4.2 The Green Belt & Strategic Gaps Between Settlements

The exact nature of "major developments" are not specified, and the option does not mention housing developments will not be included.

These are essential to allow individual communities to maintain their identity and now just merge into the nearest large neighbour
I would like to see a buffer between Rawreth and
and Wickford as well

These are necessary otherwise everything
will become one large built up area.
I would like to see one between Rawreth
and Wickford as well

Section Four. The Green Belt and Strategic Buffers between Settlements.


The CSPOD does not contain any clear justification, which demonstrates a need for Strategic Buffers in the Green Belt, however, that evidence may emerge before the Regulation 27 submission stage and therefore we reserve our position with respect to this matter.

The Council at paragraph 4.5.10 of the CSPOD accepts that if the growth is to be achieved, then there will need to be a compromise between urban intensification and Green Belt releases. The compromise is stated as edge of settlement allocations. Rochford district is entirely washed over by a Green Belt designation and as such an edge of settlement release, will mean a Green Belt release. The broad allocations identified in the CSPOD for Rayleigh (1800 units) and Hockley/Hawkwell (400 units) involve settlements, where it is proposed that Strategic Buffers are required to protect against settlement coalescence. At the present time, the urban capacity of these settlements is unknown and therefore, the CSPOD should recognise that there is a potential conflict between the rational for Strategic Buffers and the likely need to find land on the edge of these settlements to accommodate growth targeted in Rayleigh and or Hockley/Hawkwell. The CSPOD can avoid this conflict by allocating a greater proportion of the required growth to land east of Rochford/Ashingdon where the Council recognise that the need for a Strategic Buffer is unnecessary and where a number of opportunities exist to accommodate growth on sustainable sites, which will have a minimal impact on the Green Belt in the Rochford district.

The RSPB supports the protection of green belt from unsuitable development. Buffers and green corridors can help support wildlife by providing habitat corridors and facilitating movement between sites. We do however wish to point out that brownfield sites can support surprisingly high levels of biodiversity and as such should be comprehensively assessed.

A specific reference to the need to review the Green Belt boundary in the area of the Airport should be included. The review should take place within the Joint Area Action Plan and should seek to make the boundary more logical and defendable.

The Council's Preferred Option is ambiguous and is not based on robust or credible evidence. As per the Issues and Options Paper, the Preferred Options documents states that 'the Council proposes to continue its restrictive suite of policies for development within the Green Belt, in line with national guidance' an approach which contradicts text elsewhere within the document. More specifically, paragraph 4.2.5 advises that whilst 'the Council still believes that the reuse of previously developed land has an important role to play in fulfilling housing and employment targets. The scope for the use of such land appears to be diminishing as many of the major sites have been used'. Paragraph 4.2.6 goes on to advise that 'the Council will also consider releasing land where it fails to fulfil Green Belt objectives'.

Notwithstanding these comments, the Council's Preferred Option fails to provide flexibility to allow the Core Strategy to respond to changes in circumstances during the plan period, such as the limited availability of previously developed land, to allow the release of land within the Green Belt if its development is required to satisfy the strategic requirements.

In addition, under the heading 'Housing Numbers and Phasing', paragraph 4.5.3 of the Preferred Options document, states that the Council is 'reviewing its Urban Capacity Study, which was prepared in 2001'. Therefore, it is evident that at this stage the Council's Preferred Option is not informed by robust or credible evidence to demonstrate whether sufficient land is available within the District's principal urban areas, or whether it will be necessary to release land from the Green Belt, to satisfy strategic requirements.

Given that it understood that the Council's Urban Capacity Study - the findings of which could have significant implications for the Council's Preferred Options - is to be finalised within the next few weeks, publication of the Preferred Options document is both premature and prejudicial. The premature publication of the document denies the public with an opportunity to comment on Preferred Options that are based on credible evidence before the Core Strategy is submitted to the Secretary of State.

The proposed identification of Strategic Buffers to provide enhanced protection to certain sites in addition to the allocation of land as Green Belt serves no planning purpose and is therefore considered unnecessary. More specifically, the objective of Strategic Buffers is to maintain the strategic settlement pattern of the area and prevent the coalescence of settlements - an objective that is replicated by two of the 'Purposes of including land in Green Belt', which are identified at Paragraph 1.5 of the PPG2: Green Belt (1995):

• to check the unrestricted sprawl of large built-up areas;
• to prevent neighbouring towns from merging into one another.

Accordingly, there is no requirement to introduce another tier of protection to land already identified as Green Belt, given that the areas proposed to be identified as Strategic Buffers are subject to a continued application of Green Belt policy and are no more at risk from development than other sites within the Green Belt. The net result of the proposal would be to undermine the level of protection afforded to land by the Green Belt designation.

The Council's Preferred Option also fails to justify why the various Strategic Buffers identified require enhanced protection.

The issue of Strategic Buffers was a matter raised at the Issues and Options Stage, however, given that the Council has failed to provide any sufficient justification for their proposed imposition, the representation is repeated at this stage

As far as I can tell, the Strategy document makes no mention of agricultural land, which probably still represents the largest acreage of any land use in the District, and still forms a major element in its landscape character, even though employment is negligible.
I would like to see a presumption against any loss of high-grade agricultural land. Retention of agricultural land may not be considered nationally important at present, but will certainly become so again.

Rochford District Council Core Strategy Consultation Response

From A.J. Handfield



1 The Green Belt and Strategic Buffers Between Settlements.

I am concerned about the constant erosion of buffer zones. It's all very well to keep saying that we need the land for this or that but the effect is that the land is being lost for it's existing purposes, and probably lost for a very long time.

The purpose of green space is not always the obvious one e.g. agricultural use is obvious but there are other benefits which are less obvious such as for the well-being of wildlife (not just protected species but all insects, birds and mammals) and visual amenity.

2 General Development Locations.

In my view it is highly unlikely that the proposed development can be accommodated without significant infrastructure problems.

New development is usually permitted, where appropriate, with certain mitigation measures to offset expected new pressures on schools, roads, recreation and/or health facilities. These are usually very focussed. Unfortunately there are very many issues which do not get addressed because of the smaller increments of development. Smaller increments of development result from either (i) smaller development sites or (ii) relative remoteness from a larger development site. The list of infrastructure which suffers from smaller incremental development would include roads, hospitals, shopping centres, public town centre car parks, schools, water supply and waste, energy supply, air quality, solid waste etc. Any of these may benefit from developer contributions where the proposed impact is predicted to be significant but where the development is more remote, contributions are not forthcoming and the stress on the infrastructure increases in numerous small increments.

