Section 3 - The Relationship of Documents

Referring to your letter of 21st May and subsequent telephone exchange enquiring where I could view the above strategy, since as a pensioner I don't have the financial ability to own a computer. I thought that planning would have foreseen the need to incorporate this information in your letter of the 21 May.

I moved to Rayleigh in 1956, having been attracted to the Ancient Buildings in the High Street, alas "Planners" all but destroyed the old world charm that had existed by pulling down much of the old buildings and replacing them with modern monstrosities.

In 2003 Planners completely spoilt my wife and self's enjoyment of our retirement by granting planning permission for an extension to the rear of no 68 Hasbro Avenue, although I protested pointing out the loss of light that would be caused to my only living room my protest was ignored by planners, also a local Rayleigh Bylaw which restricted extensions from going beyond the existing building line was ignored. (my wife died some 14 months later, her dementia having been aggravated by both the noise and need to have the light permanently on).

Having read and tried to absorb the Core Strategy I must say it was long in wordage but short on fact such as when, where and how. I list below comments

2.6 A mix of housing and local facilities, (perhaps sewers, water, electricity and gas, or maybe the long awaited Rayleigh Swimming Bath) a swimming Bath for Rayleigh was promised in the early 60's but never reached the planning stage.

2.7 Cherry Orchard Jubilee Park now has a car park, great but no Bus service or is it only for the use of Rochford residents.

2.8 New terminal and rail station for Southend Airport great news but not of much interest to commuters who already have difficulty getting seats, an increase in travellers will be detrimental to Rayleigh people, as it is likely that seats will be filled prior to arrival at Rayleigh Station.

2.10 A new Health facility for Rayleigh, this is much needed, but will it be like the one that the developers were supposed to provide on the ASDA site off Rawreth Lane.

2.11 Traffic congestion in Rawreth Lane is already a nightmare at peak times by the time ASDA becomes operational there will be Gridlock, especially if the section from Rawreth Industrial Estate to the Traffic Lights is not widened.

2.13 There is no mention of affordable housing, this means that the youngsters whose education we have paid for will leave the area in search of affordable housing.

2.14 Why not include Rayleigh.

2.16 No disabled parking available.
2.20 Green for how long.

2.21-22 Not relevant to older people.

2.23 First mention of Senior Citizens, we are probably the major part of the electorate.

2.24 Surely council housing is the answer.

2.25 There does not appear to be much in this for Rayleigh, and north Rayleigh where all the latest development has taken place is ignored.

Section 3 this is for the most part theory.

Section 4 Why is the Upper Roach Valley a Core issue.

4.5.6 Bad neighbours surely this is for the police and social services to oversee.

4.6 Development, where is not mentioned is this to hide the fact that more Greenbelt land is to be taken. Rayleigh is to have a further 1800 units where in Rayleigh is not stated but will almost certainly be north Rayleigh where we currently have power cuts due to overloads caused by the 400 or so extra units built off Rawreth Lane. Sewage is on the limit of the sewage works to handle. Roads as mentioned previously are reaching saturation point in this area particularly during school runs and market day.

4.6 Sustainable development is at odds with the infrastructures ability to cope.

4.12 Energy conservation - for my part I do the best that finances permit being disabled I use a diesel car with very low emission rate and high mpg, I turn the gas on once a day to heat my water, and the central heating is only turned on in winter when extra clothes fail to keep me warm.

5.1 Thames Gateway is to be mainly built on the Thames flood plain and this will be disastrous when the promised sea levels rise. What is Rochford planning to do about flood protection, at least Rayleigh is mostly above the projected sea level rise, whereas Rochford is not neither are Paglesham, Wakering, Fambridge south or Hullbridge and Battlesbridge.

Paragraph 3.9 indicates that there will be a Joint Area Action Plan for the area to the west of Rochford which includes the Airport. This should be noted as being joint with Southend-on-Sea Borough Council. Paragraph 3.10 says that the Core Strategy should concentrate on areas where there is a need to reflect national guidance on a particular local characteristic. This is particularly the case for the Airport, where national policy needs to be directly related to a local policy.

