Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 40726

Received: 05/10/2021

Respondent: Mr G Marshall

Agent: Strutt & Parker LLP

Representation Summary:

It is considered that the allocation of additional sites for development gives rise to the potential to make significant enhancements to green and blue infrastructure.
For example, in respect of proposals for Peggle Meadow, Rochford, and as set out in the Vision Document that accompanies these representations, green and blue
infrastructure enhancements are proposed.

Full text:

Introduction
1.1 These representations are submitted to the Rochford New Local Plan Spatial Options (RLPSO) on behalf of Mr G Marshall and in relation to Peggle Meadow, Rochford (‘the Site’).
1.2 The Site has previously been submitted in response to the Council’s the Call for Sites, and is reference CS095 in the Council’s plan-making process.
1.3 Representations were submitted to the Local Plan Issues and Options consultation in 2018 to further promote the allocation of the Site to help meet development needs
through a sustainable, proportionate extension to the south of Rochford, capable of delivering numerous benefits.
1.4 This representation should be read alongside the Vision Document that has been prepared in respect of the development of the Site, and which accompanies the
representations at Appendix A.
2.0 Response to Local Plan Spatial Options Question 4
Q4. Do you agree with the strategic priorities and objectives we have identified?
Is there anything missing from the strategic priorities or objectives that you feel needs to be included?
2.1 We consider that Strategic Objective 1 could be clearer that the provision of homes to meet local needs entails providing housing close to existing communities. As currently drafted, it could be inferred that the priority is working with neighbouring authorities, rather than trying to meet local housing needs and support existing communities within the District per se.
2.2 Providing homes through extensions to existing settlements ensures local residents can remain within their local community and close to family, friends, and other informal social networks that form an important part of everyday life. It also ensures greater choice for
existing residents, and reduce the risk that existing members of the community may have to move elsewhere due to a lack of suitable housing.
2.3 We suggest that Strategic Objective 1 should be amended to:
To facilitate the delivery of sufficient, high quality and sustainable homes to meet local community needs, through providing homes close to existing communities, utilising previously developed land and working with neighbouring authorities if required.
2.4 In addition, we suggest that objectives of the Local Plan should include to improve the affordability of housing for people of Rochford District.
2.5 The RLPSO notes (page 12) that:
“The affordability of all housing is an issue constraining the ability for residents to afford homes in the area. The average house costs around ten times to average
annual income of a Rochford resident, which has increased significantly from around five times 20 years ago and is significantly above the national average”
2.6 We agree that affordability of housing is a very real local concern, and an issue the Rochford Local Plan must seek to address. The most recent data available1
reports that the median house price in the District is 11.57 times the median gross annual workplacebased earnings (‘the affordability ratio’).
2.7 The affordability of housing has worsened significantly in recent years – and to a much greater extent than the national average.
2.8 In 2000, the affordability ratio for the District was 5.08 – only slightly worse than the national average of 4.13. By 2020, the national affordability ratio had increased to 7.69
– significantly below the District’s 11.57.
2.9 Additionally, and whilst empirical data is currently limited, the longer term impact on housing demand resulting from the Covid-19 pandemic may well impact significantly on Rochford’s housing market and affordability of homes for local people. Early indications
are that there has already been an increased desire to move from more to less urban areas, driven by what has been dubbed the ‘race for space’ – the desire for homes with larger garden areas and home offices, better access to open space, and within less densely populated areas.
2.10 At the same time, the situation has forced many employers (although not within all sectors) to adapt and enable home-working. Whilst it is largely anticipated that there will be a degree of return to office-working, it is expected that the need for employees to be physically present within a particular office will be substantially reduced.
