Rochford District Council – Land to the north of Sutton Road, Rochford
Representations to the Spatial Options Consultation
1. Introduction
1.1. On behalf of Southern and Regional Developments Ltd, Claremont Planning Consultancy has been instructed to prepare and submit representations to the Spatial Options consultation being undertaken by Rochford District Council to inform the emerging Local Plan.

Strategy Options
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
1.2. Claremont Planning on behalf of Southern and Regional Development’s Ltd are generally supportive of the settlement hierarchy proposed. Rochford is identified as a ‘Tier 2’ settlement within the hierarchy recognising the settlement’s sizeable population and comprehensive local service base. Whilst it is acknowledged that Rochford has a considerably smaller population than
that of Rayleigh, meriting its location below Rayleigh within the settlement hierarchy; the placement of Hockley and Rochford within the same ‘Tier’ in the hierarchy is disputed. Although the populations are of a similar size, the proposed settlement hierarchy fails to account for the
strategic location of Rochford adjacent to London Southend Airport. The close proximity of Rochford to the airport provides the settlement with key transport infrastructure which connects Rochford to the wider South Essex region and rest of the country. As such, it is considered that Rochford should be distinguished from Hockley within the proposed settlement hierarchy by
virtue of its local and nationally strategic location.
1.3. It is recommended that the spatial strategy advanced by the emerging Local Plan be strongly informed by the proposed settlement hierarchy In accordance with the provisions of Paragraph 16 of the National Planning Policy Framework (NPPF), development plans should be prepared with the objective of contributing to the achievement of sustainable development. As such, it is
advisable that the overall distribution of growth is informed by this imperative and larger quantum of growth apportioned to those settlements which are identified by the hierarchy as being most sustainable. The proposed settlement hierarchy acknowledges the sustainability of Rochford for development, whilst these representations have also sought to illustrate the strategic location of
the settlement due to the presence of the London Southend Airport and its planned continued expansion to provide additional employment floorspace and associated employment opportunities.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?