It is noted that this Section makes no reference to the background of supporting documents to inform the Core Strategy Options. It is critical that the absence of an Urban Capacity Study, Strategic Housing Market Assessment, Housing Needs, Housing Strategy and Housing Land Availability Assessment, which are of course key documents necessary to underpin the Core Strategy, do not appear to have been undertaken or made available. All the material that will be relied upon by the Council as the Core Strategy proceeds to submission should be made available. The Planning Inspectorate and PPS12 confirms that options should be informed by the evidence base and that this should have been completed at this preferred option stage ("Development Plan Examinations - A Guide to Assessing the Soundness of Development Plan Documents").Of further concern is the lack of a sustainability appraisal. Whilst an appraisal was undertaken at Regulation 25 pre-submission stage PPS12 confirms at 3.18 that, "in accordance with Regulation 26, local planning authorities must undertake a sustainability appraisal of the preferred options and prepare a final sustainability report for consultation alongside the preferred options document".Against this background it is submitted that the Preferred Options Draft document is fundamentally flawed. Consideration should be given to withdrawing the Document until the appraisal and the evidence is completed to ensure that preferred options have been properly examined and consultation has taken place.The implications of the lack of the evidence base suggests that any future publication will be produced retrospectively to justify the content of the Core Strategy. This is considered unacceptable and contrary to the core principles for the Local Development Framework process.

Following my discussion with Samuel Hollingworth, in accordance with advice and the difficulties in submitting online please find attached our representations on behalf of Mr B Coker & H.R Philpot & Sons (Barleylands) Ltd in respect of the above

Section 1 Spatial Portrait

Page 2 Clause 1.7 Does not mention the supermarket now under construction at the Park School site.

Section 2 Spatial Vision

Clause 2.5 This appears to be at variance with proposals later in the document for large amounts of new residential development, which will of necessity mean releasing large areas of green space.

Clause 2.10 There is no evidence to support this assertion. Judging on past performance and lack of drive from the local P.C.T this can only be described as a "wish list" and cannot be substantiated by firm proposals

Section 3 Relationship of Documents

Clause 3.9 The key diagram forming part of this document is very difficult to follow due to the lack of easily identifiable features and has been the subject of adverse comment by members of the public who have seen it. It would benefit from the addition of main roads, the railway line etc.

It appears that the objective of avoiding duplication (3.10) has resulted in the proliferation of a multitude of documents at considerable cost in time and effort to the Council, which could be rendered obsolete overnight at the whim of Central Government.

Section 4 Core Strategy Issues

Clause 4.2.2 Policies SS1 and SS7 of the East of England Plan confirm the need to maintain the Green Belt boundary. However, the proposals later in the document to site a further 1800 dwellings in Rayleigh will require a relaxation and the use of areas of Green Belt.

Development in the Rawreth Lane area is already up to the Green belt boundary and there appears to be no other substantial areas identified in the town capable of absorbing this number of new dwellings.

Clause 4.2.6 and 4.2.7 The strategic buffer between Rayleigh and Rawreth would obviously be in Rawreth Parish and any further development in the area would, in fact, have to take place in the parish of Rawreth unless the boundaries are redrawn.

Clause 4.3.8 It needs to be emphasised that the country park is at the eastern boundary of the district.

Clause 4.4.5.iii States that the area is remote and undeveloped. This is not true of the area around Battlesbridge at the western boundary of the district

Clause 4.4.9 This does not appear to be included on the key diagram

Clause 4.4.14 Would it be appropriate to indicate which of these sites are open for public access?

Clause 4.5.4 Windfall sites should be taken into account since they contribute to a reduction in pressure on the Green Belt

Clause 4.5.5 Central Government has stated that Thames Gateway development will be housing led and it follows from this that it is not possible to rely on infrastructure improvements

Clause 4.5.6 This is a very laudable aim. However, a similar statement was removed from the Replacement Local Plan prior to adoption. It is considered essential to retain this.

Clause 4.5.9. It is true that the Council has no control over the total number of dwellings. However, the East of England Plan does not specify their distribution. This is something that the Council has complete control over and this should be made clear.

Clause 4.5.11 The second bullet point is not specific enough, densities should be set out in this document.

Clause 4.5.12. Windfall development should not be ignored.

Clause 4.6.3. Though these areas have a good range of services they are under extreme pressure and are not able to accommodate further increases in population without considerable upgrading.

Clause 4.6.4. These areas should be brought up to a standard which would make them suitable to take a fairer share of increased development.

Clause 4.6.9. It is incorrect to state that all settlements have had more than their fair share of housing .There is one area that has had more than any other:- WESTERN RAYLEIGH

Clause 4.6.10 It is considered that the allocation must take into account the fact that Rayleigh has taken the lions' share of development in the district to date.

It is unacceptable that the majority of the proposed future development should fall in Rayleigh. The split must be reviewed.

Clause 4.6.18. This is at variance with the fact that the A127 is not anymore considered by the Government to be the main road distributor for S.E.Essex. This is proven by the fact that the A13 is now the main trunk road connecting to London and the A127 has been demoted to a mere County route.

