Comment

New Local Plan: Spatial Options Document 2021

Representation ID: 41487

Received: 21/09/2021

Respondent: Ms Lisa O'Sullivan

Representation Summary:

[Re Hockley]

Folly Lane is no longer a quiet road - it's a busy rat-run, with large trucks, coaches and even buses forcing their way through a narrow thoroughfare. The new housing developments in Pond Chase and Church Road has seen the speed of traffic rise dangerously. Increased building in Hullbridge, poor access on the B1013 from Rayleigh to Rochford - with drivers avoiding the often log jammed A127 - means this is now a busy road and the only direct way Hullbridge to Hockley. Car are often parked in dangerous positions on both sides of the road and it's worse when parents are dropping children at Hockley Tennis Club. Traffic goes too fast and often cut the corners of the 90 left - 90 right and 90 left bends those of us looking to pull into Folly Chase are in jeopardy at times. The roads are broken and in disrepair fallowing the construction of Pond Chase Nursery

The bus service is infrequent and expensive, and speaking as a cyclist the roads are too narrow for safe transit for younger riders. I want proper cycle ways but where are they? And where would they realistically go? The B1013 cannot cope with the current traffic let along increased pressed form increased housing.

Full text:

Thank you for making the Local Plan and Spatial Options available on the internet and for the extensive detail included. It's taken me a while to get to examine the contents and would like to respond to proposals to develop land surrounding my family home. I am concerned by the scale of possible development all across the Rochford area, but there are two sites that will directly and adversely affect my family and I.

Of course I understand that Government policy will force significant development within the area, but I am writing to highlight issues with developing the sites of CFS064 and CFS264 and to ask that they be removed from the Plan and any subsequent consultation stages. Site CFS064 is special and should be protected in accordance with RDC's own objectives.

I list my concerns as follows:

Access to the sites CFS064 and CFS264

I live on Folly Chase, I was born here more than 50 years ago and it's been my parents only marital home in their 56 years as husband and wife. As I look at the plans it seems the only access to both sites would be through the Chase, which for many years was an unmade road off a country lane. Folly Lane is no longer a quiet road - it's a busy rat-run, with large trucks, coaches and even buses forcing their way through a narrow thoroughfare. The new housing developments in Pond Chase and Church Road has seen the speed of traffic rise dangerously. Increased building in Hullbridge, poor access on the B1013 from Rayleigh to Rochford - with drivers avoiding the often log jammed A127 - means this is now a busy road and the only direct way Hullbridge to Hockley. Car are often parked in dangerous positions on both sides of the road and it's worse when parents are dropping children at Hockley Tennis Club. Traffic goes too fast and often cut the corners of the 90 left - 90 right and 90 left bends those of us looking to pull into Folly Chase are in jeopardy at times. The roads are broken and in disrepair fallowing the construction of Pond Chase Nursery.
Any more development will just make all of this worse - if even the small site is green lit that will mean another 60 cars using the road - not to mention extra the delivery traffic.

Our road is maintained by residents and is incapable of handling construction traffic or the eventual increase in residential access traffic. It leads to a footpath, popular with dog walkers taking them into Bluebell Woods (aka Folly Wood) designated Ancient Woodland, carrying HC1 Wildlife Site designation. It's all part of the "6,320km Public Rights of Way (PRoW) in Essex - one of the most extensive networks in the country" according to the ECC website. And the Rochford District Council website highlights that "Hockley" is a member of the Parish Paths Partnership Scheme, which is an initiative introduced by Essex County Council in conjunction with The Countryside Agency to assist parish councils to maintain, develop and promote their local footpath network."

Folly Chase has no surface drainage features, no run off into gullies or gutters. There are no footpaths, and no room to build them as the roads about 9 feet wide at its narrowest point, so cannot support two way traffic. The infrastructure for housing water, and gas supplies is not far beneath the surface and any increase in heavy traffic will almost certainly damage these as they are vulnerable.

Anglian Water had serious concerns about the strain on the current sewerage systems in the area and the Pond Chase development created serious issues contributing to the ill health of several residents on the road. The complete system now cross to Folly Chase from Pond Chase, across to the field that is site CFS064 to the Hockley Community centre and has already caused significant sinking of our road surface. The nearby development in Church Road has also had significant sewage and surface water issues and any further development adding onto the existing surface water and sewage infrastructure will only increase the pressure on existing infrastructure, potentially to the point of failure, with significant public health concerns.

Folly Chase is Private Road with an undefined Public Footpath running down it. Ownership of the road isn’t registered and absent any contrary evidence each land owner owns up to the mid- point of the road. There are some private rights of way that have been established by usage and by deed, but it is apparent that the ownership issue is complex and fragmented and that my discussions with many residents shows the large majority would be unwilling to enter into any negotiation to depart from current use and access.