Roads - New developments used to be required to satisfy the IHT guidelines with regard to traffic generation i.e. any development which had less than a 10% impact on a traffic flow on a junction or road link (5% if congested) would not be required to fund remedial measures. This has been superseded by the latest government recommendations. The Traffic Management Act 2004 requires the Local Traffic Authority to manage traffic and seek to reduce congestion. The DfT "Guidance on Transport Assessment" also supersedes the old IHT guidelines.
It is impossible to mitigate against the traffic impacts on roads further away from a new development site because the impact has reduced to smaller, less quantifiable levels. The road network in the Rochford and Southend areas is however already very congested at peak times and new settlements of the numbers indicated in this draft document will impact quite severely on remote roads and junctions. Nearly everyone who lives in the area is aware of the severe congestion that frequently and regularly occurs at places such as Rayleigh town centre and to a lesser extent Hockley town centre where all the approaches are almost constantly congested at peak times, Eastwood Road which queues heavily at peak times, Progress Road junction with the A127 and Rayleigh Weir whilst not in Rochford district are still used by a lot of the rush hour traffic from Rochford district. The traffic generation from the proposed new settlements will add to this and is therefore unsustainable and undesirable.

Hospitals, dentists, clinics and g.p. surgeries - These suffer in exactly the same way that the road network further away from a development sites suffer from the incremental effects of more remote new developments as explained above. New pressures will be placed on the health service that will not be matched by the necessary increases in capital investment.
Developers are frequently required to provide a new health facility where it is needed to accompany a new housing site but this does not offset the additional stress that is being created for other functions, for example a new g.p. surgery does not address the additional stress being created on hospitals and dentists etc.

Air Quality - The Government has identified air quality improvement as a target in it's "A New Deal For Transport" and other policy documentation. Air quality will undoubtedly suffer as a result of the additional traffic generation and congestion that the new developments will create.

Energy supply and solid waste disposal - New housing development will have an impact on both of these issues since increasing the numbers of households will result in increased energy consumption and waste.
Constructing new houses will involve additional energy consumption and pollution in connection with the original creation of the houses and the materials used therein. If the houses are to be built, the CO2 produced should be offset.

The locations and distribution of proposed development numbers - I object to the enlargement of Rayleigh and Hockley for the reason that the infrastructure cannot cope. I have already described my main reasons for objecting above. There will be other increased pressures resulting from the new settlements such as on existing town centre car parks which I find unacceptable.

If additional housing has to be accepted in the district, it seems more sensible to me to enlarge Hullbridge creating a new town rather than the distribution described in the draft Core Strategy. New highway links could be created or existing ones could be upgraded much more easily, public transport could easily be improved (not rail, of course) and cycling infrastructure could be provided. Hullbridge has the potential to become a very desirable location in view of it's riverside rural setting, with a full range of housing provision.

Affordable Housing - I am pleased to see the intention to provide for gypsy and traveller needs through mainstream housing, and support that strategy.

Accommodation Type - No mention is made in the draft Core Strategy of the types of accommodation that are to be provided. It is essential for the general living quality of a community to ensure that the full mix of accommodation is provided. I would object to any proposal to build many small flats or one bedroom houses.
A method for arriving at an accommodation mix should be specified in the Core Strategy.

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)

Representations on the Consultative Draft LDF Core Strategy

I refer to the recent and past discussions between myself and Sam Hollingsworth, Nick Barnes and Andrew Meddle of your Department. I confirm that Sam Hollingsworth and I have today agreed that we may submit our formal Representations on the emerging LDF Core Strategy document by way of this emailed note, given that your interactive weblink service for depositing comments seems to be "frozen".

As you may recall, we act for Mr and Mrs David Poole, owners of the Lime House nursery site in Rayleigh, which was the subject of Representations made to the Replacement Local Plan in 2005 - and subsequently considered by the presiding Inspector as Objection Site, RDC ref 153.

Lime House is currently wholly contained within the designated Green Belt. The landholding comprises the remnants of former large-scale horticultural operations, an industrial park with a range of commercial tenants, a Wyevale garden centre outlet and a few houses.

The location of our clients' site wholly within the current designated Green Belt and as part of the "strategic gap" between Rayleigh (western boundary) and Rochford (on the eastern boundary) has implications on the Poole Family's future objectives to bring forward some of the landholding for new housing development, subject to the commitment in perpetuity that the remaining area should be maintained permanently as some form of public park.

We maintain that part of the Poole's landholding would be an excellent location for the development of a limited number of new houses, subject, of course, to the effective "rolling back" of the Green Belt designation from part of the subject site.

We attach, for completeness, a copy of our 2005 Representations, together with illustrative images - and when you come to assess and evaluate the comments raised here, we would refer you to the Representations made at that time. (Please refer to RDC's archive copy of the same).

We appreciate that your Council's approach to the national policy requirement of long term protection of Green Belt boundaries as a key principle of the emerging LDF, is a sound and laudable one.

We maintain however that there may well be opportunities in the Green Belt for some form of development, if well planned - and our illustrative proposals for Lime House reviewed and evaluated the context, character and appearance of the Lime House site as it appears today - comprising a privately owned site with no public access, a retail garden centre and a varied mix of industrial tenants.

If the Lime House site were developed in accordance with the master plan proposals illustrated by my clients, then we would refute the assertion of your Council that any "further reduction" in the width of the GB in this location would consequently be detrimental to the rationale of supporting the Green Belt per se. This view is misguided and fails to take proper account of site specific circumstances.

The Local Plan Inspector's report concluded, in respect of Lime House (site IV of those covered by the "Statement of Sites Subject of a Site Visit") that "...were further land needed for development this site has factors in its favour..."

We acknowledge that precise boundaries will be determined during the Allocations Development Document (DPD) process, but the sweeping negative statement the the Council "...proposes to continue its restrictive suite of policies for development in the Green Belt..." is not qualified, in our view, with a statement explaining that the GB boundaries will be reviewed in detail, in due course.

To that end, we object to the Core Strategy text above, on the basis that the text needs to be expanded to ensure that the prospect of a review of the boundaries is acknowledged and understood.

While the East of England Regional Assembly has confirmed, we understand, that a strategic review of the GB boundary will not be required until after 2021, we would argue that a review ought to take place within the lifetime of the emerging LDF. To that end, we object to the Core Strategy insofar as this is excluded.