Clause 4.6.20 This is no worse than the daily congestion in Rawreth Lane which is due to get worse on completion of the ASDA superstore.

Clause 4.6.21 Mentions protection of Rochford's Conservation Area. There is no similar statement about Rayleigh's Conservation Area

Clause 4.6.23 Believe the figures are flawed and unbalanced

Clause 4.6.23 This statement needs to be far more robust with greater emphasis on transport infrastructure etc. improvements preceding housing development

Clause 4.7.10 Much affordable housing appears to be being purchased on a "buy to let" basis for profit. The policy needs to contain means for discouraging this practice.

Clause 4.8 Employment. For the forseeable future the main employment pattern is likely to be commuting to London. Until higher salary employment is the norm. in the district it will be difficult if not impossible to meet these targets.

Clause 4.9.9 Generally agree though 25% appears to be a rather low figure.

Clause 4.10.3. Corporate identities etc. have often in the past been used as excuses to ignore Conservation Area requirements, particularly with shop fronts and signage. This statement needs to be made more robust.

Clause 4.10.8. Should be reworded to contain specific reference to Conservation Areas

Clause 4.14.3. This is impractical:-Where hotels don't already exist in town centre locations there is not much possibility of hotel development due to lack of suitable sites

Section 5 Implementation & Monitoring

Clause 5.4 Rochford and Castle Point PCT no longer exists as a separate entity.
Also the steering group should include secular groups as well as faith groups eg: Essex Humanists (who are affiliated to The British Humanist Association)

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

Plesae find attached our representations on behalf of Trinity College in respect of the Core Strategy (Reg 26) Preferred Options Draft Consultation.

Rochford District Core Strategy Preferred Options (Regulation 26) Draft:
Consultation Development Plan Document (DPD)

I refer to your recent statutory consultation on the above Development Plan Document
and subsequent telephone conversation with Bob Preston about Southend's delay in
making formal representations.

Please find attached Southend Borough Council's representations on your Core Strategy
Preferred Options Draft and trust that they will be given due consideration.

For your information, these comments at this time are still subject to approval by
members. I will confirm the Council's agreed position after their Cabinet meeting on 25th
September 2007.

I trust this is in order.

Main Points

1.1 The Rochford District Core Strategy should address:
* The expansion plans for London Southend Airport and related development. There should be a Core Strategy Policy stating clearly that a Joint Airport Area Action Plan (JAAAP) is being developed with Southend on Sea Borough Council. The policy would need to be clear about the potential for change within the area covered by the Area Action Plan. This should include Airport expansion plans, the development potential for additional employment land and the implications in terms of rolling back the green belt boundary in this area. The broad location of the JAAAP should be shown on the Key Diagram;
* transportation and accessibility issues including strategic road and rail links and address associated cross boundary issues such as SERT. For example the core strategy should identify potential locations for a Park and Ride Scheme on the A127 as part of 'SERT' and surface access improvements to London Southend Airport, including the new railway station. These elements should also be shown on the Key Diagram;
* the proposal within the Southend on Sea Core Strategy Core Policy CP7 to support development of a new Country Park facility located between Great Wakering and Shoeburyness and show the broad extent of the proposed Country Park on the Key Diagram.

Specific Comments

1. A Spatial Portrait of the Rochford District

para 1.4 The spatial portrait of Rochford provides an insight to the district and provides a context in which planning policy in the Core Strategy needs to be developed. As such it would be helpful if there was more detailed information about where the district's residents work and their mode of travel as well as commuting patterns into the district if significant. Further description could then follow about the district's role and connectivity with London, Essex Thames Gateway and the rest of the region. This would link with the discussion about transport infrastructure in paragraphs 1.9 to 1.11.

para 1.9 In light of the above comments it would also be helpful to set out, in the paragraphs about transport infrastructure, key linkages with areas outside the district such as London and Thames Gateway South Essex and Chelmsford. Clearly the A127 and A130 and the Southend Liverpool Street railway line are strategic transport linkages to London and the rest of the Gateway. These, together with national and regional cycle routes, should be identified on the Key Diagram.

Paras 1.11
& 1.12 Also significant to transport linkages is London Southend Airport which lies within the district. Whilst it is mentioned here, both its current and future significance, through expansion plans, for both transport (including surface access) employment generation, and the Green Belt is not addressed fully. Clearly the Core Strategy will need to consider these issues and establish a policy context within which the Joint Airport Area Action Plan can be developed. It would be helpful therefore for this section to fully develop the context in which London Southend Airport sits.

