Section 4 - Core Strategy Issues

The Core Strategy summary document available to residents fails to recognise the absolute imperative of establishing the onus of responsibility on the Local Authority to work with the County Council and Central Government to ensure significant improvements to the road infrastructure. In particuler, an alternative route must be created to enable traffic not requiring to visit Rayleigh to avoid the town completely, as the congestion caused by through-traffic is currently unacceptable and can only get worse still with the development proposals set out in the document.

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.

ROCHFORD DISTRICT COUNCIL
LOCAL DEVELOPMENT FRAMEWORK
CORE STRATEGY PREFERRED OPTIONS
(REGULATION 26 DRAFT)

My name is Dudley Ball. I have set out my personal response to the LDF document below. The views expressed are entirely my own but are being submitted by my Agents, Edward Gittins & Associates, Planning & Development Consultants, The Mount, Huxtables Lane, Fordham Heath, Colchester Essex, CO3 9TJ.

RESPONSE STATEMENT

PREFACE

"For the last 14 years Rochford District Council have wilfully promoted the idea that the Green Belt for this part of the District was first introduced in 1964 and thus post dated the planning permission for the additional 2 dwellings obtained by my father in 1962 on the whole of the disputed part of Westview, Church Road, Hockley.

Their version of the planning history is patently untrue as proved by their past Local Plans. The true account is that in 1964 this was merely an approved review of a green belt situation that had already been imposed in 1961 and as supported by the then Minister of Housing and Local Government in at least one local planning appeal.

Therefore the planning permission in the Green Belt granted in 1962 for the 2 dwellings proves beyond reasonable doubt that that part of Westview was never intended to form part of the Green Belt. The placing of the Green Belt boundary in a bisecting position in 1964 was and is quite clearly a gross error that has been sought to be concealed by RDC by their promotion of the misleading falsehood of dates that they have consistently repeated to numerous planning Public Inquiries on Westview and that have been accepted by those Inspectors to my severe detriment.

It will be shown that these statements were wilfully made by the production of documentary Council produced evidence.

Therefore all policy issues arising in the LDF process are subordinated to the overriding issue of the LPA promoting a false history to support their policy position to cope with the threat I evidently pose to them after all this time.

It is high time that this injustice to me is righted and the full development rights be reinstated for the northern half of Westview. This evidence forcefully underlines the following case for the release of the said land.

The planning permission granted in the Green Belt in 1962 for 2 houses and past Local Plans all say that the Provisional Green Belt was imposed in 1961 and supported by the then MHLG in planning appeals. It was informing/directing the planning development process at the local level.

Perhaps then in this LDF process the LPA can explain why they have felt it necessary to promote their version of crucial historical events that have led to so many of my past planning appeals being dismissed on those precise Green Belt grounds?

RDC have been notified on two specific occasions to rebut these direct allegations of mine in 2005 and so far have failed to do so. Thus the inception of this latest process gives them the fullest opportunity to explain themselves given the crucially direct bearing this matter has in the consideration of the future of the remainder of Westview.

Thus following the above accusation and claim supported by documentary evidence I set out my observations on two key areas of the Core Strategy, namely The Green Belt and then Housing."

1.0 THE GREEN BELT

1.1 The briefing note that accompanies the Core Strategy document refers to the fact that the Green Belt (GB) and the
strategic buffers it will provide will "have their precise boundaries determined during the Allocations Development Plan Document (DPD)".

1.2 It is notable that the north side of Hockley where Westview lies is the only part not identified to have strategic buffers. Thus the issue of the future location of the GB boundary at Westview can be of no importance or threat to that declared strategy. Thus the appropriateness of the GB boundary randomly bisecting the site can be comfortably reconsidered in the light of the matters raised in the above preamble.

1.3 I submit that even in isolation from the disturbing evidence I set out in my Preface, the land does not genuinely and credibly fulfil any true GB function as set out in the five purposes of the GB that are specifically recited in the Core Strategy Document (CSD).

1.4 How has the partial Green Belt designation of Westview practically and directly served any of the stated local objectives? I would draw attention to the CSD para 4.2.1 that, after declaring its GB policy a success, sets out some protective effects that arise from this policy.

1.5 Thus:-
i) It claims it has protected the historic fabric of the District. There is at Westview no historic fabric to protect and thus this GB function is not served.

ii) There is no countryside abutting Westview that could be encroached upon. This GB function is not served.

iii) As no recreational countryside abuts Westview and none is under threat if the remainder were to be residentially developed, this GB function is not served.

iv) As a number of recent surveys have repetitively confirmed there are no protected species on site and there are no special habitats identified on site, this GB function is not served.