2.11 As a consequence, it is anticipated that many more people will be prepared to live considerably further from their place of work. This is of particular relevance to Rochford, as London is accessible via railway services from parts of the District; and house prices are relatively affordable when compared to other areas in and around London. As a consequence, the area may well prove an increasingly popular destination for those migrating out of higher density areas in and around London. This in turn is likely to put considerable pressure on the housing market. If insufficient homes are provided, it is also likely to result in a significant worsening of affordability. Ensuring a sufficient supply of homes will be imperative if the Council is to tackle the issue of housing affordability in the District.
2.12 Strategic Objective 3 is proposed to be:
“To facilitate accelerated growth in our local economy through supporting the delivery of suitably located land which meets businesses needs at each stage of their lifecycle (including delivering grow-on space to enable local businesses to flourish), the continued functioning of London Southend Airport as a thriving regional airport,
serving London and the South East, as well as supporting the continued growth and innovation at the Airport Business Park”
2.13 We support this and, in addition, suggest this objective should recognise that the critical role house-building plays in supporting the local economy, and the economic benefits house building would have for the District.
2.14 As the Local Plan Spatial Options recognises on page 26, areas within which new homes are built have the potential to see significant additional expenditure and job creation.
2.15 Employment relating directly to the construction industry will have positive economic and social impacts; as will jobs relating to the supply chain which will be supported. Construction is an important part of the local economy in the District: the 2011 Census recorded that 10.5% of employed residents in Rochford District were working in the construction industry.
2.16 Development of additional homes in the District will also engender sustained local economic benefits relating to additional local expenditure, with additional expenditure on goods and services by future occupiers of new homes on first occupation, on home set up cost, and on an ongoing basis in local shops and services in the area.
2.17 Conversely, failure to deliver sufficient homes for the District would not only result in a failure to support the local construction industry and failure to realise the potential opportunities outline above, it would also likely significantly deter inward investment by potential employers, if insufficient, affordable accommodation was not available locally to provide a local workforce.
3.0 Response to Local Plan Spatial Options Question 6
Which of the identified strategy options do you consider should be taken forward in the Plan?
Growth of Rochford
3.1 It is important to recognise that Rochford District contains a number of settlements, each with their own character and communities. Whichever growth strategy is ultimately pursued, the Local Plan should ensure a proportionate level of growth is directed to the
District’s various settlements, having regard to their characteristics and sustainability to accommodate additional growth.
3.2 For the Local Plan strategy to be sound, we consider that it will need to direct a relatively large proportion of housing growth to Rochford.
3.3 As the RLPSO recognises, Rochford and Ashingdon together form a functionallyconnected settlement home to around 18,000 residents. Between Rochford town centre and a number of neighbourhood centres located throughout the wider settlement, Rochford provides for a wide range of services and business spaces, including a number of specialist employment areas supporting nearby London Southend Airport.
3.4 The RLPSO also recognises that Rochford benefits from good walking access to most services, and that the only parts of Rochford with particularly poor access to services are around Purdeys industrial estate and the residential neighbourhoods of Ashingdon village.
3.5 Rochford / Ashingdon is characterised as a top tier settlement within the current Development Plan, i.e. one of the most sustainable settlements to which to direct
additional growth.
3.6 It is one of only three settlements in the District that benefits from a railway station.
3.7 In addition, it is also one of only three settlements in the District that benefits from a defined town centre.
3.8 The Local Plan strategy should direct a significant proportion of housing development to Rochford.
3.9 In respect of RLPSO Option 1 (urban intensification) we note that the RLPSO suggests this would involve no loss of Green Belt land, would minimise loss of greenfield, and would deliver 4,200 homes over the next 10 years.
3.10 The RLPSO describes Option 1 as “the minimum expectation of national policy” and states it is “likely to be required within every strategy option”.
3.11 It goes on to state that this option would entail making best possible use of our existing planned developments, previously developed land and other under-utilised land, such as vacant buildings and contaminated land; and notes that a strategy based on urban intensification could also include taking a more permissive approach to higher densities in suitable locations (such as town centres and near stations).
