pages on your website I feel I have to respond. Whilst I have wider concerns than those regarding just the two sites above I think it is to be accepted that due to Government policy significant development has to happen somewhere within the boundaries of RDC. My purpose in writing this response , however, is to advise the council of specific issues affecting the two specific sites identified in the header and to request their removal from the Plan and any subsequent consultation stages. Indeed not only should site CFS064 be removed from the development pan, it should be earmarked for protection in accordance with RDCs own objectives detailed within the plan.

My concerns are as detailed below

Material Planning Concern regarding Access-re sites CFS064 and CFS264
The only apparent access to both sites appears to be via Folly Chase, a small unadopted road off of the already congested and unsuitable Folly Lane. Folly Lane itself has seen an unreasonable increase in traffic as it is used to access the recent new housing developments in Pond Chase and Church Road as well as the previously existing housing estate. It is now seeing additional increases in traffic flow caused by the significant housing development in Hullbridge as it is the only direct two way road access from Hullbridge to Hockley. The road is frequently difficult to get through with parked cars along both sides and heavier traffic flows in both directions. This is not helped by it’s layout with three 90 degree bends and one c 45 degree bend along its relatively short length. These bends are difficult for larger traffic, especially the type of traffic used in construction, and a drain cover on one bend is broken several times a year by lorries having to ride up on to the kerb in order to get around the bend. Generally the speed of the ‘through’ traffic is too high and I have witnessed many near misses on the bends as vehicles either cut the corners or are forced to breach the centre of the road due to parked cars. A serious head on accident is now inevitable down this road, and the prospect of further development off of it will make matters even worse as the scale of the housing for the two sites identified in the plan would equate to approximately another 500 cars using Folly Lane just to access the developed sites. This would likely equate to an average of approximately 1000 to 2000 extra car movements a day on a road that is already inadequate.

A far as Folly Chase is concerned it is so limited in its capacity that it simply cannot be deemed suitable for access for either construction traffic or the eventual increase in residential access traffic. The Chase is not a through road, terminating at a footpath leading into designated Ancient Woodland, carrying HC1 Wildlife Site designation. Folly Chase has no significant base as it was unmade until the 1980s. The current road has been constructed and maintained by the Folly Chase Road Frontagers Committee on behalf of residents. A layer of bitumen and gravel was utilised over a thin layer of type 1 hardcore that is sufficient for the low traffic flow associated with 25 houses and no through access, but will simply not support construction traffic or the flows commensurate with the potential development. The road itself has no surface drainage features, gullies, gutters or drains so all water runs over the surface to the bottom of the road. There are no footpaths, nor is there space to construct footpaths and is approximately only 9 feet wide at its narrowest point and cannot support two way traffic. The existing housing water, and gas supplies are very shallow beneath the surface and any increase in heavy traffic will almost certainly cause collapse of these and there are numerous points where the existing sewage pipes cross the road, again, at a very shallow depth and would be extremely vulnerable to increased traffic flows.

The recent adjacent Pond Chase development has well known problems with regards to access to sewerage, and whilst this is now complete and running it should be noted that the bored line of drains that traverse the bottom of Folly Chase from Pond Chase, across to the field that is site CFS064 to the Hockley Community centre have 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.


Green Belt- ref site CFS064
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 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.
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.

Infrastructure- both sites
I have detailed my concerns above regarding the inadequate infrastructure in respect of local roads, access and drainage and sewerage. In addition it is quite clear that other local services are already struggling and would simply be unable to cope with an increase in the local population of approximately 1000 people based on the estimated development potential of the two sites. Local schools, GP surgeries and wider health care have been under significant pressure for many years. Limited local car parking inhibits local trade ( it should be noted that there are several sites used for car parking included in the site allocation potentially limiting it further) and the main Southend/Hockley/Rayleigh Road is far too frequently jammed back to Hawkwell and Hambro Hill. There is no room for dedicated bus lanes or cycle lanes along this main corridor so whatever thoughts there may be regarding increasing public transport usage or cycling are simply pie in the sky and not feasible. The main road simply cannot cope with any more traffic arising from 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
It is clear that any development at site CFS064 would have a significantly detrimental effect on the environment, biodiversity and the visible appearance of the site. The visual impact will destroy the character of the site and it’s 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 . The following sites CFS146,147,167,144,168,145,137,055,121 all have far easier 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 congested community of Hockley and Hawkwell, and prevent a commensurate increase in pollution, noise and general inconvenience.

Conclusion
As can be seen form my concerns detailed above , sites CFS064 and CFS264 should be removed form the next stage. They are simply not suitable when there are many more sites which would ‘score’ much better under a wide range of development considerations.

Thank you for your time in reading our response