Strategy Option 1: Urban Intensification
1.4. It is advised that Strategy Option 1: Urban Intensification is not advanced. The current standard
method identifies a housing requirement of 7,200 dwellings in the district across the next 20 years however the consultation document establishes that approximately only 4,500 new dwellings can be delivered through Option 1. Paragraph 35 of the NPPF identifies that Plans must provide a strategy which as a minimum seeks to meet the area’s objectively assessed needs in order to be found sound. Delivering development through Strategy Option 1 will result in a substantial shortfall in housing delivery and will unlikely be considered sound by the Inspector when the Plan is examined.
Strategy Option 2: Urban Extensions
1.5. It is recognised that Strategy Option 2, which seeks to spread development across a number of development sites of between 10 and 1,500 homes adjoining existing towns and villages, could deliver a sustainable distribution of housing growth. The dispersal of urban extensions based on the settlement hierarchy is supported, where this would therefore see the largest quantum of growth apportioned to the most sustainable settlement settlements within the District as established by the proposed settlement hierarchy and it is therefore recommended that growth at sustainable settlements such as Rayleigh and Rochford should be prioritised if this option is taken forward.
1.6. Moreover, the land north of Sutton Road at Rochford as promoted by Southern and Regional Developments, has been identified within the initial appraisal undertaken by the Council as making a potential contribution to Strategy Option 2. It is agreed that the promoted land off Sutton Road could make an effective contribution to the delivery of this Strategy Option where the land abuts established areas of residential development at the settlement and is located in close proximity to employment opportunities at the Purdeys Industrial Estate. As such, the land at Sutton Road is considered to represent a logical location for the further expansion of Rochford should Option 2 be advanced by the Authority.
Strategy Option 3: Concentrated Growth
1.7. Concentrating growth in one or more locations of 1,500+ dwellings, as promoted within Strategy Option 3 is not supported. Large allocations and the development of new settlements, by virtue of their complexity and infrastructure requirements, have much longer lead-in times for delivery and therefore would be likely to contribute towards meeting housing needs towards the end of the Plan period and beyond. As such, pursuit of this Strategy Option alone will not deliver sufficient housing to meet the Authority’s housing needs in the earlier years of the Plan, leaving the Authority vulnerable to speculative development which is not Plan lead particularly if delays in the delivery of these allocations arise. Topic Paper 9: Housing prepared in support of the
Spatial Options Consultation 2021 illustrates that over the last 10 years Rochford’s historic rate of housing delivery is 227 dwellings per annum, requiring an uplift of around 60% in annual housing completions to meet the local housing need identified for the new Local Plan. The
Authority should note that paragraph 69 of the NPPF advises against the concentration of growth as proposed within Strategy Option 3, instead recommending that development plans should seek to accommodate at least 10% of their housing requirement on sites no larger than one hectare. Given the uplift in housing delivery which will be required to meet housing need, it would be prudent that the Council also consider allocating sites of a variety of sizes which can be builtout relatively quickly and make a more immediate contribution to housing supply.
Strategy Option 4: Balanced Combination
1.8. Strategy Option 4 advances a balanced combination of the various Strategy Options presented, including making the best use of urban capacity (Option 1), building on one or two large growth areas (Option 3), and a number of smaller urban extensions (Option 2). Claremont Planning strongly recommend that the Authority pursue the blended approach promoted within Option 4. It is considered that Option 4 represents the most sustainable means of meeting the District’s
housing requirement, by maximising sites available within the existing urban area, and delivering smaller urban extensions at sustainable locations in accordance with the proposed settlement hierarchy. Paragraph 69 of the NPPF establishes that a blended approach which allocates small, medium, and larger sites for development is advisable, ensuring that any potential delays in the delivery of larger allocations do not adversely affect housing delivery in the District.
1.9. Paragraph 35 of the NPPF sets out the tests for ‘soundness’ of development plans, establishing
that plans should, as a minimum, seek to meet their areas objectively assessed housing need and be informed by agreements with other authorities so that any unmet need from neighbouring areas can be accommodated where it is practical to do so. As established, the land at Sutton Road as promoted by Southern and Regional Developments has been assessed by the Council under reference CFS067 within their 2021 Site Appraisal Paper prepared in support the Spatial Options consultation. Within this assessment, the land at Sutton Road is positively considered by the Authority and its availability and deliverability for residential development recognised.
Moreover, Claremont Planning assert that the Council should recognise that the land at Sutton Road performed strongly through this assessment in relation a wide variety of criteria including but not limited to flood risk; landscape harm; site hazards and conditions; and access to facilities and services. As such, the land at Sutton Road should be strongly considered for allocation
through the emerging Local Plan, given both its environmental, and social sustainability.

2. Spatial Themes
Q9. 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?

2.1. National policy, chiefly paragraph 161 of the NPPF is clear in its expectations that development plans apply a sequential, risk-based approach to the location of development which includes taking into account all sources of flood risk as well as current and future impacts of climate change. As such, it is agreed that a sequential approach to flood risk and coastal change should be adopted by the Plan, and this would be a sound approach that is consistent with national planning policy. As recognised by the Council, much of the District is influenced by high flood risk that is likely to be subject to coastal change as a result of climate change. As such, it is recommended that development opportunities within areas at lower risk of flooding are fully considered by the Authority. Approaching flood risk and coastal change sequentially would also accord with the proposed settlement hierarchy, concentrating development at the main settlements of the District, including Rochford and Rayleigh which are the areas within the District
at lower risk of flooding.
2.2. The land at Sutton Road promoted by Southern and Regional Developments represents a suitable location for development if the sequential approach to flood risk is adopted. Although an inappreciable area to the extreme south east of the land is located within Flood Zone 3, the
Environment Agency’s flood map for planning identifies that this area of the site also benefits from flood defences; whilst the rest of the land promotion is located within Flood Zone 1, being at low probability of flooding. 2.3. Within the 2021 Site Appraisal Paper, the Council identified that the promoted land at Sutton Road performs very strongly in relation to flood risk, recognising that this small area of flood risk on site is not detrimental to the land’s deliverability. The pragmatic approach advanced by the Council in relation to flood risk on site is therefore supported. Moreover, any development scheme proposed on the site would be designed such to sensitively respond to the risk of flooding on site, through the promotion of this area as public open space. This would ensure that flood
risk on site can be suitably accommodated whilst also enhancing the quality of any development scheme pursued through the provision of high quality public open space. Given that the vast majority of the promoted land at Sutton Road is sited within Flood Zone 1, alongside the Council’s recognition that the site performs strongly in respect of flood risk, Claremont Planning consider that the development of this land would be in accordance with the recommend sequential approach to flood risk in the Plan.