3.12 The RLPSO suggests that at least 4,200 homes will be built over the next 10 years under Option 1 and that the Urban Capacity Study suggests up to a further 1,500 homes could be built through a mixture of maximising the capacity of planned housing developments and taking a more permissive approach to higher densities in urban areas.
3.13 Whilst elements of Option 1 may be capable of being incorporated into a sustainable strategy for growth, it is clear that Option 1 cannot alone result in a sound Local Plan strategy.
3.14 Firstly, it is important to note that national policy places great emphasis on the need to
significantly boost the supply of housing and to meet local housing needs. Indeed, it is an express requirement of a sound Local Plan (as per paragraph 35 of the NPPF) that it seeks to meet the area’s objectively assessed needs, as a minimum. The RLPSO suggests a need to plan for at least 7,200 additional homes, and Option 1 would fall significantly short of meeting this.
3.15 Secondly, we consider that it is highly unlikely that 4,200 dwellings could be delivered through this option within the next 10 years. Such delivery would equate to an average of 420 dwellings per annum (dpa). The Council’s Annual Monitoring Report 2019/20
states that between April 2010 and March 2020, the District achieved a total of 1,768 dwelling completions – an average of 177 dpa. This figure included homes that had been delivered on large allocations made through the Rochford Allocations Plan, and did not rely solely on redevelopment of previously developed land / urban intensification, yet was still significantly short of delivering 420 dpa.
3.16 Furthermore, the Council’s Annual Monitoring Report 2019/20 noted that of the 347 net dwelling completions achieved in 2019/20, 268 of these were from major schemes. A significant proportion of these were delivered on allocated settlement extension sites in
the adopted Development Plan. It reports that 55% of dwelling completions were on greenfield land and, separately, that only 81 net dwelling completions in 2019/20 were from windfall sites.
3.17 In addition, it must be remembered that there is only a finite supply of previously developed land suitable and viable for residential development, and it is likely that a
significant proportion of this has already been exhausted.
3.18 Thirdly, it cannot be assumed that such a level of urban intensification would be suitable or sustainable. To achieve such a level of urban intensification to deliver the number of new homes that the RLSPO suggests through Option 1 would likely result in densities of development vastly greater than existing, to the potential detriment of the amenity of existing residents and character of the District’s settlements; and / or requiring the
redevelopment of existing employment / retail / community uses for housing, with resultant negative social and economic impacts.
3.19 Fourthly, it is not clear where in the District such intensification / redevelopment of previously developed land would deliver housing, and what spatial distribution of homes this would provide. As noted earlier within this representation, it is important to recognise that Rochford District comprises multiple settlements, each with their own communities, and each with their own needs. Option 1 is unlikely to address such needs, and instead would simply focus housing where there happened to be opportunities to redevelop previously developed land.
3.20 Fifthly, it is unlikely that a strategy reliant on urban intensification / redevelopment of previously developed land will deliver the types of homes required or infrastructure improvements. It is unlikely, for example, that such approach would deliver as many affordable homes as alternative strategies, or be accompanied by any substantial infrastructure improvements, due to the likely limited scale of individual developments and potential viability challenges they would face.
3.21 It is manifestly clear that if the Local Plan is to be a sound plan that meets development needs in a sustainable manner, then it cannot rely wholly on RLPSO Option 1.
3.22 The NPPF confirms (at paragraph 136) that Local Plans are the appropriate vehicle through which to make alterations to the Green Belt boundary. The NPPF also states that such alterations should only be made where exceptional circumstances are fully evidenced and justified; and that strategic policies should establish the need for any changes to Green Belt boundaries.