1.6 I now deal with para 4.2.2 where further general objectives are raised. Thus:-

v) It refers to diverting population away from rural areas to existing urban areas. This part of Hockley is not" rural" but medium to low density "urban", and has been confirmed as a sustainable location by appeal decisions and recent permissions for partial redevelopment. This GB function is not served.

vi) Whilst GB boundaries are sought to be maintained, this does not preclude their review along with any other local planning issue. The correction of errors and omissions cannot reasonably be staved off till a strategic review promised in 2021.

1.7 Moving to paragraph 4.2.4 Here the Council raise the concept of strategic buffers and concomitantly invoke a principal reason for Green Belts "- the prevention of coalescence -":

vii) Firstly, as this site is not identified as being within a 'strategic buffer', the GB designation of this part of Westview does not serve GB purposes.

viii) Secondly, the location of this part of the site precludes its release leading to any coalescence whatsoever. It is surrounded by contiguous urban development and again the site does not serve GB purposes.

1.8 Para 4.2.5 raises the issue of Previously Developed Land and its claimed contribution to defending GB land. The whole planning unit including this site has on previous Appeal been declared PDL ,has been accepted in the Council's oral evidence at Appeal as PDL, and has been confirmed as PDL by an Appeal Inspector.

ix) The release of the remainder of this site that happens to be GB will not be piecemeal as it is residentially allocated and half is already being redeveloped. In fact, because it is PDL , the Council's own text in this para means that its release will contribute to restricting "the need for GB land to be released in a piecemeal fashion".

x) The 1988 plan was heavily criticised by the 1995 Local Plan Inspector that GB boundaries were drawn too tightly causing a row to erupt in correspondence between the Regional Planning Office and RDC Members and Officers who did not like being accused by Inspector Platts of "being dazzled by the green belt" by not properly allowing for future housing land releases and that their excessively tightly drawn boundaries would instead ensure that such land was unacceptably only available on a "hand to mouth basis". This para. signals their intent to continue with this previously criticised approach.

xi) All urban garden land is PDL yet as we shall see in the next section the Council seek to establish an exempt sub category of the lesser large gardens being excluded from redevelopment, a source up to now they have been happy to see exploited. This site, as PDL, serves that worthy purpose they identify of minimising the need to release open countryside.

xii) There is no ministerial support for their stated objective here "to prioritise the use of previously developed site" that implies they will rank them for release and use that for reasons of refusal. There is no required or proven need for PDL release prioritisation.

1.9 Finally in para 4.2.7, the capacity to review the GB status of sites is admittedly allowed where it says, "The Council will also consider releasing land where it fails to fulfil GB objectives." The use of the word 'consider' reserves their position to release any land rather than this sentence being a positive assertion that they will. The use of this word means no guarantee is being given that the Council will identify any candidates whilst still appearing to be open minded.

1.10 It can be seen in the light of the preceding and the well established 5 purposes of the GB that this site does not serve any of those purposes, is according to the owner held there on a false premise, and therefore should be released from GB designation forthwith.

2.0 HOUSING NUMBERS & PHASING

2.1 Even allowing for the deductions from the total of 4,600 units set for RDC the 3,699 remaining is nevertheless a significant number as set out in their para 4.5.1.

2.2 In order to achieve their stated priority of protecting open countryside (which this site is not) they need to follow their own counsel and look to all that PDL source of sites that will continue to contribute a worthwhile number of dwellings as a valuable part of the new housing land supply.

2.3 I am concerned that the public is being asked to endorse Draft Preferred Options in advance of the Council setting out the estimated figures for windfall sites which will be an important determinant in the scale of future allocations.

2.4 The PDL sites of single dwellings being replaced with a number of new ones are now criticised as causing harm to their surroundings and yet it is acknowledged they contribute to reducing open GB land-take. As this form of redevelopment was and is encouraged by Central Government, is a rejection of National Guidance proposed here? Good design and good development control policies should ensure that this resource is brought forward and used efficiently, not proposed to be excluded as is hinted here.

2.5 The next para at 4.5.5 seeks to compound this reinterpretation for where are the bigger urban sites; surely such sites have all gone - certainly this is true in Hockley. This is a stealth policy to prevent any further urban PDL redevelopment in Hockley such as is happening beneficially at Westview. It seems if the GB policy " doesn't get" this owner, then the new 'small PDL exclusion' category will. This is negative planning and blatant status quo protectionism of Hockley to the exclusion of the rest of the District, as can be seen in a later para at 4.6.19 where Hockley is portrayed in a less favourable sustainability light than the other two main settlements.

