Object

Representation ID: 40718

Received: 10/08/2021

Respondent: Mr John Surgett

1. It is well known that the Government has set targets for moving to zero carbon housing in this country by 2025. This was being realised in 3 steps firstly in 2010 a 25% improvement was made in the energy/carbon performance outlined in the Building Regulations then secondly in 2013 a 44% improvement was made and finally in 2025 we need to achieve zero carbon. This means that energy needed for heating lighting hot water and all electrical appliances in the house such as TVs and computers must be attained from renewable sources ie no burning of fossil fuels.
The main source of climate change is the human influence for emission of greenhouse gases. The UK produced more than 365 million tonnes of carbon dioxide in 2019. Almost half of these emissions were accounted for in energy use in buildings and more than a quarter came from the energy we use to heat light and run our homes and this does not include the massive amount of emissions produced by manufacturers in the production of most of the current building materials.
A draft Planning Policy Statement was published on climate change which expects Planning strategies to be examined in providing for new homes and it expects that all Local Planning Authorities should have an input in delivering the Governments climate change programme in facilitating any provision of new homes and infrastructure. Local Authorities therefore have a responsibility in leading their communities in dealing with climate change. Therefore the subject of housing supply needs to be looked at alongside the reduction of carbon emissions surely the best way of reducing these emissions is to limit the number of new homes being built and not by increasing the numbers year on year.
2. The NPPF states that developments should be directed away from areas of highest risk of flooding with developments not to be allocated if there are reasonably available sites appropriate for development in areas with a lower probability of flooding. Where development is necessary it should be safe without increasing levels of flood elsewhere.
South Essex Surface Water Management Plan statement includes consideration of flooding from sewers drains groundwater and runoff from land small watercourses /ditches that occurs from heavy rainfall. It appears that none of this was taken into account in the current development in Hullbridge the southern end of which is in the flood plain and should not have been built on. What was originally proposed on this site was the provision of underground attenuation tanks this was subsequently changed to attenuation basins together with an additional basin in the centre of the site which eventually discharges into an existing watercourse in Watery Lane. these basins will no doubt be full for the majority of time especially when calculated for a min of 1 in 1 year annual probability storm together with the amount of additional surface water runoff due to the extra impermeable surfaces from this development especially as DEFRA have now bottled out on introducing Sustainable Drainage Systems SUDS compulsory legislation. Baseline Review for Climate Change Adaption states that in addition to flood risk from tidal sources fluvial systems also pose a risk to parts of the district. The impermeable underlying geology and seasonable wet deep clay soils in the western parts of the district leads to rapid runoff of surface water into local watercourses which inevitably will only get worse with climate change.
3. In connection with Climate Change Mitigation it is stated that it has been demonstrated that Rochford District has a lower per capita transport emissions when compared to Essex as a whole yet BBC Look East recently reported that dangerous levels of nitrous oxide caused by diesel fumes are being found in and around the Rayleigh area. Also in a recent national news report it stated that record amounts of carbon dioxide have been recorded and is on the rise the highest in the past 4 years.
So why are we contemplating building more and more houses on Green Belt land creating more emissions and more traffic adding to this major problem.
4. Regarding Landscape and Historic Environment the NPPF states that Local Authorities planning system should recognise that heritage assets are an irreplaceable resource and preserve them in a manner appropriate to their significance. Again this was totally ignored for the current development striding Rawreth and Hullbridge. As stated in the Archaeological Assessment for this development the Local Authorities archaeological advisor at Essex County Council required archaeological mitigation measures in advance of any development impacts occurring and noted that the historical field boundaries within the site comprise undesignated heritage assets of local significance and recommended that the orientation and preservation of these historic boundaries should be encouraged within the detail of the development proposals. This has not been incorporated within this scheme especially the Ward Boundary between Rawreth and Hullbridge. It is also stated that any new development has potential to lead to incremental changes in landscape and townscape character and quality in and around the district. This includes through inappropriate design and layout.
But once again RDC granted planning Approval for the Hullbridge site which indicated the majority of the future dwellings being 2.5/3storey in an area consisting of mainly bungalows and chalet bungalows.
5. In connection with Population and Communities. Local Authorities should/must ensure that there is sufficient choice of school places which is of great importance. Yet recently at a local workshop meeting in Hullbridge it was pointed out that the local primary school had a few available spaces these children would eventually have to attend the surrounding secondary schools who have all confirmed that they are over subscribed. But according to RDC because these are not actually located in Hullbridge this is not an issue.
6. Regarding Safety Rochford is maintaining that it has a relatively low crime rate and is one of the lowest in Essex. At a recent meeting with the police at the Rochford Parish Rooms the majority of the large number of people who attended all had the same complaint which was that most crimes are not being reported due to the fact that there is hardly any or no response from the police who stated that this was mainly due to severe cutbacks. So the statement made by Rochford cannot be taken seriously.
7. In connection with the Green Belt the Government has stated that the fundamental aim of the Green Belt policy is to prevent urban sprawl by keeping land permanently open the essential characteristics of Green Belts are their openness and their permanence. The majority of this Districts land mass is designated as Green Belt and should only be released under exceptional circumstances. When we recently asked a RDC Planning Officer what is meant by exceptional circumstances he confirmed that this has not been defined. The Green Belt is supposed to serve five purposes 1. To check the unrestricted sprawl of large built up areas 2. To prevent neighbouring towns/villages merging into one 3. To assist in safeguarding the countryside from encroachment 4. To preserve the setting and special character of historic towns/villages 5. To assist in urban in urban regeneration by encouraging the recycling of derelict and
other urban land
RDC have already released large areas of Green Belt for development all over the district. With regard to the New Local Plan the submitted map for the local Hullbridge area shows the majority of the proposed larger sites are Green Belt with the exception of a portion of CFS 100 Brownfield Site being a lorry/heavy goods breakers yard which is obviously highly contaminated.
8. Regarding Health the NPPF states that health and well-being and health infrastructure should be considered in local plans and the NPPG states that Local Planning Authorities should ensure that health and well-being and health infrastructure are considered in local and neighbourhood plans and in planning decision making.
But once again this has been totally ignored by RDC on the western side of the current Hullbridge development site there are three existing Telecommunication Masts.
According to the Guide to Mobile Phone Masts. Independent scientists and doctors these are a major health hazard. Cancer clusters have been found around Mobile Phone Masts up to 400metres from a mast which in this case encompasses the majority of these new dwellings. People living near each other and close to a mast have ended up with rare cancers at the same time as each other. This has been the case in Devon Lincolnshire and Staffordshire. Many doctors are now so concerned that they have all signed petitions to demand that Governments take the health concerns over Mobile Phone Masts seriously.
Forecasts suggest that the number of people aged 85 and over in the District will increase in the future. An ageing population has the potential to increase pressures on healthcare services in the District. We do not agree that any future developments will not as stated will not result in increased pressure on existing primarary healthcare facilities. As stated by the NHS any future developments are likely to have an impact on the NHS funding program and these need to be fully addressed not by just making financial contributions only which in itself does not solve the shortage of doctors nurses dentists hospital beds and appointment times.