3.23 Exceptional circumstances are not defined in national policy or guidance. However, there is case law which provides a basis for the consideration of the issue. In particular, the judgment in Calverton Parish Council v Nottingham City Council & Ors [2015] EWHC 1078 (Admin) suggests (paragraph 51) that the following matters are relevant in the consideration of whether exceptional circumstances exist to justify alterations to the Green Belt:
 The scale of the objectively assessed need;
 Constraints on supply/availability of land with the potential to accommodate
sustainable development;
 Difficulties in achieving sustainable development without impinging on the Green
Belt;
 The nature and extent of the harm to the Green Belt; and
 The extent to which impacts on the purposes of the Green Belt may be mitigated as far as practicable.
3.24 Given the scale of objectively assessed need faced by the District, and the lack of potential alternatives to releasing Green Belt in order to sustainably meet such needs, it is evident that there are exceptional circumstances that justify alteration to the Green
Belt through the Rochford Local Plan.
3.25 We also note that there are potential options for the District to explore designation of additional, new Green Belt – land on the eastern side of the District, at Foulness, is very much open and rural in character, and in addition subject to multiple constraints that
make it unsuitable for any significant scale of development. However, this area of the District is not currently allocated as Green Belt.
4.0 Response to Local Plan Spatial Options Question 9
Do you agree we should take a sequential approach to flood risk and coastal change in our plan, locating development away from areas at risk of flooding and
coastal change wherever possible? How can we best protect current and future communities from flood risk and coastal change?
4.1 We agree that the Local Plan should seek to direct development to Flood Zone 1 (land least at risk of flooding from tidal or fluvial sources).
4.2 In doing so, however, it is important that sites, part of which lie in Flood Zone 2/3, but which are perfectly capable of accommodating a quantum of development in Flood Zone 1, are not rejected on flood risk grounds. To do so would be patently unjustified, giving rise, ultimately, to soundness concerns.
5.0 Response to Local Plan Spatial Options Questions 32 and 34
Q32. With reference to the options above, or your own options, how do you feel we can best deliver a quality green and blue infrastructure network through the
plan?
5.1 It is considered that the allocation of additional sites for development gives rise to the potential to make significant enhancements to green and blue infrastructure.
5.2 For example, in respect of proposals for Peggle Meadow, Rochford, and as set out in the Vision Document that accompanies these representations, green and blue infrastructure enhancements are proposed.
Q34. With reference to your preferred Strategy Option, are there opportunities for growth to help deliver new strategic green and blue infrastructure?
5.3 The development of Peggle Meadow, Rochford (CFS095) gives rise to the potential for green and blue infrastructure enhancements to be delivered, as set out in the Vision Statement that accompanies this representation.
6.0 Response to Local Plan Spatial Options Question 46
With reference to the options listed above, or your own options, how do you think we can best plan for vibrant town centres in Rochford, Rayleigh and Hockley? How
can we also ensure our village and neighbourhood centres remain vibrant?
6.1 It is critical that the Local Plan seeks to direct sufficient growth to the District’s various
settlements such that inter alia local services and facilities can be sustained and supported.
6.2 We consider that the Local Plan should seek to support and enhance the vitality and vibrancy of the District’s town centres; and to sustain village and neighbourhood centres.
6.3 It should be recognised that towns such as Rochford contain smaller neighbourhood centres, as well as a town centre, and that these often perform an important function for the local community which planning should seek to support.
6.4 The town centre and neighbourhood centres both have important roles in such settlements, and the Local Plan should look to support both. In respect of South
Rochford, for example, it is considered that the Local Plan should seek to ensure that neighbourhood shopping along Southend Road is sustained, as well as acting to
enhance the vitality of the town centre. Support for both is not mutually exclusive – the direction of growth to South Rochford can help support local neighbourhood shops, as well as the town centre.
7.0 Response to Local Plan Spatial Options 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?
i. Housing
7.1 The Site (CFS095) is considered suitable, available and achievable for residential development in a highly sustainable location for additional growth, and without
undermining the strategic purpose of the Green Belt. This is discussed in further detail in response to this question.
7.2 In addition, the Vision Document for Peggle Meadow that accompanies this representation (Appendix A) details the sustainability and deliverability of the Site for
housing, and demonstrates how a high-quality development will be delivered on the Site.