2.6 With regard to para 4.5.8, the evidence that this site is a well located and sustainable one for release is the fact that - within the same planning unit - the southern half along with its neighbouring property is currently being redeveloped. Sustainability is not a reason to stop this site's release from the GB.

2.7 This para. places the GB part of Westview in the forefront for release as it is an 'inside of the edge of a settlement' location despite the erroneous zoning. One merely has to look at its surroundings of large detached urban dwellings to see that it is a prime candidate - regardless of the allegations I make about the Council's own version of its planning history promoted to bolster their case for preventing its past release.

2.8 None of the criteria listed at para4.6.2 are contravened by this site, whilst para. 4.6.3 places Hockley in the top tier of settlements for preferred locations for new development; this is reinforced at para 4.6.6. It is only at para. 4.6.19 where the Hockley protectionism drifts back in and it is set in a slightly less favourable light to the other two - creating a sub-hierarchy.

CONCLUSION

It is overwhelmingly evident that this site is PDL in a sustainable location in one of the three settlements favoured by the Council and in a settlement specifically earmarked for 400 new dwellings. This site if released will contribute 6 or 7 more to those already under construction. It is abundantly clear it fulfils none of the stated 5 purposes of the GB, nor any of the others raised by the Council in their consultation document and dealt with in this response.

This site and others like it should be identified as high priority for release on the grounds that they accord with the Council's stated objectives for finding such land for the additional housing it is required to provide.


DUDLEY BALL
JULY 2007

ROCHFORD DISTRICT COUNCIL
LOCAL DEVELOPMENT FRAMEWORK
CORE STRATEGY PREFERRED OPTIONS
REGULATION 26

REPRESENTATIONS ON BEHALF OF CROWSTONE PROPERTIES LTD.

In Part 1 of these representations, we set out our general response to the document as a contribution to the wider debate relating to the District as a whole.

We have already registered our Client Company's interest in securing the release of a site on the western side of Ashingdon for residential development through the Local Development Framework (LDF) process. In Part 2, therefore, we briefly comment on the relevance of the document and our Part 1 representations to the site.

PART 1 : GENERAL RESPONSE
We will be broadly endorsing the approach being followed by the Council in accommodating the District's required share of regional growth but with certain queries and caveats. We firstly, therefore, endorse the following :-

* The Spatial Vision (paras. 2.1- 2.29), which charts the evolution of the District over three 5 year periods and provides a positive long term perspective.

* The focus on existing larger settlements to absorb growth. (para. 4.6.6 and 4.6.14 - 4.6.23).

* The protection of the open landscape and free-standing settlements. (4.2.1 et seq.).

Our reservations are as follows:-

• The introduction of the concept of "strategic buffers between settlements" seems superfluous. Green Belt designation and
associated policies are and will remain effective in ruling out inappropriate development which might otherwise lead to the coalescence of settlements by the erosion of important buffers
or green wedges or by blurring the distinction between settlements
and the countryside. The introduction of a further local designation
will not add anything to the level of protection that already exists.

• There is currently uncertainty and some ambiguity as to whether the Council intends to review the Green Belt boundary in order to make provision for future housing requirements. The phrase "need to retain
the green belt boundary" in paragraph 4.2.2, for example, could be read as an intention to retain the existing boundary or a future reviewed and amended boundary. The position statement in paragraph 4.5.10, however, does suggest that some Green Belt land on the edge of settlements will be required, but again this is not explicit as it refers generally to impact on the Green Belt rather than to the need to utilise Green Belt land per se. We acknowledge, however, that paragraph 4.2.6 does seem to strongly hint that some Green Belt land will need to be released.

• Flood risk issues are not addressed. Flood defence and PPG25 considerations are currently being underplayed. (These feature strongly in neighbouring Maldon District's draft LDF which highlights the possible impact of rising sea levels on human and natural resources). Given the attention rightly devoted to "climate change" and "sustainable development", it is surprising that flood risk does not feature as a key issue - especially as this is a factor that must be taken into account in determining future locations for growth.

In summary, therefore,:-

• We seek the deletion of the text in the first bullet point in paragraph 4.2.7 on the basis that "strategic buffers" would be superfluous having regard to the strict nature and proven effectiveness of Green Belt designations;

• We seek greater clarity and commitment to a review of the Green Belt boundary in order to ensure growth can be absorbed in the most sustainable locations; and

• We identify the need for a clear statement on the likely influence of flood risk considerations on the future of built-up areas, homes, workplaces and habitats.

