Dear Sir / Madam
Rochford Local Plan Spatial Options (Regulation 18)
Thank you for the opportunity to comment on your Spatial Options Document. These representations are submitted on behalf of Rydon Homes which has land interests to the south of Wellington Road, Rayleigh (Call for Sites references CFS053 and CFS086). Rydon is promoting the land for the residential development of around 110 homes (including affordable housing.
By way of clarification, the Rydon representations comprise of the following documents :
- this letter which provides a strategic overview of the issues raised in the Regulation 18 document
- a schedule which provides responses to certain of the questions posed in the
Regulation 18 document
- a Green Belt assessment prepared by Liz Lake Associates
- a Landscape Assessment prepared by Liz Lake Associates
- Transport Strategy site prepared by Vectos
- Local Plan Evidence Base Appraisal Technical Note prepared by Vectos
- Surface Water Flood Risk Technical Note, prepared by Stuart Michael Associates
- Design Assessment prepared by Omega.

Overview of the Regulation 18 Document
The strategic direction of the Reg 18 Plan is strongly supported since it seeks to move towards a more sustainable pattern of development where new development can be low carbon and be located where a good range of facilities can be accessed by foot, cycle or
public transport. It is considered that these over-arching principles strongly point to a strategy which locates most development in the main towns. In this context, Rayleigh should be considered the primary focus for development in the District since
- it is the largest town, by a large degree
- it contains the widest range of facilities, services, jobs and public transport
- it is the only ‘Tier 1’ settlement in the District and is at the top of the District retail hierarchy
- this approach is also supported by the conclusions of your Integrated Impact Assessment.
Whilst it is accepted that major urban extensions can sometimes have the ‘critical mass’ to deliver infrastructure, many Local Plans have been found unsound because of a lack of range and choice of sites plus the delivery risks involved in a strategy based around a very limited number of large sites. A failure of one large site can prejudice the whole plan.
It is for these reasons that in addition to Rayleigh being the primary focus for development in the District, the new housing allocations should be in the form of a mix of sizes and locations around the town. This will allow scope for diversity, choice and the involvement of smaller
housebuilders. It is also a robust delivery strategy. For reasons explained below, it is considered that the land south of Wellington Road fulfils all the objectives of your emerging Local Plan and can assist in improving the ‘completeness’ score of Rayleigh.
The consultation document seeks views on the overall level of development in the District. Comments on the three options are :
- Option 1 ‘Current Trajectory’ (4,500 homes) : This would substantially undershoot the Government’s standard methodology and is a strategy which is likely
to fail at Examination
- Option 2 ‘Standard Methodology’ (7,200 homes) : This is the absolute minimum housing provision needed to avoid the plan being found unsound
- Option 3 ‘Standard Methodology + 50%’ : Whether the uplift is 50% or some other figure is not the real issue. Government policy states that the Local Authorities
should seek to meet the unmet needs of adjoining areas, where this is achievable. In view of this, the Local Plan evidence base should investigate the degree to which
Rochford can exceed 7,200 homes in the period to 2040 in order to meet unmet housing needs from adjoining areas and provide more affordable housing.
For these reasons, the Plan should adopt ‘Option 3’ and seek to provide housing in excess of 7,200 homes.
South of Wellington Road
As noted above, Rydon is promoting 6.31hectares of land south of Wellington Road as a housing allocation for around 100 homes.
In addition to complying with your emerging strategy of locating allocations is sustainable locations where facilities can be accessed by foot, cycle and public transport, the promotion of this site is supported by Rydon’s own evidence base. These documents are attached, but can be summarised below :
1. Green Belt Review by LLA : This report assess the Green Belt role of the site and places this in the context of the Council’s study undertaken by LUC. The main
problem with the LUC report is that its site assessment is insufficiently ‘fine grained’ to pick up smaller sub areas which have development potential within large parcels
which, overall, are not seen as having potential. The LLA report then provides a Green Belt assessment of a sub area made up of only sites CFS053 and 086. This
identifies how this site is effectively an indent in the eastern built-up edge of Rayleigh with development on three sides. It also has a strong tree / hedgerow boundary on its eastern side and its topography slopes inward towards the urban area of the town. In
combination, this means that the site could be developed without materially compromising the purposes of the wider Green Belt around Rayleigh.
2. Landscape Assessment by LLA : This ties in closely with the LLA Green Belt review and demonstrates that sites CFS053 and 086 have significantly different
landscape characteristics from the wider area of open countryside to the east. As such, it is capable (with mitigation) of being developed with limited impact on the
wider landscape.
3. Sustainable Transport Assessment by Vectos : Whilst the Local Plan concept of ‘completeness’ is supported, it is felt that the methodology used is flawed. As a
consequence, sites CFS053 and 086 are given much poorer ‘completeness’ scores than they actually merit. The Vectos report suggests some amendments to the
methodology to make it both more logical and accurate. As a consequence, the Rydon sites, with the existing public footpath / bridleway route to Napier Road and on
to the Town Centre can be seen as very sustainable location. It will also assist the achievement of ‘completeness’ in Rayleigh.
4. Drainage Report by SMA : In response to the drainage concern identified in the Site Assessment, Stuart Michael Associates (SMA) have been commissioned by Rydon
Homes Ltd to assess the impact of the risk of flooding from surface water on the Site.
Whilst the site is located within Flood Zone 1, the site is also identified as being low, medium and high risk of surface water flooding. SMA’s report confirms that any
surface water flooding is constrained to the peripheries and low lying areas of the site within and adjacent to the existing watercourses. Proposals can therefore be brought forward with no risk of flooding. It should be noted that the proposals could also include provision to mitigate risk of flooding to properties outside the site and
downstream of the site.
5. Design Assessment by Omega : The Design report seeks to synthesise all the evidence contained in the Rydon evidence base to produce an illustrative masterplan. This shows a development of between 92 and 110 homes arranged within generous levels of open space. The urban context analysis indicates certain design themes which could be adopted to ensure that a sense of place can be created, as well as somewhere which echoes the essential characteristics of the best of Rayleigh’s urban fabric.