We support the Core Strategy statement at 4.2.6 that the Council will consider releasing land where it fails to fulfill Green Belt objectives.

Finally, we also section 4.6 that explains the intended split between settlements and the hierarchy-based approach to allocating land for housing.

We trust these formal representations are clear and helpful - and we would welcome a discussion with your department.

Please provide us with an acknowledgement of receipt of these comments in due course - and keep us informed in general terms about the LDF process and consultation procedures.

Representations on the Consultative Draft LDF Core Strategy

I refer to the recent and past discussions between myself and Sam Hollingsworth, Nick Barnes and Andrew Meddle of your Department. I confirm that Sam Hollingsworth and I have today agreed that we may submit our formal Representations on the emerging LDF Core Strategy document by way of this emailed note, given that your interactive weblink service for depositing comments seems to be "frozen".

As you may recall, we act for Mr and Mrs David Poole, owners of the Lime House nursery site in Rayleigh, which was the subject of Representations made to the Replacement Local Plan in 2005 - and subsequently considered by the presiding Inspector as Objection Site, RDC ref 153.

Lime House is currently wholly contained within the designated Green Belt. The landholding comprises the remnants of former large-scale horticultural operations, an industrial park with a range of commercial tenants, a Wyevale garden centre outlet and a few houses.

The location of our clients' site wholly within the current designated Green Belt and as part of the "strategic gap" between Rayleigh (western boundary) and Rochford (on the eastern boundary) has implications on the Poole Family's future objectives to bring forward some of the landholding for new housing development, subject to the commitment in perpetuity that the remaining area should be maintained permanently as some form of public park.

We maintain that part of the Poole's landholding would be an excellent location for the development of a limited number of new houses, subject, of course, to the effective "rolling back" of the Green Belt designation from part of the subject site.

We attach, for completeness, a copy of our 2005 Representations, together with illustrative images - and when you come to assess and evaluate the comments raised here, we would refer you to the Representations made at that time. (Please refer to RDC's archive copy of the same).

We appreciate that your Council's approach to the national policy requirement of long term protection of Green Belt boundaries as a key principle of the emerging LDF, is a sound and laudable one.

We maintain however that there may well be opportunities in the Green Belt for some form of development, if well planned - and our illustrative proposals for Lime House reviewed and evaluated the context, character and appearance of the Lime House site as it appears today - comprising a privately owned site with no public access, a retail garden centre and a varied mix of industrial tenants.

If the Lime House site were developed in accordance with the master plan proposals illustrated by my clients, then we would refute the assertion of your Council that any "further reduction" in the width of the GB in this location would consequently be detrimental to the rationale of supporting the Green Belt per se. This view is misguided and fails to take proper account of site specific circumstances.

The Local Plan Inspector's report concluded, in respect of Lime House (site IV of those covered by the "Statement of Sites Subject of a Site Visit") that "...were further land needed for development this site has factors in its favour..."

We acknowledge that precise boundaries will be determined during the Allocations Development Document (DPD) process, but the sweeping negative statement the the Council "...proposes to continue its restrictive suite of policies for development in the Green Belt..." is not qualified, in our view, with a statement explaining that the GB boundaries will be reviewed in detail, in due course.

To that end, we object to the Core Strategy text above, on the basis that the text needs to be expanded to ensure that the prospect of a review of the boundaries is acknowledged and understood.

While the East of England Regional Assembly has confirmed, we understand, that a strategic review of the GB boundary will not be required until after 2021, we would argue that a review ought to take place within the lifetime of the emerging LDF. To that end, we object to the Core Strategy insofar as this is excluded.

We support the Core Strategy statement at 4.2.6 that the Council will consider releasing land where it fails to fulfill Green Belt objectives.

Finally, we also section 4.6 that explains the intended split between settlements and the hierarchy-based approach to allocating land for housing.

We trust these formal representations are clear and helpful - and we would welcome a discussion with your department.

Please provide us with an acknowledgement of receipt of these comments in due course - and keep us informed in general terms about the LDF process and consultation procedures.

The building of 1,800 additional homes in Rayleigh is utterly unacceptable. It would put intolerable pressure on our local roads, schools and G.P. services. It would also mean a devastating loss of Green Belt land. Future residential development should be spread more evenly over the whole of the Rochford District, so that a smaller, fairer burden falls on Rayleigh.

Green Belt should stay just that!

We write in response to the Rochford District Core Strategy Regulation Draft (preferred options).

Our interest in the Core Strategy is in regard to housing numbers, phasing and general development locations. We represent a consortium of landowners in Hawkwell known as the Old Nurseries Consortium, who jointly own a site in Hawkwell known as land off Thorpe Road.

In general, we feel that the Councils approach and the content of the draft Core Strategy can be supported. There are a number of points that have been raised in the draft that we consider are essential for future housing allocations in the District and should be carried forward into the approved Core Strategy. The points are discussed in more detail below, with reference to the site that we represent.

Green Belt

Green Belt land should be protected, and where possible brownfield land should be given priority for development. However, the draft Core Strategy conveys that the scope for using previously developed land in the District appears to be diminishing as many of the major brown field sites have already been used (paragraph 4.2.5).

It is obvious that to meet the housing requirements set out by the East of England Plan, which is the provision of at least 4600 new homes by 2021, that some Green Belt land will need to be allocated for housing development in the allocations DPD.

Therefore, in our view sites on the edge of settlements that do not harm the purpose of the Green Belt should be the only ones that are considered for housing development in the Green Belt.

We maintain that only suitable Green Belt land should be allocated as part of the allocations document. As a starting point, the strategic buffers identified in the draft which help to maintain the function of the Green Belt and prevent coalescence are considered essential and should not be compromised by the future allocation sites.

A point to mention with regard to the land off Thorpe Road is that the Council own a strip of land at the southern edge of one of the strategic buffers between Hawkwell and Ashingdon, known as Clemence Hall Open Space and be safeguarded from development and prevent coalescence.

Housing Number and Phasing

Paragraph 4.5.8 of the draft Core Strategy states that new development in the District should be directly related to sites with the availability of services and infrastructure. Development will need to be phased to ensure that the extensions of settlements and the provision of services go hand in hand.