In Part 2 which follows, we briefly highlight the relevance of certain points in the document and our Part 1 representations to our Client Company's Land Bid site.

PART 2

LAND BID - LAND OFF RECTORY AVENUE, ASHINGDON

We attach as ANNEX EGA1 a Land Bid submission dated 22 February 2007. We now briefly comment on a few points of relevance arising from our representations in Part 1.

Firstly, Rochford/Ashingdon is identified as one of the main settlements which will absorb the majority of growth. After Rayleigh, Rochford/Ashingdon is expected to accommodate the second largest number of new dwellings in the District.

Secondly, although currently within the Green Belt and in the gap between Ashingdon and Hockley, the Land Bid site would, if released, provide a logical and alternative permanent Green Belt boundary. The Land Bid site can be partly used to extend the cloak of woodland and open space on the western edge of Ashingdon to provide an attractive and physical defensible Green Belt boundary.

Thirdly, the land is outside any flood risk area.

We therefore consider the Land Bid site remains in broad conformity at this stage with the emerging Core Strategy.

Chartered Town Planner
July 2007

The provision of transport infrastructure and services to support forecast development is an essential component of the District's spatial and strategic strategy and accordingly should be identified as a key Core Strategy issue.

Paragraph 4.5.8 of the document states that 'the development of the District is directly related to the availability of the necessary services and infrastructure and the processing of the required permissions. The development of the area needs to ensure that services and infrastructure can be phased to achieve development objectives in an environmentally and economically sustainable manner'.

Further, under the title 'General Development Locations', the document states at paragraph 4.6.23 that 'There is no doubt that improvements to existing transport and other infrastructure will be required to accommodated (sic) these levels of expansion (3,700 dwellings), and the specific location of new housing will need to be carefully considered'.

Notwithstanding these comments, the Preferred Options document fails to specifically address how, when or where required improvements to the district's transport infrastructure and services will be achieved.

The exclusion of this key issue results in the Preferred Options document failing to address how the Council propose to address cross boundary accessibility issues, including proposed new road links, which are essential to the implementation of regional regeneration objects. More specifically, whilst the Southend Core Strategy Submission Document identifies a 'proposed new road link' that will traverse land toward the south eastern part of the district to facilitate regeneration objectives in the Shoeburyness area, the Preferred Options document makes no reference as to how the Council seek to either address the proposed road or any implications for the Green Belt boundary. This is an issue which was raised at the Issue and Options stage but has not been addressed.

On this basis, it is requested that 'Transport Infrastructure and Services' is identified as a key Core Strategy issue and a comprehensive policy outlining how improvements required to facilitate the scale of development envisaged in the District during the period up to 2021 will be achieved in a sustainable manner is prepared.

I am very disappointed not to have attended the meeting regarding the above proposals which was held at Hawkwell Village Hall on 31 May. I only found out that a meeting had been held when I visited Rayleigh High Street recently and spotted a caravan giving information out to Rayleigh residents.

Mr Firth advised me that his office advertised the meeting by placing an advertisement in the Evening Echo, putting up notices in local shops and setting up a website. This was clearly not enough. A local Councillor has told me that she has received numerous complaints from Hawkwell residents who would have liked the opportunity to express their views on this important matter but were unaware that the meeting had taken place. I don't know many readers of the Echo and most people still do not have access to the Internet. My husband and daughter visit our local Co-op daily to pick up their newspapers but neither saw a notice in the window. I understand the meeting was poorly attended, hardly surprising in the circumstances.

Kindly confirm that you have placed my name on your mailing list so that I can attend the further meetings planned for this autumn. I trust that you will also make vigorous arrangements to advertise these meetings so that the residents of Hawkwell village are aware when they are taking place.

Thank you for inviting us to comment on your Preferred Options Report. We have scrutinised the document with a view to assessing its robustness as a basis for moving towards the submission stage, bearing in mind the tests of 'soundness' set out in paragraph 4.24 of Planning Policy Statement 12 (PPS12): Local Development Frameworks.

There is further information on assessing soundness on the Planning Inspectorate's website: http://www.planning-inspectorate.gov.uk/pins/appeals/local_dev/index.htm. As experience of the new system grows there is also an expanding body of advice and good practice available, notably the Inspectorate's 'Lessons Learnt' document (June 2007 - available via the same web link) and the Core Strategy guidance produced by the Planning Advisory Service: http://www.pas.gov.uk/pas/aio/31034.

