To whom it may concern

Response to the Rochford District Council Local Plan re Site 179 Final Viability Report 2017
We have become aware that the land belonging to Steven’s Farm to the east of Folly Chase ,West of Betts Wood, North of Folly Wood and South of the railway line has been included in the Call for Land site reference 179 and has been deemed ‘viable’ for housing development within the Final Viability Report 2017 of the Strategic Housing and Employment Land Availability Assessment 2017 ref CFS064.
This submission objects to any development of the Site whatsoever and that the site should be removed from consideration of development within the Local Plan and should instead be considered for protection due to it’s Green Belt and ecological status.
We understand that RDC assessed the suitability of all sites under consideration in its Strategic Housing and Employment Land Availability Assessment 22017. In terms of infrastructure, the document states (on age 321- see attached) that no highways access is required, no significant investment in utilities needed and no significant investment in sustainable transport needed. We strongly disagree with this.
Green Belt
The land in question forms part of the Metropolitan Green belt. Such land can only be developed for ‘Exceptional circumstances’ as detailed in the Planning Policy Guidance Note 2 (PPG2), and states in para 143 that Inappropriate development is by definition harmful to Green Belt’’ and in Para 145 that ‘’A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are’’ ;
a. Agriculture and Forestry.
The outline proposal is for residential development thus condition is not satisfied. Indeed any development would actually be in direct opposition to this as the land is already prime agricultural arable land and is actively farmed.
b. Essential facilities for outdoor sport and recreation.
The site already includes a football pitches at the Community Centre, the Community Centre itself and is widely used for walking, dog walking, running and cycling. The outline proposals would diminish the provision of outdoor sport and recreation and this condition cannot therefore be satisfied by any housing development.
c. and d. Limited extension and/or alteration of existing buildings.
Other than the Community Centre there are no existing buildings within the site. The Community Centre itself still has a long unexpired lease and development of it fails the test above in any case. This condition cannot be fulfilled
e . Limited Infilling.
The Local Plan allocation site reference 179 states that the land could be used for up to 265 dwellings. This is anything but ‘limited’ and this condition cannot be fulfilled
f. Limited affordable Housing
Again the size of the potential development is anything but limited. Condition cannot be met.
g. Limited infilling or redevelopment of previously developed land.
This land has not been previously developed and condition cannot be met.
Paragraph 136 of the National Planning Policy Framework lays out that ‘exceptional circumstances’ must be met for any consideration of changing existing Green Belt boundaries. Paragraph 137 specifically states that ‘’the…authority should be able to demonstrate that it has examined all other reasonable options for meeting its identified need for development. …..and whether the strategy…. Makes as much use as possible of suitable brownfield sites and underutilized land’’

From the above it is clear that the site cannot be considered any further for housing development as to do so contravenes existing Metropolitan Green Belt legislation. The site should be removed from the development plan.
Local Wildlife Sites and Incorrect identification of their proximity to the site.
An additional contravention of Policy to the Green belt restrictions is that the site is in ‘close proximity’ to 3 Local Wildlife Sites (LoWs) namely, Betts Wood, Folly Wood and Hockley Hall-South Wood. These are all designated a minimum of HC1 (ancient Woodland) and have further designations. Folly Wood occupies most of the southern boundary of the site, Betts Wood most of the eastern boundary and Hockley Hall-South Wood circa half of the northern boundary. It should be noted that there is a strip of woodland joining Folly Wood and Hockley Hall-South Wood along the entire western perimeter and this may mean that these two LoWs are in fact one larger site. It is important to point out that the Site Allocation Assessment Criteria fails to mention the ‘close proximity’ of the LoWs and that it is vital that this is noted by RDC. This omission must render the Site Allocation Assessment as invalid, and that the site should not be developed.
The ’Buffer Zones’ that would be required at the perimeter of the LOWs and around the mature veteran Oak trees within the site would reduce the available land suitable for development significantly and render the site uneconomic.
The LoWs mentioned above, and the immediate surrounding environment, including the field detailed in site 179 support a rich and varied population , indeed such woodland is recognized as providing the most diverse and important habitats in the UK and is already limited to just 550,000 Hectares across the entire UK.
