access to services/facilities which, in recent decades, have not been realised as the town has essentially grown in other directions primarily to the north and west, with substantially lower walkability than the land south of the ACL Centre site at Rocheway.

3.45 Coupled with the above, the Site is only 800 metres (or a 10-minute walk) from Rochford train station, which provides regular mainline services to Southend Victoria, Southend Airport and London.
3.46 The Site is also within cycling distance of the district’s major employment areas including Southend Airport, Purdeys Industrial Estate, Rochford Business Park and the emerging Saxon Business Park.
3.47 Further development to the east, specifically at Site CFS050, would therefore plainly improve the
completeness of Rochford.
Land south of the former ACL Centre is suitable
3.48 The Site is a suitable location for development, is free from technical constraints and is unencumbered. To justify this assertion, we have extracted the Appraisal for the CFS050 site from RDC’s Site Appraisal paper as contained within the evidence base – see below.

[see document for image]

3.49 Against the assessment criteria in the Site Appraisal paper, site CFS050 scores very well. Most of its assessed criteria fall into the green (i.e. performing well/unconstrained), scoring either 4 or 5 out of a possible 5 points in respect of its suitability. The Site is noted as being deliverable for housing, subject to policy. We agree with this assessment, as there are no overriding constraints to development. In this respect it will be noted that the Site performs well against the criteria relating to ecology, resource, air quality, site conditions, access to facilities and Green Belt impact.
3.50 In respect of Green Belt, we note the findings of the Green Belt Study (Assessed under parcel AA120) and propose that the existing Green Belt boundary is re-drawn along the Site’s existing eastern boundary, which is formed of mature trees and hedgerow and could be strengthened as part of a scheme’s masterplan, so that the Site is included within a revised development
boundary for Rochford, in accordance with NPPF paragraph 143f).
3.51 In only one case does the Appraisal attribute a low score of 1 out of 5 – relating to “access to bus services”. Allied to this it should be noted that the Site scores 4 out of 5 against the “distance to bus services” criterion. We agree with this as the nearest bus stops to the Site are
less than 400 metres away, on East Street/North Street. But we do not agree that the Site has poor access to bus services. The extract from the Essex Bus Map3 below shows that the numbers 7 and 8 buses, frequent services at every 15 minutes, pass through East Street/North
Street on their way to local destinations including Rayleigh, Hockley, Southend Airport, central Southend and Shoeburyness, amongst other local villages. School services also offer transport to secondary schools in Rayleigh and Southend.

[see document for image]

3.52 Based on these observations, when assessed against the Appraisal’s methodology, the “access to bus services” score should instead be at least 3 out of 5.
3.53 In two cases the Appraisal attributes a low score of 2 out of 5 – relating to heritage (built assets)
and site conditions and hazards (water).
3.54 In respect of the Built Heritage, RDC’s Conservation Area Appraisal & Management Plan shows
that the nearest designated heritage assets (Grade II listed 26 and 28 East Street and the
Rochford Conservation Area boundary) are approximately 200 metres from the Site. It should be
noted that the development of the former ACL centre (consented under 17/00102/FUL) directly to
the north, there was no suggestion that the scheme would cause any harm to heritage assets.
According to the methodology, we therefore consider that the Site should be attributed a score of 3 out of 5 on the basis that, at the very least, any impacts could be mitigated through scheme design.

3.55 In respect of site conditions and hazards (water), the Appraisal attributes the Site a score of 2, which is defined in the methodology as “containing water supply apparatus or easements”. It should be noted that the development of the adjacent former ACL centre, which historically formed part of the same site as CFS050, is currently being delivered onsite. This means that the
presence of any water apparatus should not present an insurmountable constraint to development and would be accounted for as part of the design.
3.56 Taking account of the above, we consider that the Site is entirely suitable for development.
Land south of the former ACL Centre is available and deliverable
3.57 Land south of the former ACL Centre is in single public sector ownership and is wholly within the
control of Essex County Council. Essex Housing on behalf of Essex County Council has a growing track record of securing viable planning permissions for and then delivering sites for new housing across the County, including sites at Goldlay Gardens and Moulsham Lodge in Chelmsford, Norton Road in Ingatestone, the former County Hospital in Colchester, and the former ACL Centre at Rocheway adjacent to the north of this Site, which is currently being delivered. As the Site’s promoter is also the landowner, Essex County Council, it can be ensuredthat the loss of the existing underutilised and poor-quality playing pitch space can be compensated for through better provision in terms of quantity and quality in an alternative suitable location, in accordance with Sport England guidance.
Increasing the accessibility of Millview Meadows

3.58 As set out above, the release of the Rocheway Site from the Green Belt and allocation for residential development as part of the new Local Plan brings with it the opportunity to vastly enhance the accessibility to Millview Meadows, the public park to adjacent to the west of the Site which suffers from very poor accessibility despite being open to the public. It should be possible
to create new pedestrian access points into the park as part of a masterplanned new development on the Rocheway Site.
Enhancing local sports facilities
3.59 As set out under the relevant chapter heading above, the development of the Rocheway Site
offers the opportunity to direct financial contributions towards the substantive improvement of other local sports hub sites and/or key centres identified in the Local Plan and through the supporting evidence base, to ensure that there is no net loss of pitch space