General Development Locations

Paragraph 4.6.2 of the draft Core Strategy states that the Council will not allocate sites which are considered sensitive due to landscape designations, biodiversity issues or are liable to flooding. We agree with this approach as a number of Green Belt sites have been put forward which do raise these issues and should be avoided.

Countryside around Hockley and Hawkwell in particular does have a number of environmental designations from the Roach Valley, Hockley Woods to the southern boundary of the conurbation, and also a series of open spaces and wildlife throughout the area. Therefore the conurbation as a whole is significantly limited in terms of its prospects for development. However, what we would like to clarify is that the site that we represent, Land off Thorpe Road, is not presented with any such physical or environmental constraints.

The Core Draft identifies 3 tiers of settlement within the district. The top tier is Hawkwell/Hockley, Rayleigh and Rochford/Ashingdon. These settlements have been identified as the top tier of settlements as they have a good existing range of services and facilities as well as some access to public transport. They are capable of some expansion, infilling and redevelopment. These sites would be capable of accommodating housing in the short term as they benefit from existing infrastructure.

Taking into account sustainability issues, the Council believe that the settlement pattern should be focused on existing settlements, with the main settlements taking the majority of development required. The draft core strategy identifies the 'majority' of development as 90% of the overall housing requirement for the District, some 4140 dwellings by 2021.

The draft Core Strategy sets out a preferred split of housing allocations as set out below:

Rochford/Ashingdon - 1000
Hockley/Hawkwell - 400
Rayleigh - 1800
Smaller Settlements - 500

A number of sites have been put forward for the allocations DPD. Taking the characteristics of each of these sites into consideration, the environmental constraints and also the existing position of each of the main settlements, we would consider that the allocations proposed by the draft adequately reflect the level of development that would be feasible without causing undue harm to the districts settlements.

With particular regard to the sites of Hockley and Hawkwell, paragraph 4.6.19 of the draft Core Strategy identifies that Hawkwell is the best located part of the conurbation, being only a short distance from the Cherry Orchard Link Road. The land off Thorpe Road is very close to the link road. Also, it is approximately 1km away from Hockley town centre and the railway station. There are also local shops and services at a lesser distance. Additionally, there are bus services in Main Road and Rectory Road.

Affordable Housing

Under guidance set by the East of England Plan (Policy SS13) the LPA consider the threshold for affordable housing should be set at 25 units with a provision of 30% required.

It is stated in paragraph 4.7.6 of the draft Core Strategy that the Council will examine the details of affordable housing through the preparation of its other DPD's. It is intended that the allocations DPD will provide a minimum figure for the number of affordable units to be completed on each site specified.

We consider that the proposed housing allocation sites should be identified by the opportunity to contribute towards the affordable housing requirements in the district.

Housing allocation sites should be of a certain size that will trigger the affordable housing threshold of 25 units, to be able to contribute towards affordable housing. Additionally, sites should be able to be developed without the need for major infrastructure costs, as high building costs could result in a justification for developers to provide less affordable housing on specific sites.

If wholly used, the site known as land off Thorpe Road could accommodate not less than 330 dwellings. Under the guidance proposed by the Council the site could therefore accommodate up to 90 affordable units which is a large part of the required affordable units across the entire district. The site does not require any major infrastructure works and therefore the affordable housing provision envisaged would be achievable.

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.

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.

Local Development Framework - Re The Lords Golf Course site (formerly The Hanover) and neighbouring land fronting Lower Road and Hullbridge Road, Rayleigh Essex SS6 9QS

Further to our letter of 16th February 2007 concerning the above site, which you have agreed to kindly consider for possible future housing development as part of your preparation for the Allocations Document, we understand we shall be given the opportunity to expand on the merits of this potential site in due course.

However, at this stage, we feel it is appropriate to consider the potential for the development of the above site within the context of the Draft Core Strategy options currently being considered by the Council.

Accordingly, we enclose our comments which we ask you to treat as being formally submitted in response to the current public consultation on the Councils Draft Core Strategy preferred options (Regulation 26) and trust this may encourage the Council to adopt an appropriate strategy sympathetic to our client's aspirations relating to the above mentioned site.

1. We support the broad approach of directing future housing growth towards established settlement areas and avoiding any significant growth within or around the more modest rural settlements situated within the eastern part of the district.
2. However, in view of the recent housing growth which has taken place within the District's main urban areas, together with the planned future demand for housing, it is felt future residential development should be more widely distributed around the fringes of the established urban areas.
3. The current strategy is felt to be too rigid in this respect and a more flexible approach is needed to avoid an over concentration and to make best use of existing services, facilities and communication links.
4. We suggest some loss of the existing Green Belt in appropriate fringe locations adjacent to the existing establish main settlement areas is unavoidable and, given the limited opportunities for redevelopment or windfall sites remaining within the settlement areas, a controlled and orderly adjustment to the Green Belt boundaries around some of the existing urban areas, in appropriate sustainable locations, is felt to be necessary.
5. This will give an opportunity to provide much needed affordable housing and create mixed high quality and attractive sustainable schemes within such locations, at appropriate densities to ensure the efficient use of land. This approach is more likely to safeguard the residential amenity and character of established residential areas, whilst safeguarding the vast majority of the surrounding countryside and protecting the rural character of the district.
6. It is apparent from the Councils analysis (4.2 - 4.5) that the local authority can no longer rely on regeneration within established settlement areas alone, without some release of the Green Belt.
7. The Councils spatial vision for the district appears to envisage development opportunities on existing Green Belt sites around the urban fringe can achieve attractive sustainable environments which can be landscaped and connected to the green grid and public open space. In addition such projects can incorporate enhancement to public open space and make a positive contribution towards community facilities, in appropriate locations. This can help to address the recognised deficit of playing pitch provision in the district.
8. Without seeking to deny the protection of the Green Belt is an important consideration, by adopting a sensitive and careful approach, some rounding off of existing settlements and limited residential expansion into the Green Belt is felt to be necessary and reasonable within the plan period, as is implied in paragraph 4.26.
9. The combination of generally maintaining the existing Green Belt boundaries but allowing some release of fringe sites to enable appropriate residential expansion to take place is considered to be an appropriate approach, particularly when reinforced by the inclusion of strategic buffers to ensure adequate separation is maintained between neighbouring settlements.
10. Whilst accepting the need to adhere to national policies and guidelines in respect of the protection of the Green Belt and the need to safeguard the rural character of the district, in view of the demand for housing which must be accommodated in the most appropriate way, we respectfully submit that the Development Control Policies DPD should allow for some relaxation of Green Belt control, particularly with regard to sites to be identified on the proposals map, taking into consideration the sites allocation DPD process. We feel it important that the Core Strategy at this stage should not rule out such an approach.
11. Such an approach can be adopted, in suitable locations so as to integrate new housing together with Green Tourism and leisure facilities, in order to provide a viable framework for the provision of facilities which would not otherwise become available to benefit existing communities.
12. We note the Council's intention to make sites specific allocations in the allocations DPD in order to accommodate the housing provision for Rochford for the period 2001-2021.
13. Flexibility is needed at this stage, particularly bearing in mind the Councils review of its Urban Capacity Study prepared in 2001 has not yet been completed and the planning circumstances have significantly moved on since the last study was carried out.
14. The Council's proposed compromise referred to paragraph 4.5.10, to release land from the edge of settlements, will inevitably mean the loss of some Green Belt land. Nevertheless, this approach will ensure high quality development can be achieved with minimal impact on openness and rural character or Green Belt objectives.
15. It is noted that the Council have excluded the policy option to prevent the need for any Green Belt Release (para 4.5.12).
16. In this respect we suggest the Council should not exclude the contribution which medium sized sites can make, subject to the merits of each individual case being carefully considered (para 4.5.11).
17. The need for the strategic buffers is recognised but they should not preclude any reasonable development proposals brought forward during the allocations DPD process. In this respect it will therefore be necessary to retain a degree of flexibility as to the precise location of the boundaries of these "buffers".
18. We respectfully suggest the 90% figure referred to in 4.6.6 should be treated as indicative only since much will depend on the outcome of the above mentioned Urban Capacity Study and the quality and range of sites which come forward at the site allocations stage. Having said this we accept it is sensible to channel the majority of new housing development within and adjacent to the main settlements.
19. We would suggest Hullbridge and the immediately surrounding area can be seen to have greater potential for expansion compared with Canewdon and Great Wakering, having regard to the character and scale of these existing settlements and accessibility to the wider area.
20. The development of our client's site which is situated close to the settlement of Hullbridge will provide the opportunity for local services and facilities to be enhanced.
21. We accept the Strategic Buffers are indicatively shown at present but we would respectfully suggest there is some potential for some expansion to the south of Hullbridge without prejudice to retaining a reasonable Strategic Buffer between any such development and the urban area of Rayleigh.