Although this material does not constitute government policy or guidance it will be helpful in considering the adequacy of the work undertaken to date and the further work required prior to submission. Indeed the Inspectorate recommends that authorities undertake a self-assessment of the soundness of their draft DPDs as they prepare their submission versions, and to make this available when they formally submit these documents.

While we welcome the steps that your Council has made in progressing the Core Strategy to the preferred options stage, our assessment suggests that significant further work is required prior to producing a submission document, if the Council is to minimise the risk of the Core Strategy being judged unsound following the examination.

For this reason our letter focuses on general issues that need to be addressed rather than detailed observations on the various options that have been set out. Nonetheless we would like these comments to be considered as formal representations, and have related them where possible to the tests of soundness set out in PPS12.

Sustainability Appraisal and Appropriate Assessment (soundness test iii)

We are aware that some sustainability appraisal work has been undertaken already in support of the previous round of consultation. It is surprising that no further information appears to be available at this stage, and that the results of the sustainability appraisal are not used to support and justify the choice of preferred options. It would have been helpful for the Preferred Options Report to include a summary of the sustainability effects of each the different options, drawing upon the appraisal process. This is a potentially serious omission. At examination the authority will need to demonstrate a clear trail of options generation, appraisal, selection or rejection and the role that SA has played in this process. In our view the present consultation exercise fails to provide this trail of evidence.

You are also reminded that Local Planning Authorities are now obliged to consider whether 'Appropriate Assessment' is required during plan production, to assess the potential impacts on sites of European importance for nature conservation. Ideally the need for AA should be gauged during the Sustainability Appraisal scoping stage, with the assessment itself (if required) undertaken alongside the development and testing of options. There appears to be no evidence from the consultation material that these steps have been taken, and we would urge you to address this before moving to submission stage. Draft guidance is available on the CLG website: http://www.communities.gov.uk/index.asp?id=1502244

A spatial plan consistent with national policy and other strategies (test iv)
The Core Strategy should be a strategic document which sets out a vision and framework for guiding the future development of the area, taking into account other plans and strategies and the spatial requirements of different service areas. As Maydo Pitt explained in her letter of 16 November last year, we would expect the process of developing preferred options to consider and present alternative scenarios for the future of the district, covering matters such as the broad distribution of development, particular directions of growth and the approach to managing key issues such as the rural environment, local economy and town centres.

While the Preferred Options Report contains a reasonable basis for an overall spatial vision, it fails to translate this into a clear set of objectives and a spatial strategy to guide the future of the district. This is evident in a number of ways:
* There is insufficient detail about the approach to be taken to the location of key uses and the future of important areas (e.g. employment, town centres);
* Many of the 'preferred options' are procedural in nature (policies will be prepared on... etc.) rather than indicating the substance of the approach to be taken;
* There is little indication of the way in which the implications of other plans and strategies (listed in the box on page 2) are to be addressed;
* Some of the policy areas suggest matters that are more appropriately dealt with through the proposed Development Control Policies DPD, although it is difficult to be specific given the lack of detail in the preferred options that are set out.

In our view significant further work needs to be undertaken in order to provide the basis for a spatial plan, and to allow stakeholders to have a say on the broad spatial choices facing the district. Given Rochford's coastal location we find it particularly surprising that there is no indication of how the strategy and policy approaches are intended to address climate change and flood risk.

We are also concerned that some of the preferred options are inconsistent with national policy, and that the report fails to provide adequate justification for these departures. In particular:
* The proposals for local landscape designations (strategic buffers, special landscape areas, area of historic landscape), which require particular justification in the context of PPS7;
* The proposed approach to the environmental performance of buildings (page 35) which fails to accord with emerging policy in Planning and Climate Change (draft supplement to PPS1).

At the same time you are reminded that policies in the Core Strategy (and elsewhere in the LDF) should not repeat statements of national policy or policies contained in the RSS. There are suggestions in some of the preferred policy approaches that such repetition could occur, although it is difficult to be specific due to the lack of detail in the document.

Regard paid to the community strategy (test v)

Although the document identifies some general influences stemming from the Community Strategy (page 9) it could do more to explain how these are carried through into the spatial strategy and preferred policy approaches.