3. Housing for All
Q17. With reference to the options listed above, or your own options, how do you feel we can best plan to meet our need for different types, sizes, and tenures of housing?

3.1. Meeting the need for different types, sizes, tenures of housing by requiring a suitable or negotiable mix of housing that is responsive to the type and location of development, as promoted by Option 2 is recommended by Claremont Planning. It is considered that this represents the most pragmatic approach to meeting these needs by providing flexibility in the market to ensure that the right types of homes are delivered in the right locations. Applying a blanket housing mix policy would fail to recognise that some types of land are more well suited to certain forms of development. For example, both the Housing Topic Paper 2021 and 2017 SHMA establish that there is the greatest need for small and mid-sized semi-detached and detached dwellings.
Claremont Planning consider that the release of Green Belt land, including the promoted land off Sutton Road should be strongly considered by the Council whereby the release of this land will both assist the Council in meeting their overall housing need, and facilitate the delivery of an appropriate mix of housing. In particular this will assist the delivery of family sized housing which
is better suited to delivery on greenfield land than constrained urban sites.

4. Future of London Southend Airport
Q28. With reference to the options listed above, or your own opinions, how do you feel we can best manage the Aiport’s adaptations and growth through the planning system?
[please state reasoning].

4.1. Following the adoption of the current Joint Area Action Plan for the London Southend Airport in 2014, the context for the Airport’s future growth has altered substantially. The consultation document establishes that the Airport’s development will need to respond to the emerging Government Aviation Strategy. Moreover, the COVID-19 pandemic has substantially impacted the Airport, with planned growth now envisaged to take place over a much longer time period than initially anticipated. Claremont Planning therefore agree that it is prudent to prepare an updated Joint Area Action Plan which accounts for both the changed policy, and economic
context of the Airport’s growth.
4.2. The regional importance of the airport, alongside its strategic cross-boundary location within Southend but adjacent to Rochford necessitates that a joint approach for the Airport’s growth is advanced in accordance with a coherent vision. Although Option 2 would satisfy the need for a joint, cross boundary approach to the Airport’s growth, national policy is clear that strategic policies should be focussed on setting overall strategies for the pattern scale and design. As such, development at London Southend Airport would more appropriately be considered within a detailed Area Action Plan rather than through Local Planning Policy. As such, Claremont
Planning would support the pursuit of Option 4, where this Option will ensure that any resultant Area Action Plan can be prepared in accordance with policies contained within the new Local Plan.