At this stage, we feel it is appropriate to consider the potential of the above site for development within the context of the Draft Core Strategy options currently being considered by the Council.

Accordingly, on behalf of our clients we enclose a document containing our comments in response to the current public consultation and trust this will encourage the Council to adopt an appropriate strategy sympathetic to our client's aspirations relating to the above mentioned site. You will appreciate the enclosed submissions have been lodged within the required timescale.

1. We support the broad approach of directing future housing growth towards established settlement areas and avoiding any significant growth within or around the more modest rural settlements situated within the eastern part of the district.
2. However, in view of the recent housing growth which has taken place within the District's main urban areas, together with the planned future demand for housing, it is felt future residential development should be more widely distributed around the fringes of the established urban areas.
3. The current strategy is felt to be too rigid in this respect and a more flexible approach is needed to avoid an over concentration and to make best use of existing services, facilities and communication links.
4. We suggest some loss of the existing Green Belt in appropriate fringe locations adjacent to the existing establish main settlement areas is unavoidable and, given the limited opportunities for redevelopment or windfall sites remaining within the settlement areas, a controlled and orderly adjustment to the Green Belt boundaries around some of the existing urban areas, in appropriate sustainable locations, is felt to be necessary.
5. This will give an opportunity to provide much needed affordable housing and create mixed high quality and attractive sustainable schemes within such locations, at appropriate densities to ensure the efficient use of land. This approach is more likely to safeguard the residential amenity and character of established residential areas, whilst safeguarding the vast majority of the surrounding countryside and protecting the rural character of the district.
6. It is apparent from the Councils analysis (4.2 - 4.5) that the local authority can no longer rely on regeneration within established settlement areas alone, without some release of the Green Belt.
7. The Councils spatial vision for the district appears to envisage development opportunities on existing Green Belt sites around the urban fringe can achieve attractive sustainable environments which can be landscaped and connected to the green grid and public open space. In addition such projects can incorporate enhancement to public open space and make a positive contribution towards community facilities, in appropriate locations. This can help to address the recognised deficit of playing pitch provision in the district.
8. Without seeking to deny the protection of the Green Belt is an important consideration, by adopting a sensitive and careful approach, some rounding off of existing settlements and limited residential expansion into the Green Belt is felt to be necessary and reasonable within the plan period, as is implied in paragraph 4.26.
9. The combination of generally maintaining the existing Green Belt boundaries but allowing some release of fringe sites to enable appropriate residential expansion to take place is considered to be an appropriate approach, particularly when reinforced by the inclusion of strategic buffers to ensure adequate separation is maintained between neighbouring settlements.
10. Whilst accepting the need to adhere to national policies and guidelines in respect of the protection of the Green Belt and the need to safeguard the rural character of the district, in view of the demand for housing which must be accommodated in the most appropriate way, we respectfully submit that the Development Control Policies DPD should allow for some relaxation of Green Belt control, particularly with regard to sites to be identified on the proposals map, taking into consideration the sites allocation DPD process. We feel it important that the Core Strategy at this stage should not rule out such an approach.
11. Such an approach can be adopted, in suitable locations so as to integrate new housing together with Green Tourism and leisure facilities, in order to provide a viable framework for the provision of facilities which would not otherwise become available to benefit existing communities.
12. We note the Council's intention to make sites specific allocations in the allocations DPD in order to accommodate the housing provision for Rochford for the period 2001-2021.
13. Flexibility is needed at this stage, particularly bearing in mind the Councils review of its Urban Capacity Study prepared in 2001 has not yet been completed and the planning circumstances have significantly moved on since the last study was carried out.
14. The Council's proposed compromise referred to paragraph 4.5.10, to release land from the edge of settlements, will inevitably mean the loss of some Green Belt land. Nevertheless, this approach will ensure high quality development can be achieved with minimal impact on openness and rural character or Green Belt objectives.
15. It is noted that the Council have excluded the policy option to prevent the need for any Green Belt Release (para 4.5.12).
16. In this respect we suggest the Council should not exclude the contribution which medium sized sites can make, subject to the merits of each individual case being carefully considered (para 4.5.11).
17. The need for the strategic buffers is recognised but they should not preclude any reasonable development proposals brought forward during the allocations DPD process. In this respect it will therefore be necessary to retain a degree of flexibility as to the precise location of the boundaries of these "buffers".
18. We respectfully suggest the 90% figure referred to in 4.6.6 should be treated as indicative only since much will depend on the outcome of the above mentioned Urban Capacity Study and the quality and range of sites which come forward at the site allocations stage. Having said this we accept it is sensible to channel the majority of new housing development within and adjacent to the main settlements.
19. It will be noted the indicatively shown Strategic Buffer at present would not preclude some modest enlargement of the established residential part of Ashingdon, in a northerly direction. This would fully safeguard the strategic separation from Hockley/Hawkwell to the west.