Whether the proposals are the most appropriate in the circumstances (test viii)

In our view the Preferred Options Report does not do enough to explain and justify the proposals that it contains, posing a significant risk that a submission document flowing from it could be found unsound unless further work is done:
* It is unclear how the spatial vision (pages 4-7) links to the identified issues (page 11), or how those issues derive from the spatial portrait (pages 1-3) and evidence base. It is not sufficient simply to state that "The Council considers that the following are the key Core Strategy issues" (page 11). The spatial portrait itself appears rather superficial, fails to cross-refer to the supporting evidence base and contains some irrelevant material (e.g. the Council's corporate performance ratings);
* There is insufficient information about the way in which many of the policies will be framed (e.g. what does "some relaxation" of green belt policies for major sites, green tourism and renewable energy schemes - page 13 - actually mean?);
* Where specific details are presented, there is frequently a lack of evidence and explanation underpinning the approaches being adopted. For example: the intended distribution of housing development across the settlement hierarchy (and specific urban extensions named in para. 4.6.8); the suggested approach to accommodating gypsy and traveller needs (wholly as part of mainstream housing allocations?); the proposed requirement for 25% of housing units to meet lifetime homes standards; and the suggested target and threshold for affordable housing contributions.
* As a related point, there is often insufficient consideration or explanation of alternative options (such as those for the settlement hierarchy), and a failure to justify why alternatives have been rejected: the standard wording which appears throughout ("These alternatives have been discounted because they fail to meet sustainable development objectives, the Corporate vision and Principle Aims") is inadequate. At the same time alternative options should not be invented where no reasonable alternatives can be shown to exist; in many cases the alternatives that are presented in the Preferred Options Report are not realistic (e.g. those relating to landscape protection on page 20, or relying on windfalls/urban intensification to meet housing needs - page 22) .

Hence we consider that much more effort needs to go into identifying, justifying and assessing options. It also needs to be clear to consultees at the preferred options stage that they can still express a preference for those options that the authority proposes to reject; it is not evident to us that the present consultation satisfies this requirement.



Clear mechanisms for implementation and monitoring (test viii)

In our comments at your issues & options stage (Maydo Pitt's letter of 16 November) we noted that the implementation and monitoring framework would need to be developed further as work on the Core Strategy progressed. It is disappointing to see that no progress has been made in this respect.

The Core Strategy will need to go much further than it currently does in setting out the responsibilities, timescales and risks involved in delivering the vision, objectives and policy approaches, including key infrastructure requirements, inter-dependencies and contingency measures.

Other matters

There are a number of errors in the document. The Foreword implies that this is an issues & options consultation, not the preferred options. Supplementary Planning Documents (page 10) are not DPDs. References to the draft East of England Plan are out of date following publication of the Proposed Changes in December last year. Similarly the references to national renewable energy targets (para. 4.12.5) will need updating in the light of the recent Energy White Paper.

The key diagram remains insufficiently clear. This should be a key tool in communicating the spatial strategy, but fails to set out clearly the main settlements, key infrastructure networks, directions of growth and strategic links with neighbouring areas.

Conclusion

It is very apparent that the Preferred Options Report is no more than a minor re-working of the Regulation 25 version, with preferred options now set out in place of the 'possible' and 'probable' options presented previously. Most of the remaining text remains unchanged. As our representations in this letter make clear this is an inadequate basis for moving forward to the submission stage. We find it particularly disappointing that many of the observations contained in our letter of 16 November have not been addressed.

We are conscious of the resource constraints facing the authority but consider that significant further work on options development, testing and consultation is necessary. This will inevitably require a further round of consultation on the preferred options in due course.




Please contact me should you wish to discuss anything contained in this letter, or work in relation to your LDF more generally. We would welcome early sight of any further material that you produce in due course so that informal feedback can be provided.

What is the point of having the expense of County Councils and Town Councils etc if Government Policy is going to be forced upon us anyway? What about infrastructure and the extra pressure on this that these extra houses will cause, especially on roads, sewers, health care, schools etc. Loss of Green Belt is unacceptable. There should instead be tax incentives (as this is driven by central government, tax incentives should come from central government also) to encourage the full use of all brown sites as a top priority before any other land is used.

All new houses should have high standards of insulation and energy saving devices now before planning permission is granted.

Any new land used must be more fairly spread over the whole of the Rochford District - Rayleigh is already to densely populated!

What is the definition of affordable housing? (Affordable to whom? Prices and specification of these houses must be clearly defined).

In general, the pubilc needs more detail to comment properly on this very important matter. Questionnair should have been more widely distributed - supermarkets, Echo and free local papers, all newsagents etc etc.