As stated above it is shown that RDC have not addressed previously any of the alternatives in terms of major impacts and sustainability especially with the current major development in Hullbridge and we therefore have no confidence that this will change in any future emerging New Local Plan for this District.
RDC need to take into account further carbon emissions overcrowding traffic congestion flooding and further drains on the existing infrastructure.

Listed below are some key issues that we feel need to be addressed in any New Local Plan A. Infrastructure is paramount to all Planning Applications including the provision of all services especially the condition of the existing road network being capable of accepting the increase in traffic numbers. Just providing a new roundabout to provide access to any new large development should not be taken as providing adequate infrastructure as this does not reduce the amount of traffic.
B. The density for outer suburbs should be as stated 20–40 dph with very few apartments and more bungalows. Local Authorities are currently using 30-60 dph which causes more overlooking/overcrowding more 3 storey dwellings and less amenity space. Density should be allocated for actual dwelling plots and should not include open space play areas access roads and space required for attenuation basins which should all be omitted from overall site areas.
C. Approval for development sites that merge with neighbouring villages/parishes especially striding across Ward Boundaries should not be allowed.
D. Brownfield sites are being totally ignored and Local Authorities should not be allowed to re -designate Green Belt without at least applying for a Change of Use in order to for local residents to submit their valid objections.
E. Developers should not be allowed to provide financial contributions for off site provision instead of providing the required numbers of affordable homes.
F. All Local Authorities should ensure that all Planning Applications take into account current Building Regulations for example the style of windows to comply with means of escape ventilation requirements and the use of certain types of external cladding materials G. A minimum number of Lifetime Homes with full wheelchair accessibility should be required to all new developments.
H. All developments should have all required energy generated by on-site renewable and low carbon sources.
I. Not enough amenity space is provided for apartment complexes. Drying areas and bin storage should not be included as part of the amenity space together with balcony areas. Balconies should not be allowed to provide for additional storage and clothes drying.
J. DEFRA should reintroduce Sustainable Drainage Systems SUDs as compulsory legislation to stop flooding.
K. Transport carbon emissions should be taken into account in and around the local areas.
L. Provision of youth facilities should not be by providing football pitches alone.
M. Developers should not be allowed to remove trees and hedgerows prior to the granting of Planning Consent.
N. All developments should be made to comply with their Local Design Guide especially car parking arrangements.
O. All developments should comply with Secure by Design with no back alleys.
P. No Planning Approvals should be granted for any housing development to be constructed near or adjacent to existing Telecommunication Masts.
Q. The awarding of the New Homes Bonus issued to Local Authorities by Government should not be a reason for granting Planning Permission.