We are instructed by our client Fairview New Homes Ltd, to submit comments on the published Preferred Options Core Strategy Document, and these are set out below. For ease of reference specific references have been made in accordance with the paragraph numbers as contained in the published document.

Core Strategy Issues: The Green Belt and Strategic Buffers Between Settlements, Housing Numbers and Phasing and General Development Locations

In addition to the stated Preferred Option, the subsequent supporting text in Paragraph 4.2.6 states that the Council will 'consider releasing land where it fails to fulfil green belt objectives', which is clearly not reflected in the Preferred Option.

There is thus inconsistency between this text and the Preferred Option. The flexibility of the supporting text is paramount to the ability to deliver housing over the plan period, and further, its importance in the ability to assist with other plan objectives, such as land that is suitable for housing, as this will assist in delivering the required number of new dwellings across the district and is given support by my client.

This flexibility is essential in larger settlements, such as Rayleigh where 1800 new dwellings are required across the 15 year plan period, as stated at Paragraph 4.6.10.

Further, release of small areas of Green Belt surrounding larger settlements will allow a concentration of development in key areas. The larger existing urban areas, for example, Rayleigh provide the most suitable locations to take future development and infrastructure. Support is therefore given to the sentiments provided at Paragraph 4.6.6 regarding the future sustainability in Rochford and development locations. Further support is clear at Paragraph 4.6.15, where reference is made to top tier settlements being best placed to accommodate expansion.

In addition, Paragraph 4.6.8 outlines the need for focusing new development on the most sustainable sites 'around' the largest and most established settlements. Concentrating development in these areas, which may require the release of parts of the Green Belt, will allow for increased protection and delineation of the Green Belt and a reduced need for development in other smaller areas surrounded by Green Belt.

Without this required flexibility in the policy approach, no assessment can be made as to the appropriate release of land that is be suitable and required for housing, nor as to the requisite phasing/hierarchy that would inform such release.

It is, therefore, proposed due to the above reasons that a formal policy be included within the Core Strategy to allow the review of the Green Belt, as necessary, so as to provide flexibility in, and ability to, meeting the Districts development needs, and that this policy should define the phasing/hierarchy of release. A policy of this nature would, additionally, provide support in maintaining the settlement hierarchy outlined at Paragraphs 4.6.3 - 5.

Core Strategy Issue: Affordable Housing

Although the percentage requirements are in line with guidance provided in PPS3, the National Guidance also states that an overall plan wide target should be set (PPS3 Paragraph 29 Part 1). Consideration should be had towards individual locations and specific sites depending on the findings of the Strategic Housing Needs Assessment (PPS3 Paragraph 29 Part 3). As a result it is suggested that the above preferred option contain an element of flexibility and negotiation to bring the policy in line with National Guidance.

As well as resulting in a policy that would be consistent with National policy affordable housing would then be able to be provided in the most suitable areas, for example in the most sustainable locations with established infrastructure. A policy containing an element of negotiation would also be more sensitive to local housing need as it fluctuates throughout the Council's administrative area rather than a blanket approached as outlined in the preferred option.

Once again there is inconsistency between the supporting text and the preferred options. Paragraph 4.7.2 considers that LPAs must 'negotiate' for the inclusion of an element of affordable housing provision on larger sites. However, there is no mechanism to provide any negotiation in the Council's affordable housing preferred options.

Further, the second point of the preferred options required that affordable housing be spread throughout new development. Whilst my client is sure you are aware, management is a real issue for social landlords, and often it is not practical to adopt a 'pepper pot' approach.

Core Strategy Issue: Landscaping

Whilst it is understood that it is appropriate and important for the Council to seek environmental improvements as part of new developments, the requirement made would have to specific and in relation to the development. The Council make reference to this in the supporting text at Paragraph 4.11.5 and Fairview New Homes believe that explicit reference should be made within the preferred option. In addition mechanisms would need to be put in place to enable varying provisions relevant to each situation.

In addition, PPS3 states at Paragraph 54 that LPAs should prioritise deliverable sites for development. Care should be taken to ensure that the preferred option for landscaping does not result in extensive financial costs that prohibit the development of deliverable sites identified as part of the housing trajectory. This issue could be avoided by providing a specific and negotiable policy concerning landscaping.

Core Strategy Issue: Energy and Water Conservation and Renewable Energy

Support is given to the Council's intention to reduce the need to travel and encourage energy efficient transport. Concentration of development surrounding existing larger settlements in the district will facilitate this provision. A larger population will provide a greater number of people to make use of public transport services and as a result increased funding to improve services with regards to energy efficiency.

Allowing further development around settlements with existing transport infrastructure would provide the most sustainable option. Development in this location would also reduce the overall need to travel due to the proximity of existing employment, services and other facilities. This is in line with comments made above regarding General Development Locations. This is clearly supported by Paragraph 37 Part 2 of PPS3. It is, therefore, proposed that the preferred option should make reference to sustainable locations supporting public transport.

Fairview New Homes would like to object on a number of grounds, set out below, that the Council's preferred option that all new development in the district is carbon neutral is unrealistic and unobtainable. Whilst it is important and achievable to include an element of renewable energy provision in all developments, as noted at Paragraph 4.12.6, this is not comparable to requiring carbon neutral development.

Although the Council's concerns are understood, it should be included in the preferred option that carbon neutral development will not be possible on all sites and that there is an element of variation. It is recognised in the text at Paragraph 4.12.8 that locations vary and this should be carried through to the preferred option. A further limiting factor is the cost of providing a carbon neutral development. Development on certain sites will become unfeasible and investment in the area will as a result become threatened.