Conclusions
Rydon welcomes the publication of the Regulation 18 document and supports many of its aims and objectives which work towards a more sustainable and low carbon future. As part of this, your own evidence base and the Integrated Impact Assessment would suggest that the town of Raleigh should be the primary focus of new development. Rydon support this and consider that its own evidence base clearly makes the case for the allocation of around 110 homes south of Wellington Road.
Should you wish to discuss these representations in more detail, we would be pleased to arrange an early meeting.

Rochford Local Plan Regulation 18 Spatial Options Consultation
Representations on behalf of Rydon Homes
Responses to Questions
Q2. Do you agree with our draft vision for Rochford District? Is there anything missing from the vision that you feel needs to be included?
A : The draft ‘Vision’ for Rochford contains many appropriate and supportable elements, but it should contain a commitment to delivering sufficient high quality homes to meet need.
Q3. Do you agree that we should develop a range of separate visions for each of our settlements to help guide decision-making?
A : Yes, there should be separate ‘Visions’ for each of the main settlements. This will help capture their diversity and distinctiveness. It may be necessary to have a a generic ‘villages / hamlets’ Vision for the smallest communities.
Q4. Do you agree with the strategic priorities and objectives we have identified? Is there anything missing from the strategic priorities or objectives that you feel needs to be included?
A : The strategic objectives are generally supported. However, the number should be expanded to cover cross-cutting themes. An example would be to make the link between the objective for zero carbon and the concentration of new development in sustainable locations (ie. the larger towns) explicit.
Q5. Do you agree with the settlement hierarchy presented? If not, what changes do you think are required?
A : Yes, the settlement hierarchy is sound. It correctly identifies Rayleigh as the Tier 1 primary settlement in the District.

Q6. Which of the identified strategy options do you consider should be taken forward in the Plan?
A : Dealing first with the level of Growth, Option 1 (Current Trajectory) would fail to meet the standard methodology figure. As a consequence, it is probable that the Plan would be found unsound and fail. Option 2 (Standard Methodology) is the minimum possible figure
that the Plan could pursue and could still be found unsound since it would not be attempting to meet the unmet needs of adjoining local authorities. Option 3 (Standard Methodology + 50%) has the greatest chance of being found sound since it would allow Rochford to meet some unmet needs from adjoining authorities and would allow a greater portion of affordable housing in the District to be met. The reference to 50% in Option 3 is misleading. Option 3 should just have the objective of exceeding the standard methodology figure by whatever the District can accommodate. This may be +15%, it may be +60%. The evidence needs to be produced to justify a specific figure.
With regard to the spatial strategy options, the most sustainable and deliverable option is 2A (Urban Extensions Focussed on Main Towns). However, in reality, this is likely to take the form of Option 4 (Balanced Contribution) since in order to meet the overall housing
provision, there will need to be both urban intensification and some strategic releases at the main towns.

Q7. Are there any reasonable alternatives to these options that should be considered instead?
A : A refined option would be a Balanced Contribution made up of
(i) Some urban intensification
(ii) Small / medium urban extensions at main towns
(iii) A limited number of strategic releases to ‘top up’ the yield from (i) and (ii) to meet the selected housing provision.

Q8. Are there any key spatial themes that you feel we have missed or that require greater emphasis?
A : Zero carbon should be added to the list of 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?
A : A sequential approach to flood risk is both logical and in accordance with the guidance in the NPPF.

Q10. Do you agree that the Coastal Protection Belt and Upper Roach Valley should be protected from development that would be harmful to their landscape character?
A : The Coastal Protection Belt and Upper Roach Valley should have continued protection.