South Rochford as a location for growth
7.3 The adopted Core Strategy (2011) identifies Rochford as a tier 1 settlement, noting that it is a local centre. Rochford is one of the largest settlements in the District and is home to a range of services, facilities, employment opportunities, and is well served by public transport. It clearly represents a sustainable location to which a proportion of the District’s growth should be directed.
7.4 The general location South Rochford was considered through the Council’s previous Local Development Framework process and Core Strategy as a general location for growth.
7.5 The Council’s reasons for rejecting South Rochford were set out in the Core Strategy Sustainability Appraisal Addendum (2011) and were as follows:
“Location 2 [South Rochford] was not selected as it has the potential to engender coalescence with Southend, performed less well in sustainability terms compared with
West Rochford and would be less likely to deliver community benefits than development in South East and East Ashingdon”.
7.6 It is important to note that these concerns related to the general location of South Rochford, and not to any specific site.
7.7 The other reason to reject South Rochford as a general location was not that it was an unsustainable area for growth per se, but rather there were other areas that were considered more sustainable.
7.8 Firstly, it should be recognised that these areas have subsequently been developed, or their development is already been accounted for, and that there is still an outstanding need for housing.
7.9 Secondly, since adoption of the Core Strategy, Rochford District – jointly with Southendon-Sea Borough Council – adopted the London Southend Airport and Environs Joint Area Action Plan (JAAP). The JAAP directs significant employment growth and
infrastructure improvements into the area commensurate with the general location of South Rochford.
7.10 In addition, a railway station has been delivered at London Southend Airport. This is accessible from a number of locations within South Rochford, and significantly enhances the sustainability of this area for growth.
7.11 Having regard to the above, it is clear South Rochford is considered a sustainable location for growth.
Peggle Meadow (CFS095)
7.12 Peggle Meadow, Rochford is site reference CFS095 in the Council’s current plan-making process.
7.13 It is located off Southend Road, at the southern end of Rochford. Peggle Meadow is a mall site on the edge of an existing urban area, with development immediately to the north and west.
7.14 The Site measures c.3.9 ha, is mostly grassland, resembling a horse paddock, and contains several storage sheds no longer in use.
7.15 Historically, the land was farmed as market gardening. However, it has not been in productive use for c.25 years and has been uncultivated during this time. The land is not currently in use and, indeed, is no longer viable for agricultural use.
7.16 The Site is located to the south of Rochford, and is subject to a significant degree of containment due to the existing residential development immediately to the north and west; and watercourses and their accompanying dense vegetation to the south and east.
Views into and out of the Site are very much restricted.
7.17 The Site is close to the District boundary with Southend Borough Council, with Warners Bridge Park to the south providing a substantial and robust green buffer between it and the built form of Southend-on-Sea.
7.18 Arable fields are located to the east of the site, though it should be recognised that the Site does not project any further eastwards than the existing built form to the north of the Site.
7.19 There are a range of shops, services and facilities within close proximity to this Site.
7.20 As set out in the Vision Document (Appendix A) that accompanies this representation,
the Site is within walking distance to a range of facilities, services, public transport connections, and employment opportunities; and benefits from excellent access to rail
and bus services, providing sustainable links to larger centres.
7.21 A retail park including both convenience and comparison shops is located approximately 400m from the site – well within walking distance. Additionally, a neighbourhood shopping parade is located to the north of the Site, and also within walking distance.
7.22 London Southend Airport and Southend Airport railway station (which provides links to Southend, Rochford centre, and London Liverpool Street), are located opposite the site and within walking distance.
7.23 In addition to being accessible to future employment growth at London Southend Airport, the site is well located in relation to existing employment areas at Temple Farm Industrial Estate and Purdeys Industrial Estate.
