Executive summary

RW Land & Planning Ltd welcome the opportunity to submit representations on
behalf of J F Spencer & Son Ltd in response to the Core Strategy Preferred Options, published by Rochford District Council in October 2008.
This submission is split into two parts:

1. Core Strategy Representations
It is felt that the "Core Strategy Preferred Options" does not provide a balanced or
justified distribution of the housing numbers throughout the district and that key
sustainability principles have been disregarded when identifying the preferred housing allocations.

Accordingly, it is considered that Hockley, as a first tier settlement within the district should be allocated a larger proportion of the housing numbers in the area already identified on the Key Diagram as being suitable for housing growth (West Hockley).

2. Site Suitability Appraisal - Land and property at Folly Chase, Hockley

A suitability appraisal of land off Folly Chase, Hockley including the residential plot
known as Thistledown, demonstrates its suitability as a deliverable location for housing in line with the Core Strategy principles. The sites location, within walking distance of Hockley town centre and the available facilities, services and public transport links locally and regionally identify this site as being able to meet sustainability principles and should be considered
appropriate for development.

A Masterplan illustrates one of the many ways this site can be developed for housing and provide a deliverable opportunity to provide social housing within a sustainable location, reducing the reliance on the private car.
Appendix 1 - Site Suitability Matrix
Appendix 2 - Site Photographs

1. Core Strategy Representations
Sustainable Community Strategy - Page 6
We welcome the importance the Council place on the close links between the Sustainable Community Strategy and the Core Strategy including ensuring accessibility to services.
Housing Issues and Options - Page 16
We welcome the acceptance by the Council that infilling alone will not be able to provide the housing numbers necessary and that this would have an adverse effect on the character of the towns.

Whilst we acknowledge that the release of greenfield sites for development present
an opportunity to provide new infrastructure, it is surely more sustainable to concentrate additional housing on greenfield sites which benefit from existing infrastructure and nearby services. This would then enable Planning Obligations to improve services and facilities rather than having to focus on providing basic
infrastructure.

Transport Issues and Options - Page 18
It is acknowledged within the Core Strategy that car dependency within the district
is higher away from the main three settlements of Rayleigh, Hockley/Hawkwell and
Rochford/Ashingdon, primarily due to the rail links within these three towns.

This principle of sustainable development therefore dictates, unless there is a justifiable reason, that the majority of the housing proposed should be within or adjacent to the main three settlements.

Settlements Issues and Options - Page 20
We welcome the four tiers of settlements and the Council's acknowledgment that Hockley is classed as a Tier One settlement containing a "local town centre catering for local need".
We also agree that the Second tier Settlements of Hullbridge and Great Wakering have a "more limited range of services access to public transport is relatively poor".

H1 Distribution - Preferred Option
We acknowledge that brownfield sites should take priority over the development of
Greenfield sites. However, with a rising housing market over recent years, many of the sites identified in the Urban Capacity Study still remain undeveloped it could be argued that if the sites were suitable for development they would have come forward by now. The Council must therefore demonstrate that there is evidence to
suggest that the remaining sites are genuinely available and deliverable within the specified phased timescale.

If they are not deemed to be available, the housing must be allocated on greenfield sites associated with a Tier One settlement.

H2 General Locations and Phasing - Preferred Option

It is welcomed that the Core Strategy accepts that greenfield development will be necessary in order to achieve the required housing numbers.
As set out in the H2 chart and Key diagram, the reliance of Tier Two and Three settlements (Hullbridge, Great Wakering and Canewdon) to provide 860 houses pre 2021 is unsustainable, unjustified and contrary to sustainable planning
guidance at national, regional and local level.

It is acknowledged by the Core Strategy that the Tier Two and Three Settlements only having limited services and poor public transport links and despite this, over 34% of the greenfield housing allocations have been located here without justification.

We acknowledge that development in Tier Two and Three Settlements is necessary to ensure that village communities continue to grow. However, there has been no justification provided that warrants such a large percentage of the overall housing numbers being allocated to these lower tier settlements.

The distribution of the greenfield housing allocations as it stands is contrary to PPS3 which provides clear local level guidance for Core Strategies when deciding on housing locations:
"...at the local level, Local Development Documents should set out a strategy for
the planned location of new housing which contributes to the achievement of
sustainable development." Part of which is "...the contribution to be made to cutting carbon emissions from focusing new development in locations with good public transport accessibility and/or by means other than the private car..."
Even with significant public transport improvements, residents will have to travel a
substantial distance to Rayleigh, Hockley/Hawkwell or Rochford/Ashingdon in order to catch a train and go beyond the local area. This level of development in the lower tier locations are promoting a significant increase in carbon emissions, contrary to PPS3, even if the residents travel by public transport, which the Core Strategy accepts is not the current situation, with high car dependency.

