4.1 Introduction

Thank you for the consultation on the above document. At this stage we have outlined some general principles and key issues that we feel should be included and addressed in the Core Strategy.

I hope this information is of use to you. If you have any further queries, please do not hesitate to contact me.

We are surprised that this does not include reference to Climate Change and Peak Oil,which are major issues effecting the District. Policies will be needed in relation to the impact of Climate Change, minimising greenhouse gas emissions and adapting to the low carbon economy

We are surprised that transport has not been identified as a Key Core Strategy issue. The Rochford District contains an Airport as well as rail and road links. It would have been useful for the Core Strategy to say something about these. Improvements to roads are mentioned but there is no mention of public transport or how it might be improved.

Section Four. Core Strategy Values


Para 4.1 The Council's list of key core strategy issues includes policy areas which we consider to be inappropriate in a core strategy. The key issues listed that are considered to be inappropriate are:

• Protection and Enforcement of the Upper Roach Valley
• Protection of special landscapes, habitats and species
• Landscaping
• Compulsory Purchase and Planning Obligations
• Good Design and Design Statements
• Character of Place and the Historic Environment

PPS 12 suggests that a core strategy should focus on a spatial vision for the area, it should set out broad locations for delivering the housing and other strategic development needs such as employment, retail, leisure, community, essential public services and transport development. It is accepted that the central policy requirements may not fit in every authority; however, the CSPOD appears to concentrate too much on landscape character and design, which dilutes the focus on the spatial strategy. The areas which should be omitted could be dealt with as separate of combined development plan documents.

The RSPB would like to see two additional issues added to the list of policy issues. These are flood risk management and sustainable transport provision. Both are issues affecting Rochford District and we would expect to see policies to address these at a local level.

Much of Rochford District is at risk of coastal flooding and climatic projections suggest this risk is likely to increase. The RSPB would like to see a pro-active approach to managing flood risk taken by the Council. We would recommend the Council investigate opportunties for coastal realignment and the creation of new intertidal habitats; these act to absorb the power of waves and reduce flood risk, as well as providing Biodiversity Action Plan priority habitats.

While not seeking duplication, there should be an area of policy for the Airport, which refers to the Joint Area Action Plan. The Council has agreed to the JAAP and it is therefore logical that its parameters and objectives are included in the Core Strategy so that the more specific policies can be contained in the JAAP as a separate Local Development Document. These parameters and objectives are:
• To accommodate the increase in jobs
• To support the Airport's role in seeking to accommodate further passenger growth as set out in the Airports White Paper.
• To achieve infrastructure changes to improve airport safety and performance and to achieve better multi-modal surface transport access.
• To achieve environmental enhancement and related measures, including adjustments to the Green Belt boundary to make it more logical and defendable.

The key diagram should show an asterisk located in the area west of Rochford to indicate that the Joint Area Action Plan is to consider this area.

Core Strategy Preferred Options (Regulation 26) Consultation Response

In response to the council's invitation for consultation comment on the Regulation 26 draft of the Core Strategy Preferred Options, I attach my views on some of the issues raised within the consultation document. I have also delivered a hard copy of this response to the council's offices this afternoon.

My comments are not a comprehensive critique of the consultation document and are limited to those issues that I either have an understanding of, or which I feel are most closely related to issues that are important to me at this point in time. Broadly speaking, there are no items to which I object and I consider that the Regulation 26 draft is comprehensive and well rounded. My comments are merely to either suggest some additional considerations on a few points or to fully support the council's preferred options on others.

With Andrew Meddle's departure, I would like to take this opportunity to introduce myself to you and clarify the reason for my participation in the LDF consultation process. We met at the first of the Core Strategy 'Roadshow' exhibitions at Hockley Parish Hall. I am one of two owners of a site to the south of Sutton Court Drive and to the east of Southend Road/Warner's Bridge Chase, and I have been promoting the site for release from the green belt for residential development on the grounds of sustainability. I have taken the liberty of attaching (with my consultation response) a copy of the submission that I made to the council in February this year in response to the Allocations Development Plan Document questionnaire. I also attach a copy of the site plan that I submitted at that time.