It is also unclear from the preferred options or supportive text the Council's priority regarding other Core Strategy Issues. For example, would the Local Authority accept development that was not carbon neutral in order to meet the housing requirement over the plan period?

Core Strategy Issue: Compulsory Purchase and Planning Obligations

Fairview New Homes is aware of the need of Planning Obligations attached to planning permissions. However, the Council should be mindful of meeting the five tests set out Paragraph B5 of Planning Circular 05/05, in that planning obligations should be relevant, necessary, directly related to the proposals, of an appropriate scale and reasonable.

Core Strategy Issue: Community, Leisure and Tourism Facilities

Support would like to be given to the Council's preferred options regarding community, leisure and tourism facilities, provided that there is compliance with Paragraph 4.14.7 of the supporting text. As the LPA recognise it is important that proposals are judged against material considerations and that this judgement is carried through to adoption of the document.

On behalf of our client we would be grateful if you would acknowledge receipt of this submission and have due regard to these comments when making changes to the Core Strategy prior to the submission of the document.

Introduction

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

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

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

Green Belt & Strategic Buffers Between Settlements

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

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

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

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

Housing Numbers and Phasing

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

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

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

General Development Locations

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

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

Employment

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

Community, Leisure & Tourism Facilities

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

Land at Home Farm

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

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

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

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

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

These simplified responses will tend to refer to areas of concern rather than items such as the proposals for the extension of protection of the Roach Valley and the Cherry Orchard Jubilee Park, which the Parish Council welcome and support.


Spatial Vision

* 2.6 The PC sees the delivery of mixed dwelling types and affordable accommodation as essential, as through its planning comments it has repeatedly expressed concern over the loss of mixed accommodation within Hockley.
* 2.8 Given progress to date there is serious concern as to whether completion at the airport will be achieved within the next five years.
* 2.24 Again given progress to date there is concern that should be made an absolute priority.


Core Strategy Issues

* 4.2.6 The PC would wish to know whether sites such as Pond Chase Nurseries, or other sites in and around Hockley, would come in this category.
* 4.3.3 Will RDC increase spending and man power to achieve this?
* 4.4.9 The PC would remind RDC of recent efforts to get the very important historical area around the parish church of SS Peter and Paul included in an appropriate protection designation.
* 4.5.4 The PC continues to be concerned over the effect of infilling, Particularly "windfall Sites". on the infrastructure.
* 4.5.6 Again, would this affect sites such as Pond Chase Nurseries?
* 4.5.8 Logically Infrastructure and services should be in place before development to avoid strain or disruption on those existing.
* 4.5.10 The PC would wish to be advised of any such proposals for Hockley.
* 4.6.23 There is indeed a current need to improve public transport, particularly busses. Over the years the PC has received requests for the extension of a bus service, at least to Apex corner in Plumberow Avenue.

Affordable Housing

* As a general comment the PC considers this the highest priority. It is also concerned that infilling will contribute little to this. The authorities views on this would be welcomed.


Employment

* Again a general comment. It is to be hoped that the authority is working closely and directly with local school and not just the County Authority.




Good design and Design Statements

* The PC's Planning Committee has been seriously concerned over the contrasting quality of many single and small developments in Hockley. Of particular concern has been the very poor design of many rooms in the roof. The PC welcomes clear and enforceable policies that require a high standard of good design.
* Irrespective of any listing the PC would wish the authority to have regard for the preservation of buildings of quality, historic interest and character when considering redevelopment. ( For example the old doctor's ouse, Southend Road, now demolished.)

Community, Leisure & Tourism Facilities

* There is an urgent need for improvements to youth facilities, particularly unstructured leisure.

On Behalf of The Hockley Parish Council
Cllr R Vingoe.

Rochford District Council: Local Development Framework - Core Strategy Preferred Options (Regulation 26) Draft

I am writing in response to your Core Strategy Preferred Options (Regulation 26) Draft consultation. I enclose a copy of our representation made on behalf of our client Persimmon Homes Essex.

I trust that this is self-explanatory, however, should you require additional information or wish to discuss any of the matters raised, please do not hesitate to contact me.

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options Development Plan Document.

1.2 The comments refer to the relevant paragraph numbers in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options, Swan Hill has serious concerns regarding the way the document has been prepared. The lack of clearly defined policies means that these will only appear in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. This is considered insufficient, and is likely to result in the document being considered to be unsound in front of an Inspector.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley
Hampshire
PO15 7AH

Tel: 01489 580853 Fax: 01489 580913 E-mail: peter.kneen@charlesplanning.co.uk


2.0 Section 4.2: Green Belt and Strategic Buffers

2.1 As set out in the earlier representations to the Issues and Options Stage of the Core Strategy, Swan Hill considered that the District Council need to set out that a review of the Green Belt boundary will be needed as part of the Rochford Local Development Framework. Given the housing requirements of the Draft East of England Plan, and the changes as a result of the publication of PPS3: Housing in November 2006, there will be a need for the District Council to identify areas where a Green Belt boundary review would be acceptable.

2.2 Many local authorities have recently seen their Core Strategies fail the Tests of Soundness due to a failure to clarify in their Core Strategy adequate awareness of how they will meet the strategic housing requirements of the Draft Regional Spatial Strategy. As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development would not result in the failure to comply with the general objectives of the Green Belt.

2.3 It is clear from the approach to general locations of development (as set out in Section 4.6 of this version of the Core Strategy) that the Council have accepted the need to expand into the Green Belt, and that where expansion is acceptable, it should occur in the most sustainable locations, i.e. the top and second tier settlements. As such, Swan Hill considers that the Green Belt policy should set out that the Green Belt boundary will be reviewed as part of the Rochford Local Development Framework and the Key Diagram should be amended to highlight the general direction where such an encroachment has been assessed to be acceptable.

2.4 A failure to undertake an assessment at this stage could result in the Core Strategy being determined to be unsound, as it would not provide sufficient information from which the rest of the Local Development Framework could feasibly operate. For example, without the spatial framework in the Core Strategy setting out the general locations into which development in the Green Belt would be acceptable, other documents, such as the Allocations DPD and Development Control Policies DPD could not operate. The Council need development at the edge of existing settlements, and as the Core Strategy currently stands, this is not achievable as all the settlements are bounded by Green Belt land, which under the provisions of PPG2: Green Belts, is protected from inappropriate development. The Hertfordshire Structure Plan made provision for the review of its Green Belt boundary (Policy 5), and could therefore be used as a guide to the approach the District Council could take in the preparation of their Green Belt policy for the Core Strategy.