With specific reference to site CFS064

This land abuts the full length of our back fence, we have all manner of wild life that comes into our garden from here including newts, common lizards and adders (a protected species) as well as bats, and dragonflies.
I note that the land is Metropolitan Green belt land and have read that such land can only be developed for ‘Exceptional circumstances’ as detailed in the Planning Policy Guidance Note 2 (PPG2). It also says in paragraph 143 that "Inappropriate development is by definition harmful to Green Belt’’ and in Paragraph 145 is says ‘’A local planning authority should regard the construction of new buildings as inappropriate in the Green Belt. Exceptions to this are;


• 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 under-utilised land’’

All the above suggests the site cannot be considered any further for housing development as to do so contravenes existing Metropolitan Green Belt legislation so it must be removed from the development plan.


Local Wildlife Sites and Incorrect identification of their proximity to the site CFS064.
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 have passed the first stage consultation as a consequence.

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 CFS 064 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.

When I was a little girl I used to play in "the big field" and in the gloaming of summer would watch the glow-worms in the grass by Folly Woods. The LoWs assessments do not detail many resident species but it's not only the glow worms that the children growing up here see on their walks. We have grass snakes and slow worms as well as adders and very cute common lizards. There are frogs, toads, smooth Newts, great Crested Newts. I have seen badgers, foxes, muntjac deer and even a very fast weasel! There are nesting buzzards, sparrow hawks, merlin, tawny owls, little owls, nightjar, blue tits, great tits, long tail tits, robins and wrens, coal tits, willow warblers, chiff chaff, blackcap, blackbirds, thrushes, goldfinch, greenfinch, chaffinch, yellowhammer, tree creeper, nuthatch, swallow, swift, house martin. In the trees of the ancient woodland we have many corvid including crow, jackdaw, Magpie, Jay, Rook, then there's the Coot, Moorhen, Cuckoo, dunnock and sparrows and when it's cold fieldfare, lapwing, and redwing shelter and rest. Goldcrest, Great Spotted Woodpecker, Green Woodpecker, Lesser Spotted Woodpecker, Grey Heron, Pied Wagtail, Grey Wagtail, House Sparrow, Kestrel, Linnet, Nightingale, Meadow Pipit, Skylark, Starling have all been seen here as the seasons change. And we all love the bats so their must be a colony making their home within Folly and/or Betts Woods. There's rich flora, including wild honeysuckle, wood anemones and the bluebells, all with the many variety of beetles, spiders and Wood Ant colonies.

They live happily undisturbed amongst brambles, oak, hornbeam, holly and Ash trees around the 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 centre 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.


I have been shown 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. So this site really should not be considered for development - instead it should be listed for protection in accordance with the Local Plan objectives - taken off the development plan and placed in a protection plan.

Infrastructure- both sites

I've mentioned my concerns about local road issues - I haven't added my worries about the times ambulances take to get to our road and then back to Southend hospital (While it continues to have an A+E unit).
I have also explained how inadequate drainage and sewerage is in the area but we have to also address the pressure local services are already straining under. If both sites are green-lit hundreds more people (and children) will be looking for places in our local schools, GP surgeries, dental surgeries and nurseries. The bus service is infrequent and expensive, and speaking as a cyclist the roads are too narrow for safe transit for younger riders. I want proper cycle ways but where are they? And where would they realistically go? The B1013 cannot cope with the current traffic let along increased pressed form increased housing.

Reduction of Quality Arable farming land-CFS064
I am concerned the Plan may well reduce the acreage available for arable farming. What measures have the council made to ensure we have sufficient acreage available for farming use to enable us to keep feeding ourselves?

Impact on the landscape and community
Any development at site CFS064 will be detrimental on the environment, biodiversity and the visible appearance of the site. The visual impact will destroy the character of the site and its surroundings and the increase in population and traffic would destroy the culture of the existing community within Folly Chase.

Spatial Options Document 2021
Whilst I agree with the Vision Statement for Hockley as detailed in the SOD I cannot see how the proposed development sites would achieve the stated vision. Surely any further development would conflict with the entire Vision Statement, other than the one regarding affordable housing, but as we have seen on numerous occasions building more houses does not link directly to improved affordable housing allocations as builders charge increasingly higher prices. Surely a Central Government led policy on house pricing/profits is the answer?

Q58e asks re the significance of the ‘local green spaces’ but makes no mention of the Local Wildlife Sites. These should be equally regarded and are very significant. I have heard that CFS064 could be considered for re wilding. If so, with it’s close proximity to LoWs it could become an education centre or Country park, accessible to many by foot and cycle. It therefore does need protecting form development as it would help increase the land locally t comply with the Vision Statement and improve the environment and bio diversity for the benefit of the local community.

More Suitable Sites
My introduction acknowledged the need for some developments to comply with Government policy. There is a consensus that Hockley itself cannot cope with more development in the immediate vicinity but the Plan includes sites on the western fringes of the district that are clearly more suitable with better access, room to provide additional social infrastructure as well as housing, better transport and potential for more transport hubs, and would keep the majority of traffic away from the existing overly congested community of Hockley and Hawkwell.

Conclusion
I ask that sites CFS064 and CFS264 be removed from the next stage. They are simply not suitable.