Despite being a Tier One Settlement with an active and diverse town centre and good public transport including a train station, Hockley has only been allocated 50 houses (2% of the total greenfield allocation within the district). This goes against the Core Strategy vision of concentrating development on Upper Tier settlements which have the services and facilities to accommodate additional development.
In light of this unsustainable and unsound approach to housing distribution, Policy H2 General Locations and Phasing - Preferred Option and the Key diagram should be amended to reduce the proposed housing numbers associated with Tier Two and Three settlements and redistribute the surplus to Tier One Settlements and Hockley in particular which has received an unnecessarily low number of houses
despite existing services and facilities to accommodate additional development.

It is proposed in the analysis set out in Appendix 1 that Land at Folly Chase, West Hockley is suitable and capable of accommodating circa 200 houses. Policy H2 should be amended to reflect this.

We welcome a flexible approach to the release of land in order to maintain a five year land supply is supported and necessary. It is imperative, however that in assessing the release of land, the landowners willingness to sell or develop the site is taken into account.

We welcome the identification of West Hockley as being a suitable location for development pre-2015.

H2 Alternative Options
We welcome the comments regarding North East Hockley and agree that the location would place undue pressure on the highway network and that it is unviable for development.

H3 General Locations - Post 2021
The continued reliance on lower tier settlements post 2021 is again unjustified and
unsustainable with 340 homes proposed. These locations, even following improvements to the infrastructure will not provide genuine alternatives to the private car due to the length of journeys required to get to services, facilities and employment.

H4 Affordable Housing
The 35% level proposed must be based on sound qualitative evidence with the flexibility to be reduced if there are site specific circumstances that warrant it.

We do not accept the desire by the Core Strategy to "pepper pot" social housing
throughout developments, it causes difficulty for Housing Associations to manage their properties effectively and efficiently. This should be amended to allow for clusters of social housing units in say, groups of 15-20.

H5 Dwelling Types
Whilst we acknowledge that PPS3 suggests that local level planning documents should assist in developing a suitable mix of houses on sites, PPS3 para 23 also states that developers should "...bring forward proposals that reflect demand and the profile of households requiring market housing...". It is therefore imperative
that H5 makes reference to the influence of market demands and does not solely
rely on the advice of the Strategic Housing Team as the policy currently intimates.

H6 Lifetime Homes
We welcome the fact that the pursuit of 100% Lifetime Homes from 2010 will be viability tested.
H Appendix 1

We welcome the associated infrastructure required in relation to development at
West Hockley.

As part of the development of Land off Folly Chase, Hockley, further community benefits beyond those listed could be included, such as a new community woodland and play space.
Proposed development at the lower tier settlements (Hullbridge, Great Wakering
and Canewdon) are reliant on significant public transport improvements which sequentially is contrary to sustainability principles of focusing development in areas of good public transport, with the ability to improve further.

ENV3 Flood Risk
We welcome the proposal to pursue development in areas which fall into Flood
Zone 1 and the use of the sequential test in PPS25.

ENV4 Sustainable Urban Drainage
SUDS is not always the best environmental option for dealing with drainage. We welcome the viability test intended to identify those sites where SUDS is not appropriate.

ENV8 Renewable Energy
We recognise the Core Strategies desire to adhere to the Code for Sustainable Homes star rating, however, there remains a doubt as to whether Code Level 6 is realistically achievable within the current timescales. There will always be the potential for National Policies to alter the rating system and timescales. There is a
requirement for the Core Strategy to remain flexible and be in parity with The Code for Sustainable Homes, or its successor. Moving away from the Code should it alter, would alienate the Districts development sites from developers and reduce the likelihood of them being built within the Core Strategy phasing timescales.

We welcome the decision to not pursue the 10% renewable "Merton Rule" as piecemeal renewable energy production is not an efficient approach to its production.

T1 Highways
We welcome the objective to locate and design housing developments that reduce the reliance on the private car.

T2 Public Transport
We welcome the objective developments must be well related to public transport, or accessible by means other than the private car.

RTC1 Retail
We welcome the designation of Hockley as a district centre and that retail developments will be focussed towards it along with Rayleigh and Rochford.

RTC5 Hockley Town Centre
We welcome the proposals contained within this policy for the improvement of facilities, services and town centre living within Hockley Town centre.

CLT1 Planning Obligations and Standard Charges
We welcome the continued use of Planning Obligations to secure reasonable on and off site improvements as set out in Circular 05/2005.
Standard charges must take into account the level of impact the future residents are likely to have on the strategic infrastructure and be negotiated on a site by site basis.

[more details including photographs regarding the site put forward can be found our ref allocations no. 69]