The LoWs assessments do not detail many resident species but the following can/have been found in and around these sites and the site in question; Grass snakes, Adders, Slow Worms and Common Lizards , Common Frogs, Toads, Smooth Newts, Great Crested Newts, Badgers, Foxes, Muntjac Deer, Buzzards, Sparrow Hawks, Merlin, Tawny Owls, Little Owls, Nightjar, Blue Tits, Great Tits, Long Tail Tits, Coal Tits, Willow Warblers, Chiff Chaff, Blackcap, Blackbirds, Song Thrush, Goldfinch, Greenfinch, Chaffinch, Yellowhammer, Nuthatch, Swallow, Swift, House Martin, Crow, Jackdaw, Magpie, Jay, Rook, Coot, Moorhen, Cuckoo, Dunnock, Wren, Fieldfare, Lapwing, Redwing, Goldcrest, Great Spotted Woodpecker, Green Woodpecker, Lesser Spotted Woodpecker, Grey Heron, Pied Wagtail, Grey Wagtail, House Sparrow, Kestrel, Linnet, Nightingale, Meadow Pipit, Robin, Skylark, Starling and significant numbers of unidentified bats over the field and in the gardens of Folly Chase at night suggest a colony within Folly and/or Betts Woods. Rich flora, especially Bluebells and significant insect species including Wood Ant colonies.
This incredibly diverse range of species rely on the tree and plant species found in Ancient Woodland and on arable farmland. They require free movement between sites and the field, and the large mature Oaks within it, provide essential movement corridors between the three identified LoWs sites. Any development in the field in the center of these three LoWs can only have a massive detrimental effect on the population, and the existing richness and diversity proves this is a site that should be preserved, not destroyed. Consideration for development must cease forthwith.
The ’standing advice’ of the Government in this regard is found within Natural England and Forestry Commission guidance ( https://www.gov.uk/guidance/ancient-woodland-and-veteran-trees-protection-surveys-licences). Standing Advice is a ’Material planning consideration’. Ancient Woodllands have equal protection in the National planning Policy Framework.
We draw attention to the RDC’s own statements regarding potential development within the Local Plan document. The plan clearly states that one of it’s key objectives is ‘’for meeting future needs (including housing….). It will also identify areas for protection, such as sites that are important for wildlife and open space.’’ The RDC have failed in their policy objective and in following correct process that there is a failure to even identify the proximity of the LoWs detailed above in the Site Allocation Assessment Criteria.
Rather than the site be considered for development, we have shown that it should be identified for protection in accordance with the Local Plan objectives and that it should be removed from the development plan and placed in a protection plan.
Material Planning Concerns
There are many Material Planning Concerns but we wish to draw RDC attention to the access to the site, none of which is viable. The only access is via the Community Centre. This has 7 years remaining on it’s lease and would need demolishing, in contravention of Green Belt policy to improve and increase recreational and community spaces, and any access beyond it would necessitate destroying the existing playing pitches and removal of trees that fall within the Betts Wood HC1 designation.
The road access to the Community Centre is via Westminster Drive itself accessed only by Buckingham Road and Osborne Avenue. None of these are appropriate site access in respect of the heavy polluting traffic required for it’s development, and for the increased traffic flow post development. These roads already have severe access limitations due to traffic flows for Hockley Primary School, and the amount of residential parking throughout the day, due to the existing estates not providing anywhere near sufficient off-road parking. Emergency access would be severely curtailed by more through traffic of any kind to the site.
The only other point of access is via Folly Lane and Folly Chase directly. Folly Lane has the same problem with existing traffic flows and parking, its twisty nature is unsuitable to construction traffic, the existing Folly Grove development still requires construction traffic and is repeatedly damaging drain covers down the road evidencing it’s unsuitability for heavy traffic. Folly Chase provides the only direct access to the site. It is unadopted, too narrow has limited turning options, and no footpaths. It is maintained by us the other residents and is not to standard to support anything other than limited residents’ access. It is inconceivable that it could be considered suitable for either development/construction traffic or significant flows of several hundred car movements daily post development.
Indeed, the road itself is owned by the residents who would not provide any consents for wider access or development.
We would also like to point out that CFS064 is misinterpreting the site as our land is included in the plan without our consent. The site should be redrawn with our land taken out. With regard to access as pointed out above Folly Chase is a privately maintained road but a section of the road in front of our property which is the only access into CF064 is actually owned by us (title number EX879939 – see attached). Surely this and the information above rules out any suitable access for a housing development on this site.