I would be obliged if you would acknowledge receipt of this consultation response in due course.

I trust that my enclosed consultation response is of use to the council and if I may be of any further assistance in the future, please do not hesitate to contact me.

Core Strategy Preferred Options

Thank you for your email of 21 May consulting The Theatres Trust on the Preferred Options for the Core Strategy.

The Theatres Trust is the national advisory public body for theatres and a statutory consultee on planning applications affecting land on which there is a theatre. This applies to all theatre buildings, old and new, in current use, in other uses, or disused. Established by The Theatres Trust Act 1976 'to promote the better protection of theatres', our main objective is to safeguard theatre use, or the potential for such use but we also provide expert advice on design, conservation, property and planning matters to theatre operators, local authorities and official bodies.

Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and therefore anticipate policies relating to cultural facilities.

We are disappointed that the Preferred Options document does not have any actual policies for our consideration although we note at 4.1 that policies will be developed for the issues that have been identified. Presumably policies will be available for scrutiny in the Submission document but at this late stage of the Core Strategy consultation consultees will be unable to effect any changes to the text thereafter.

However, we support your Core Strategy Issues and will comment on two.

4.13.7 Planning Obligations

To ensure that development in Rochford enhances the local environment, provides adequate community facilities and promotes urban regeneration the Council should seek to enter into legal agreements with private developers under Section 106 of the Town & Country Planning Act 1990. It is important that the need for developer contributions for the infrastructure of cultural activities is identified in the Core Strategy and you may want to broaden this out in the form of a supplementary planning document. The document should develop detailed policies setting out what achievements are expected from section 106 agreements including cultural provision. Investing time and resources in such a document will set down clearly what is required of the developer and other funding partners.

4.14.8 Community, Leisure and Tourism Facilities

As drivers for economic development, cultural activities such as the performance arts and tourism are fast growing sectors, and cultural facilities are a fundamental and dynamic part of this cultural asset base. This issue should also deal with new leisure and cultural facilities and it is important that local authorities carry out thorough and rigorous assessments of the need for open space, recreation, theatre and cultural facilities in line with PPG17 to reflect local distinctiveness. Opportunities for the provision of combined cultural activity spaces should be explored.

The section on 'An Inclusive Community' in your Community Strategy states on page 26 that 'To promote active and responsible citizenship, creating a community inclusive of all groups, and enabling everyone to fully participate in activities that improve their quality of life'.

'Celebrating Essex - a shared vision' does not appear in your list of local strategies and initiatives but on page 21 it encourages local authorities in the Essex county consortium to follow these aspirations and opportunities.

Our aspirations are to ensure that:

* Cultural facilities and opportunities are maintained and developed

* The natural and historic environment of the county is respected, protected and promoted

* The importance of culture is recognised and used to full effect in addressing social, health, economic and education issues.

Our opportunities are:

* To assist the voluntary sector and ensure that all voluntary organizations and individuals have access to information and funding

* To plan for future investment in the cultural infrastructure of the county

* To develop partnerships between the cultural sector and other providers to address health, social and environmental issues

* To coordinate and collate information and research on cultural provision and the benefits of culture across the county.

We recommend therefore that there should be specific policies in your Core Strategy to promote and protect your existing community, cultural and leisure facilities, and that public open space, recreation, sports, children's play, leisure, cultural, school and adult education, youth, health, public service and community facilities should be provided to meet the needs generated by any new development. An appropriate policy should also state that the loss of an existing facility should be resisted unless it can be demonstrated that the facility is no longer required or is to be rebuilt elsewhere.

We look forward to being consulted on the Submission Core Strategy and any Area Action Plans for your town centres.

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.