5. Green and Blue Infrastructure
Q32. With reference to the options above, or your own options, how do you feel we can best deliver quality green and blue infrastructure network throughout the Plan?
5.1. The Green and Blue Infrastructure Topic Paper 2021 identifies that previous housing and economic growth throughout South Essex has not been sufficient to meet the region’s growth potential. As such, Claremont Planning maintain that although delivering quality green and blue infrastructure is valuable to the wellbeing of Rochford residents, this must be balanced against
the region’s need for growth. It is therefore recommended that identifying general objectives for
strategic green and blue infrastructure (Option 2) is pursued by the Authority, with this Option relying on other existing allocations, such as open space, local green space, and local wildlife site designations to deliver improvements.
5.2. The suggestion identified within the Topic Paper that the Plan could still contain policies that help to deliver improvements to green and blue infrastructure, including the capture of funding through planning obligations associated with development is recommended to be advanced alongside this approach. Advancing Option 2 would continue to promote the delivery of improvements on site where appropriate, without constraining the ability of development to make the most effective use on land by requiring on site improvements to be delivered. Moreover, it is not considered that detailed, site-specific policies are relevant for inclusion within a strategic plan of this nature where national planning policy established in Chapter 3 of the Framework the role those strategic
policies should play, which is to set out the overall strategies for the pattern, scale and design quality of such places. As such, policies relating to the site specific provision of green and blue infrastructure would be more appropriately dealt with through the preparation of non-strategic level Plans and Policies, such as those in Neighbourhood Plans.
5.3. The Green and Blue Infrastructure Topic Paper 2021 also establishes that the connectivity of green and blue infrastructure is challenging, with many poor green and blue linkages between towns, villages, rural areas, and waterfronts. Whilst Option 3, requiring certain new developments to provide local green and blue infrastructure on-site, may increase the quantum of green and blue infrastructure throughout Rochford, there is risk that this may worsen the connectivity of these spaces through their piecemeal development. Contrastingly, securing funding through planning obligations as part of Option 2 could deliver strategic improvements to this network to be made in accordance with a wider vision for the area. This would represent a more effective and deliverable strategy in meeting that criteria for soundness as identified in the NPPF.

6. Town Centres and Retail
Q46. 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 ensure our village and neighbourhood centres remain vibrant?

6.1. Claremont Planning support the ambition of Options 5 and 10 in their recognition that delivering a suitable mix of uses including residential development is essential in continuing to support the viability and vitality of town centres. It is considered important however, that the Council recognise the important of allowing settlements to expand through new development outside of the existing settlement boundary, as this can allow the population of settlements to grow. This in turn can
increase footfall to existing shops and services, and enhance the vitality and viability of these settlements, especially where good pedestrian connectivity to the town centre is present. Whilst it is recognised that the consultation document identifies that town centres within the District have not suffered declines in footfall as acutely as national trends would indicate, further development could ensure that town centres remain sustainable in the future.

7. Green Belt and Rural Issues – Plan Objective 20 (p.69-70)
7.1. The recognition that the release of Green Belt land will be required to meet housing needs through the emerging Plan is strongly supported. It is agreed that the Council can demonstrate the exceptional circumstances necessary to justify this release, in accordance with paragraph 141 of the NPPF. The Consultation Document has sought to establish that a spatial strategy reliant on urban intensification will not deliver sufficient housing to meet the Council’s objectively assessed need, and confirms that early discussions with adjacent authorities have not identified capacity for accommodating unmet need arising from Rochford. As such, it is agreed that the
emerging Local Plan will be able to demonstrate the exceptional circumstances necessary to justify the release of Green Belt land.
7.2. The Rochford District and Southend-on-Sea Joint Green Belt Study (February 2020) supporting this consultation contains detailed site assessments of the contribution made by promoted sites to the purposes of the Green Belt, including an assessment of the promoted land north of Sutton Road at Rochford that is within a wider Parcel 63. The assessment of the land presented within the Green Belt study is supported, where the assessment recognises the diminished contribution
made by the site to the purposes of the Green Belt, particularly safeguarding the countryside from encroachment and preventing coalescence, by virtue of the site’s relative enclosure by the established Rochford settlement. When the harm of the Parcel’s release was assessed at Stage 2 of the Study, it was concluded that moderate harm to the Green Belt would result. Claremont
Planning contest this conclusion, and assert that instead the harm resulting from the Parcel’s release is instead low, or low-moderate. The Stage 2 assessment undertaken recognises that this parcel of land is weaker performing Green Belt due to its high level of containment, going on to establish that by virtue of this containment the release of land in this area would be of no harm to adjacent Green Belt parcels. Due to the recognition within this assessment that the release of
this land from the Green Belt would not be detrimental to the wider Green Belt, the subsequent conclusion that moderate harm to the Green Belt would result, is not considered to be robustly justified.
7.3. National planning policy, chiefly paragraph 142 of the NPPF, sets out that where exceptional circumstances are demonstrated, a pragmatic approach to Green Belt release, giving first consideration to land which is previously developed and/or well-served by public transport, should be advanced. Claremont Planning support the assertion made within the Joint Green Belt
Study paper that the environmental and sustainability effects of Green Belt release need to be considered alongside the harm to the Green Belt of release, where the most sustainable locations for development may not be the areas which would result in the least harm to the Green Belt. Where this nuanced approach to Green Belt release is considered, Claremont Planning contend
that the merits of releasing the promoted land off Sutton Road are especially evident where it has been established that the site represents a both a highly sustainable location for development at one of the District’s main settlements, and a location at which harm to the Green Belt arising from the land’s release is limited. In light of both the limited contribution made to the Green Belt by this parcel, alongside the negligible harm arising from the land’s release and highly sustainable location, it is strongly recommended that the Council consider the promoted land at Sutton Road
for Green Belt release.