7.24 The Site is accessed via Southend Road – which provides a direct connection with Southend to the south; and Rochford town centre to the north, negating the need for vehicles travelling from the site to either of these centres to navigate through existing residential areas / the non-strategic highway network within the District.
7.25 Development of the Site is presents a number of opportunities, which are discussed in details within the Vision Document. In summary, these opportunities / benefits of the Site’s development include:
 Creation of a more robust and defensible Green Belt boundary.
 Minimal impact on the Green Belt, and would not engender coalescence.
 Landscape enhancements.
 Provision of homes in a location well related to facilities, services and employment opportunities; and with excellent accessibility to public transport services.
 Enhanced sustainable transport links for the wider area.
 Avoidance of impact on the District’s local highway network.
7.26 In relation to the Site’s ability to deliver improved sustainable transport links to the benefit of the wider area, the cycling and walking charity, Sustrans, have confirmed they expressly support development of the Site due to the sustainable transport
improvements it will enable. A copy of Sustrans’ letter is provided as Appendix B. We consider this is a factor that should be afforded significant weight in favour of the Site’s allocation.
7.27 Further to the Site’s excellent accessibility to public transport services (including rail and bus) it is important to note that the NPPF states:
“Where it has been concluded that it is necessary to release Green Belt land for development, plans should give first consideration to land which has been
previously-developed and / or is well-served by public transport”. (Paragraph 142, emphasis added)
7.28 The Site has been considered by the Council through its Strategic Housing and Employment Land Availability Assessment (SHELAA) (2017) (as site referenceCFS095).This noted that the Site is not subject to any constraints that would prohibit its development.
7.29 The SHELAA (2017) considered the Site’s proximity to educational facilities; healthcare facilities; open space / leisure facilities; retail facilities; public transport facilities; and existing residential areas. Against all of these, with the exception to education, it found that the site’s proximity was ‘good’.
7.30 In respect of proximity to education it was rated as ‘medium’.
7.31 In respect of proximity to education, we note that the SHELAA (2017) does not consider that this renders the site unsuitable, but would nevertheless wish to emphasise that the Site is in close proximity to Southend Road along which run regular bus services which
connect the site to a number of schools (and, considering accessibility beyond educational facilities, to the town centre).
7.32 The SHELAA (2017) acknowledged that the vast majority of the Site is within Flood Zone 1 – land least at risk of tidal or fluvial flooding. Development of the site can be delivered without residential development taking place within Flood Zone 2 or 3.
7.33 The Site has been subject to a Flood Risk Assessment (July 2020), provided as Appendix C to this representation. Key conclusions of this Flood Risk Assessment include:
 All proposed dwellings will be located within Flood Zone 1. NPPF states that all uses of land are appropriate in this zone and the Sequential Test has been applied within
the site boundary and can be deemed as being passed.
 All built development and SUDS features will be located outside of the design climate change (35%) 1 in 100 year floodplain and climate change (65%) 1 in 100 year floodplain.
 Proposed dwellings will be set above the extreme climate change 1 in 1000 year flood level.
 Safe access/egress can be achieved during the peak of the event.
 It is considered that there is a low risk of groundwater flooding.
 There is a very low to high risk of surface water flooding which will be mitigated by ensuring that the proposed dwellings are set above the flood depth. 7.34 The SHELAA (2017) confirmed that the Site can be delivered without requiring significant infrastructure upgrades.
7.35 Vehicular access to the site can be achieved, as confirmed through an Access Appraisal
that has been undertaken, and previously submitted to the Council.
7.36 There are no physical constraints that prohibit the development of Peggle Meadow for housing.
7.37 The SHELAA (2017) concluded that the Site’s suitability for development will be dependent on a Green Belt assessment.
7.38 Subsequently, the Council published the Rochford District and Southend-on-Sea Borough Joint Green Belt Study February 2020 (‘the Green Belt Study (2020)’).
7.39 The Green Belt Study (2020) suggested that development of the Site would result in ‘moderate-high’ level of harm to the Green Belt.