2. Spatial Vision for the District

Paras 2.7
& 2.17 The Southend on Sea Core Strategy DPD Policy CP7: 'Sport, Recreation and Open Space' supports the development of a new Country Park facility, as part of the development of a Green Grid of open spaces and associated linkages throughout Essex Thames Gateway. This is nominally located towards the north east of the borough, with potential to cross the border into Rochford district and shown on the Key Diagram. Southend Borough Council considers that such a proposal aligns with Rochford Council's objective of preventing coalescence in the area between Southend/Shoeburyness and Great Wakering and reinforces the visitor recreation and leisure role that Rochford uniquely holds both for its own residents and those of Southend. It would be helpful, therefore, if the spatial vision in either the 5 or 10 year periods reflected the proposal for a Country Park between Southend/Shoeburyness and Great Wakering.

3. The relationship of documents in the Local Development Framework

Para 3.9 In the text box detailing the set of Development Plan Documents there is reference to a 'Joint Area Action Plan covering land to the west of Rochford'. It is unclear whether this refers to the Joint Airport Area Action Plan or not. It would be helpful if this is the case that the word 'Airport' is included within the title of this AAP. If it is not, then clearly the Joint Airport Area Action Plan should be included within this section, particularly as there has been a formal resolution by both Councils. In addition, it is considered essential that the broad locations of the proposed Area Action Plans are shown on the Key Diagram.

4. Core Strategy Issues

Para 4.1 Rochford District contains an Airport and strategic road and rail links with demanding cross boundary issues that need to be addressed. The spatial portrait also highlights issues of congestion and accessibility both in terms of the road infrastructure and the inadequacies of public transport. Southend Borough Council considers it essential that 'transport infrastructure and accessibility' should be a key policy area within the Core Strategy and it should address strategic issues such as support for the Airport expansion and surface access solutions, SERT, public transport improvements and cycling and walking.

It is noted in paragraph 3.10 that the Core Strategy intends to avoid duplication between local and National policies particularly in relation to green belt and development in flood risk areas. However, flood risk and climate change are key challenges for all LPAs particularly in this area and the Core Strategy should specifically refer to how it will address flood risk locally.

There also appears to be a lack of consideration of sports and recreation provision outside the management of protected open spaces which are intrinsically attractive because they are natural habitats.

4.2 The Green Belt & Strategic buffers between settlements

Para 4.2.1 Southend Council agrees that as a matter of principle, Green Belt land should be protected, and where possible brownfield land should be given priority for development. It is also noted that a Strategic Review of the green belt boundary is not considered appropriate at this stage in line with RSS Proposed Changes Policy SS7 and that the preferred option is to continue its restrictive suite of policies for development within the Green Belt.

Para 4.2.7 However, the preferred option indicates that there may be some relaxation for major developed sites, green tourism and renewable energy proposals. Southend Borough Council considers it essential that the Core Strategy specifically addresses the need to review the Green Belt boundary within the proposed boundary of the Joint Airport Area Action Plan. The preparation of this AAP has been agreed by both Councils and work is underway on developing the plan. It would be inconsistent therefore not to address Green Belt boundary review in this area within the Core Strategy both in policy terms and on the Key Diagram.

Para 4.2.4 In addition, Southend Borough Council is unclear as to the need for another tier of protection to land already identified as Green Belt, as implied by the proposed designation of Strategic Buffers, particularly as these areas are subject to a continued application of Green Belt policy. However, should they be areas where particular enhancements or management for recreation were needed then this Council would recommend that the proposed Strategic Buffer between Great Wakering and North Shoebury be proposed as a Country Park to complement Policy CP7 in the Southend on Sea Core Strategy DPD.

4.8 Employment

para 4.8.3 The recognition of the potential of London Southend Airport to be a catalyst for employment generating uses providing jobs for local people is welcomed.

Para 4.8.5 This paragraph indicates that additional jobs growth in the district will be accommodated within, London Southend Airport, Rochford Business Park, and various locations throughout the district. These locations should be shown on the key diagram. In addition
Southend Borough Council consider that the Core Strategy Policy dealing with employment should state clearly that a Joint Airport Area Action Plan is being developed with Southend on Sea Borough Council and both show the broad area that the AAP will cover on the Key Diagram and be clear within the policy about the proposal in terms of the expansion of the Airport, the development potential for additional employment land etc and the implications in terms of rolling back the green belt boundary in this area.

4.14 Community, leisure & tourism facilities

The approach to the provision of community (which should include education, health and social care facilities) and leisure facilities appears to be criteria based approach for dealing with planning applications for such uses in an appropriate manner. Whilst this is necessary, it would also be helpful to have an overview as to the locational requirements of other agencies dealing with health and social care provision.