8. Planning for Complete Communities
Q57a. Do you agree with our vision for Rochford and Ashingdon? Is there anything you
feel is missing?
8.1. The proposed vision statement for Rochford and Ashingdon is generally supported by Claremont
Planning, where it proposes the further growth and development of the settlement. In particular, the vision statement’s recognition of the settlement’s strategic location close to key employment sites and London Southend Airport, and intention to bolster its regionally significant role is strongly supported. However, it is considered that the proposed vision statement places too great an emphasis on economic growth at the settlement. Instead, Claremont Planning recommend
that the proposed vision statement be amended to include a more balanced and holistic approach
to growth, where it is considered that the Council should recognise the role that residential development has in supporting both the vitality and viability of town centres, alongside a recognition that economic and jobs growth must be supported by sufficient housing provision to
support the local workforce. Moreover, as a ‘Tier 2’ settlement in the District, Rochford represents a highly sustainable location for residential development and should therefore represent a location for significant growth through the emerging Local Plan to assist in meeting the District’s housing needs. As such, it is advised that the vision statement be revised to recognise the role of residential, alongside economic development in realising the growth ambitions of the district.
Q57b. 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?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community Infrastructure [open space, education, healthcare, allotments, other]
4. Other
8.2. Promoted site CFS067 as identified on Figure 45: Map of Rochford and Ashingdon, should be made available for residential development. Through these representations to the Spatial Options consultation, Claremont Planning have sought to identify that the central location of the promoted land at Sutton Road within the Rochford settlement establishes the land as both a highly sustainable, and logical location for further residential development. This assertion is complemented by the 2021 Complete Communities Topic Paper prepared by the Authority within with the promoted land is located within an area identified as having a high walking completeness score of 11-13, meaning that there are a large number of services and facilities located within walking distance of the site. However, the Complete Communities Topic Paper also identifies that whilst the most complete areas in the settlement are located near the town centre, there are areas of low population density in and around the centre where future growth might optimise proximity to services. As established, the land off Sutton Road is entirely enclosed by the established Rochford settlement, and abuts existing residential development and employment
land at all elevations. Given the high walking completeness score of the land, the development
of the site represents an opportunity to both locate development at the most sustainable locations
within the settlement, whilst increasing the number of residents living in ‘complete’ areas.
8.3. The Complete Communities Topic Paper demonstrates that Rochford has good levels of
completeness in respect of access to education, health, civic, and sport and leisure facilities whilst only 8% of the settlement is located within the walking catchment of green infrastructure. It is considered that the release of the promoted land off Sutton Road for residential development represents an opportunity to address this shortfall. Within the south of the site at Sutton Road is
a small area of Flood Zone 3 which is promoted for use as public open space / access arrangements through any development proposal advanced. Moreover, the north-easternmost corner of the land is located within the Southend Airport Public Safety Zone within which
development potential is restricted. As such, this area is also promoted for and provides an opportunity to deliver public open space and ecological enhancement. Through careful scheme design it is therefore considered that any proposed development on site will deliver a connected series of public open spaces and green infrastructure, supporting both recreational activities and
delivering biodiversity gains. Given the relative enclosure of the site by established development, it is considered that both future occupants and residents of the wider site area will benefit from this enhanced green infrastructure provision.
Enclosed : Site Location Plan