Q11. Do you agree we should require development to source a percentage of their energy from low-carbon and renewable sources? Are there other opportunities in the District to supply low-carbon or renewable energy?
A : Agree in principle, the difficult question is what is the appropriate percentage which is both viable and deliverable.

Q12. Do you agree we should require new development to achieve energy efficiency standards higher than building regulations? What level should these be set at?
A : This may not be necessary since the Government is already proposing to strengthen Building Regulations to deliver high energy efficient standards. If the Local Plan was to propose even higher standards, this would need to be rigorously tested in terms of the impacts on both viability and delivery.

Q14. Do you consider that the plan should include a place-making charter that informs relevant policies? Should the same principles apply everywhere in the District, or should different principles apply to different areas?
A : Yes, a high level ‘place making charter’ would be useful, in principle to provide guidance whilst not being inflexible.

Q15. Are the principles set out in the draft place-making charter the right ones? Are there other principles that should be included?
A : The principles are generally supportable. However, carbon negativity (as opposed to being carbon neutral) is unrealistic.

Q16a. Do you consider that new design guides, codes or masterplans should be created alongside the new Local Plan?
A : Rydon supports this objective in principle. However, design guides, codes and masterplans should only be produced in full collaboration with landowners and developers. Any documents should be regarded as flexible and allow alternative approaches to come
forward, where these can be fully justified.

Q16b. If yes, do you think it is more appropriate to have a single design guide/code for the whole District, or to have design guides/codes/masterplans for individual settlements or growth areas?
A : A single Design Guide for the whole District would become too generic and fail to identify what makes each settlement unique. Settlement specific design guides would be most effective, as long as they do not stifle innovation and can allow alternatives approaches,
where fully justified.

Q16c. What do you think should be included in design guides/codes/masterplans at the scale you are suggesting?
A : It is important that any documents are not too prescriptive and allow a degree of flexibility. All documents should include a date by which they will be reviewed.
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?
A : The appropriate response is to negotiate a site specific mix which is appropriate to the settlement and the characteristics of the site itself (Option 2). National Space Standards are appropriate. The approach to Part M4 of the Building Regulations could reflect that adopted in the London Plan.

Q38. With reference to the options above, or your own options, how do you feel we can best meet our open space and sport facility needs through the plan?
A : Option 4A is the most appropriate solution to meeting open space needs if they can all be met on site. Any needs which cannot be met on site should be met by off site contributions.

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 also ensure our village and neighbourhood centres remain vibrant?
A : Option 2 (incorporating Town Centre policies in the Local Plan) is the most appropriate approach.

Q47. Do you agree with the local centre hierarchy set out in Figure 36? If not, what changes would you make?
A : Given the status of Rayleigh as the Tier 1 settlement in the Settlement Hierarchy and its wide range of shops and services, it should be defined as the only ‘Primary Town Centre’ at the top of the retail hierarchy.

Q56a. Do you agree with our vision for Rayleigh? Is there anything you feel is missing?
A : The Vision for Rayleigh is appropriate in that it captures the need for new allocations to be accessible by foot, cycle or public transport.

Q56b. With reference to Figure 44 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 Rayleigh?
1. Housing [market, affordable, specialist, traveller, other]
2. Commercial [offices, industrial, retail, other]
3. Community infrastructure [open space, education, healthcare, allotments, other]
4. Other
A : Rydon is promoting the residential allocation of sites CFS053 and 086 south of Wellington Road, Rayleigh for around 110 homes. The justification for this allocation is set out in the attached Sellwood Planning covering letter plus
- The Green Belt Review by Liz lake Associates
- The Landscape Assessment by Liz Lake Associates
- The Sustainable Transport Assessment of the Promotion Site by Vectos
- Drainage report by SLR
- Design Assessment by Omega.
In summary, the land being promoted by Rydon accords with the emerging spatial strategy of the Local Plan in that it is located in Rayleigh which is the most sustainable settlement in the District with the greatest range of services, facilities, jobs and public transport. Within Rayleigh, the site is within easy walking / cycling distance of a wide range of facilities and can assist in the achievement of the ‘completeness’ objective of the Local Plan. The development of the site will cause no material harm to the wider Green Belt and countryside since it represents an indent in the built form on the eastern side of Rayleigh, with development on three sides. The eastern boundary of the site is strongly vegetated and when combined with the topography would represent a strong and defensible long term boundary to
the Green Belt in this location.

Q56c. Are there areas in Rayleigh that development should generally be presumed appropriate? Why these areas?
A : Yes, sites CFS053 and 086 south of Wellington Road.
Q56e. Do you agree that the local green spaces shown on Figure 44 hold local significance? Are there any other open spaces that hold particular local significance?
A : The green spaces shown are of local significance and should be identified as such. No additional green spaces should be identified as having local significance.