Introduction

1. The following representations are submitted on behalf of Mrs L Byford who owns a significant area of land on the north eastern edge of Rayleigh, including an area of farm land and employment land adjacent to the north eastern boundary of Rayleigh together with horse related uses adjacent to Home Farm on the western edge of Hockley. In general terms her land ownership is bounded by the railway line to the north, Hockley to the east, Hockley High Road to the south linking Rayleigh and Hockley and Rayleigh itself to the south west bounded by Hambro Hill.

2. Within this area of land we believe that there is scope for a residential and mixed use allocation adjacent to Hambro Hill and this area is identified on the attached plan.

3. We welcome the consultation on the Preferred Options, and comment below on specific options raised within the document under those headings set out in the document itself.

Green Belt & Strategic Buffers Between Settlements

4. Whilst we note that the Council proposes to continue its restrictive suite of policies for development within the Green Belt in accordance with PPG2, we note that the Council in addition to this proposes to establish strategic buffers between key settlements which will be defined and protected by policy and included on the Core Strategy key diagram.

5. Whilst we accept the reasons for this designation we do consider that it unnecessary duplicates Green Belt policy particularly given that the first two purposes of including land in Green Belts as defined by para 1.5 of PPG2 are to check the unrestricted sprawl of large built up areas and to prevent towns from merging into each other.

6. If the green buffer designation is to be included within the Core Strategy and defined in more detail on proposal maps, there must be defined accurately to exclude those areas that do not fulfil Green Belt objectives and/or those areas of land that could be developed without impinging on the broader objective of avoiding the merging of separate towns.

7. In particular it is important that development within the strategic buffers that accords with paragraph 1.6 of PPG2 in terms of the use of land in Green Belt in particular in providing opportunities for outdoor sport and outdoor recreation near urban areas is retained and that the strategic buffer designation does not offer an additional layer of policy which overrides the Green Belt designation and related policies.

Housing Numbers and Phasing

8. The draft East of England Plan makes clear that the housing allocation figure for individual districts must be based on minimums rather than maximums and these should be reflected in this section. Whilst the Core Strategy and Site Allocations document will no doubt seek to identify as many urban capacity sites as possible, it is inevitable some windfalls will emerge and given that this source should not be used towards meeting housing supply in the first ten years as set out in PPS3, it could be that the minimum allocation could be exceeded by the windfall factor.

9. Whilst we accept from paragraphs 4.5.9 and 10 that housing numbers and intensification of the existing urban area, together with the Green Belt releases are politically unpopular, we do support the Council's stance that housing numbers are not matters under its control and that the Council has a responsibility to ensure that the new homes are built and released in order to ensure that land supply is available.

10. The compromise to the Council in releasing land from the edge of settlements is supported and this accords with the thrust of PPS3. As such we support the Council's preferred option in relation to housing numbers and phasing subject to comments above on the figures being seen as minimums and this being reflected in the final policy.

General Development Locations

11. We support the settlement pattern being based on existing settlements with the three main settlements being Hawkwell/Hockley, Rayleigh and Rochford/Ashington taking the majority of new development which is defined as 90% of the housing development required. These settlements do have a good range of services and facilities together with access to public transport, unlike the second and third tier settlements which by comparison are considerably smaller and with a consequentially much poorer range of services.

12. In particular we support the Council's preferred options for general development locations in relation to the split between settlements as this appears to be proportionate to both the size of settlement and the range of services within each. We particularly support the rejection of alternative options as these clearly failed to meet sustainable development objectives and indeed and would be inconsistent with the approach of PPS3.

Employment

13. We consider a criteria based approach towards the retention of existing employment land in the district should form part of the Council's preferred options for employment not necessarily to ring-fence all employment land in existing use but to ensure that new allocations do not simply make good ongoing losses in employment land to other uses and to ensure that new jobs are classed as net additions to the existing stock.

Community, Leisure & Tourism Facilities

14. It is important when setting out a policy dealing with leisure proposals to set out the Council's preferred option such that this provides clarity for development particularly those located within Green Belt locations where paragraph 4.14.5 of the core strategy preferred options is a little vague. As set out above it is important that those uses considered appropriate for Green Belt locations are expressed clearly in the document and that this accords with PPG2, with particular regard to horse riding facilities and the encouragement of such facilities in the countryside as set out in the Replacement Local Plan under Policy LT14.

Land at Home Farm

15. The area of land on the north eastern edge of Rayleigh which forms part of Home Farm which is considered appropriate for housing and mixed use development is indicated on the plan attached to these representations. It is contained by the woodland to the east and by the existing area of open space, a railway line to the north and west. Adjacent to the site is an existing employment area which could be retained or redeveloped as appropriate. Whilst the land falls to the north, the small area is visible between the wood and the open space can be contained by new planting and or an extension of the woodland to increase the local biodiversity as part of the development.

16. Part of the site is used for sand extraction for specialist brick making and this area of land is despoiled and the allocation and development of the site will clearly resolve this particular issue. In addition the area of open space north of Hambro Hill to the east of the railway line at present does not have public access, despite being defined as local open space on the Replacement Local Plan, and is therefore not available to the general public, this might be closely related to the substantial residential estates of northern Rayleigh which themselves are deficient in open space. This position could be resolved by the allocation of the site which could include the area of open space and ensure that public access is gained to it, together with an enhancement of the appearance and the facilities within the open space.

17. Given that development to the north of Rayleigh, west of railway line together with development along Hockley Road extends the settlement boundary of Rayleigh beyond the representation site, allocation of this land would not impinge on the strategic gap between Rayleigh and Hockley and for the same reason the land does not fulfil a cogent Green Belt purpose. Allocation of the site would create a more logical and a defensible Green Belt boundary as well as being a clearly defined edge to the strategic gap as defined on the attached plan.

18. On behalf of our clients we welcome the opportunity to be involved in this stage of the production of the core strategy and look forward to being involved in further development of the local development framework.

19. Please do not hesitate to contact us should you wish to discuss the above or the attached in more detail.