7.40 Within this study, the Site forms a small part of the a larger parcel that was assessed as P65.
7.41 The Green Belt Study (2020) concluded that Parcel P65 makes a strong contribution to purposes 1, 2, 3 and 5 of the Green Belt (to check the unrestricted sprawl of large builtup areas; to prevent neighbouring towns merging into one another; to assist in safeguarding the countryside from encroachment; and to assist in urban regeneration, by encouraging the recycling of derelict and other urban land). It concluded that it makes a weak contribution to purpose 4 (to preserve the setting and special character of historic towns).
7.42 It is important to recognise the need to treat the results of any assessment of a larger parcel with caution when seeking to apply them to a smaller site within such a parcel. Clearly, smaller sites within a larger parcel may make a different level of contribution to the purposes of the Green Belt, and the harm their development may cause to the purposes of the Green Belt may well be different to that of the larger parcel in which they
have been incorporated for the purposes of assessment. 7.43 A note provided by the Local Plan Examination Inspector to Welwyn Hatfield Borough Council in relation to its Local Plan and the approach to the review of the Green Belt underlines this issue, stating:
“The phase 1 Green Belt Review was at such a strategic level as to render its findings on the extent of the potential harm to the purposes of the Green Belt, caused by
development within the large parcels considered as a whole, debatable when applied to smaller individual potential development sites adjacent to the urban areas. It goes without saying that a finer grained approach would better reveal the variations in how land performs against the purposes of the Green Belt. Such an approach is also more likely to reveal opportunities as well as localised constraints, both of which might
reasonably be considered further”. (EX39 of the Welwyn Hatfield Local Plan
Examination, December 2017).
7.44 As such, it is imperative to consider the Site itself: its contribution to the purpose of the Green Belt, and the extent of any harm to the purposes of the Green Belt that its development would entail.
7.45 In addition, case law confirms that in considering whether exceptional circumstances apply that justify alterations to the Green Belt, it is necessary to not only consider the potential harm to the purposes of the Green Belt development would engender, but also the degree to which such harm could be mitigated. The Green Belt Study (2020) fails to consider potential mitigation measures, and this will be something that the Local Plan
will need to consider.
7.46 A Green Belt Report (2020) has been prepared and submitted previously to the Council, and provided again as Appendix D to this representation. In addition, a site-specific Landscape and Green Belt Statement (2021) has been undertaken by James Blake Associates and provided as Appendix E.
7.47 As these studies confirm, when one looks at the Site in detail, it is clear that it only make a limited contribution to the purposes of the Green Belt.
7.48 The Landscape and Green Belt Statement (2021) considered the Site specifically, and in detail. In relation to Purpose 1 of the Green Belt (to check the unrestricted sprawl of large built up areas) it noted that the Site is located in close proximity to the built up area of Rochford and would not result in encroachment. Rather, its development would result in limited ‘infill’ of the previous brownfield land. It also noted that the Site is well contained by strong physical features including the built-up area of Rochford, the Prittle Brook and the Harp House Ditch. Overall, it concluded the Site was of low importance to Purpose 1 of the Green Belt.
7.49 In relation to Purpose 2 (to prevent neighbouring towns merging into one another) the Landscape and Green Belt Statement (2021) found that the Site is physically and visually separated from Southend and as such would not result in any physical or visual
encroachment. Furthermore, it noted that Warners Bridge Park provides a gap between Rochford and Southend which is of substantial permanence, and that the gap which exists now between the two settlements will exist to no greater or lesser degree whether or not Peggle Meadow is developed. It concluded the Site is of zero importance to Purpose 2.
7.50 Regarding Purpose 3 of the Green Belt (to assist in safeguarding the countryside from encroachment), the Landscape and Green Belt Statement (2021) found that the Site is well contained by strong man-made features to the north and west, and and dense and mature green infrastructure to the east and south. It also noted that the proposed strategic green infrastructure will provide further containment. As the Landscape and Green Belt Statement (2021) noted, it is also relevant that the Site has a degraded / neglected character. It concluded that the Site is of low importance to Purpose 3 of the
Green Belt.
7.51 In relation to Purpose 4 (to preserve the setting and special character of historic towns) the Landscape and Green Belt Statement (2021) concluded that the Site is not considered to form part of the landscape setting of a historic town, nor does it impact on any Conservation Areas or Listed Parks and Gardens. It went on to conclude the Site is of zero importance to Purpose 4.
7.52 In summary, the Landscape and Green Belt Statement (2021) provided by James Blake Associates concludes the Site is of low importance to Purpose 1 and Purpose 3 of the Green Belt, and of zero importance to Purpose 2 and Purpose 4. It provided clear and
robust justification for reaching such conclusions.
7.53 In respect of the need to consider the potential to mitigate impacts on the Green Belt in addition to considering a site’s contribution to the purposes of the Green Belt, it is relevant to note mitigation measures are proposed as part of the development of the
Site.
7.54 These include enhanced landscaping to reinforce the existing mature vegetation towards the southern boundary; and a loose-grained layout of dwellings towards the south and east of the Site (proposed to take a traditional form, and will be a scale and massing
which reflect the existing residential development in the locality, in order to minimise visual impact).
7.55 Additionally, and still in relation to the issue of Green Belt, the NPPF states that where Green Belt is released to meet development needs, as well as prioritising locations close to public transport links, plans should also set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. The PPG3
sets out the compensatory improvements that strategic plan-making authorities should seek to deliver in the event that it is necessary to release land from the Green Belt. These include the following:
 New or enhanced green infrastructure;
 Woodland planting;
 Landscape and visual enhancements (beyond those needed to mitigate the immediate impacts of the proposal);
 Improvements to biodiversity, habitat connectivity and natural capital;
 New or enhanced walking and cycle routes; and
 Improved access to new, enhanced or existing recreational and playing field provision.
7.56 A number of such compensatory improvements can be delivered through development of the Site. 7.57 In terms of new or enhance green infrastructure, in addition to the enhanced landscaping that is proposed, the proposed development also incorporates the creation of a new public open space to the north of the Site. This will also provide a recreational benefit.
7.58 Through development of the Site, ecological benefits will be delivered, with ecological enhancements to be delivered as part of the additional landscaping enhancements,
SuDS and open space provision.
7.59 In terms of cycle and pedestrian link enhancements, the Site represents a unique opportunity to deliver a cycle link which the Core Strategy (2011) promoted.
7.60 This link is discussed further within the accompanying Vision Statement, and to reiterate,
is supported by Sustrans.
7.61 This link will facilitate a safe and attractive pedestrian and cycle access to Warners
Bridge Park, Temple Farm Industrial Estate, and to Southend-on-Sea more generally,
for existing and future residents of Rochford.
7.62 It should be noted that this new link will also provide a safe and convenient pedestrian / cycle access for existing and future residents of Rochford to recreational facilities and playing fields at Warners Bridge Park.
7.63 The ability of the Site to deliver the above compensatory measures called for by national
guidance in instances where land is removed from the Green Belt, are factors which weigh very much in favour of removing this Site from the Green Belt.
7.64 The Site is clearly a suitable and sustainable site for residential development, and one through which a number of additional benefits, in addition to the provision of housing, can be delivered.
7.65 Turning In relation to deliverability, the Site is not subject to any legal or ownership constraints to its delivery for housing, and is being actively promoted for development by the owner. It is an available and achievable site for residential development, in addition
to being a sustainable one.
7.66 A Landowner’s Vision Statement has been prepared by the landowner, and accompanies this representation as Appendix F. This sets out the landowner’s desire for an exceptionally high quality development at Peggle Meadow, to provide a legacy for this Site, which has been in his family’s ownership for generations.