2.5 In addition, PPS7: Sustainable Developments in Rural Areas sets out that local landscape designations should only be maintained where it can clearly show that other criteria-based planning policies cannot provide the necessary protection. In the case of the Strategic Buffers identified in the Core Strategy document, Swan Hill is not convinced of the need for these designations. Their primary purpose is to restrict settlements coalescence, however, the District benefits from the countryside being protected by the Green Belt, which was established to maintain the openness of the countryside and prevent urban sprawl which could lead to settlement coalescence. In view of this, Swan Hill considers that the provision of Strategic Buffers are unnecessary, where the existence of the Green Belt offers more than sufficient protection from settlement coalescence.

3.0 Section 4.5: Housing Numbers and Phasing

3.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas on previously developed land. However, given the character of the District, and the strategic housing requirement of the Draft East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements. As set out in paragraph 4.5.10, Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

4.0 Section 4.6: General Development Locations

4.1 As set out in Section 2.0, Swan Hill supports the approach taken by the Council towards the need to expand settlements into the Green Belt to meet the strategic housing requirements and that is must be done only in the most sustainable locations, and where the objectives of the Green Belt are not compromised. Swan Hill has considered further the Council's position towards only providing 10% of the strategic housing requirement to the second tier settlements (Canewdon, Great Wakering and Hullbridge), with 90% being located in the top tier settlements (Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh). This approach is generally accepted as it conforms to the principles of providing developments in sustainable locations, whilst also recognising that the smaller settlements need additional development to ensure services and facilities remain viable. Swan Hill welcomes the recognition that the provision of development on larger sites, in these top and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

4.2 However, as set out above, Swan Hill has serious concerns over the lack of direction the Council has taken towards identifying specific locations around the top and second tier settlements where sustainable urban extensions can be achieved. Without identifying these general locations, other Development Plan Documents cannot function to bring forward these allocations. As such, Swan Hill considers that the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensuring these minor extensions to the settlements can occur without offending Green Belt policy.

4.3 In respect of development in the other smaller settlements, below the top and second tier, Swan Hill supports the District Council's approach not to provide any identified allocations of land, but to simply reply on providing affordable housing in these locations, to meet only identified local need, through the provision of a rural exception sites policy.

5.0 Section 4.8: Affordable Housing

5.1 Swan Hill recognises the importance of providing affordable houses in new residential developments, in order to meet the specific needs of the existing population. In this regard, Circular 06/98: Planning and Affordable Housing and the Draft East of England Plan sets out provisions and thresholds for affordable housing as part of new residential developments.

5.2 As set out above, and in accordance with the provisions of PPS3, Swan Hill supports the Council's approach towards the inclusion of a Rural Exceptions Site Policy. In this regard, Swan Hill considers that the District Council have sought to apply the correct threshold from which new developments should provide affordable housing. Having regard to the Council's approach towards seeking a smaller number of larger sites around the District to meet their strategic housing requirements, setting the threshold at 25 dwellings or more would allow for a greater provision of affordable housing to be provided on these larger sites, without being a burden on developers seeking smaller-scale infilling type developments within the existing urban area. Setting a provision of 30% of all new houses on the larger scale sites would help provide a significant element of affordable housing to meet the needs of the local community.

6.0 Section 4.9: Good Design and Design Statements

6.1 In respect of the Council's preferred option that Design Briefs will be required in advance of the submission of all major planning applications, Swan Hill considers that the inclusion of this assessment is an unnecessary duplication of National policy and statutory requirement, particularly for major developments. The General Development Procedure Order (as amended) makes the submission of a Design and Access Statement for most types of development a Statutory requirement, and as such, it is considered unnecessary to include it in policies in the Core Strategy.

6.2 In respect of the issue regarding 'lifetime housing standards' and the Code for Sustainable Homes, Swan Hill recognises the importance of providing houses that conserve energy and minimise waste, and supports the requirement that all new homes comply with the minimum standards set out in the Governments Code for Sustainable Homes, particularly given that it could in the future become a mandatory requirement. In respect of the provision of 25% of all new homes meeting the lifetime housing standard, it is considered that many of the requirements of lifetime homes are presently controlled under Building Regulations provision, and would not therefore need to form part of any planning policy document. Swan Hill considers that it is appropriate to include within the Core Strategy the District Council's approach towards the provision of lifetime homes and that they would encourage developers go beyond the standard Building Regulations requirements in order comply, where appropriate and possible, with these standards.

7.0 Section 4.10: Character of Place and the Historic Environment

7.1 Swan Hill supports the provision of policies to protect the intrinsic character and historic environment of the District. However, Swan Hill considers that these policies should not be overly prescriptive. Each planning application should be assessed on its own merits, and the policies should allow for a degree of flexibility in the design of schemes so as to not stifle the creation of new, innovative schemes, and meet the density target set out in PPS3.

7.2 In respect of the provision of a new 'Local List' of buildings, Swan Hill considers that this is inappropriate, contrary to the provisions of PPS7, which seeks to remove unnecessary local designations. If a building is worthy of listing, it should be listed. The Local List cannot afford a building any form of statutory protection, and the List should therefore not be prepared.

8.0 Section 4.11: Landscaping

8.1 Swan Hill recognises the importance of a suitable landscaping scheme in new developments, particularly where a suitable landscaping scheme could significantly enhance the presence of new developments on the existing environment. It is also important to highlight that under the provisions for Design and Access Statements, landscaping forms an integral part, and should in many cases be sufficient to essentially set out the basis for a landscaping scheme in many small scale developments.

8.2 Swan Hill recognises the importance of landscaping schemes on larger development proposals, and that they should form part of the planning application pack, in order to provide a basis from which the Council and Developer would negotiate as suitable scheme. Swan Hill considers that it would be important as part of any landscaping policy proposal to establish what types of planning applications the Council would want a more detailed landscaping scheme. However, this should only occur in the relevant Development Plan Document, not in the Core Strategy, but in the Generic Development Control Policies DPD. It is considered sufficient within the Core Strategy to establish the approach to landscaping policies the Council will take, and to state that more detailed specific requirements for such policies will be set out within the Development Control document.

9.0 Section 4.12: Energy and Water Conservation, and Renewable Energy

9.1 With regard to the preferred options set out in this Section, each has been considered in turn below:

9.2 In respect of the issues of policies seeking to reduce the need to travel and encourage the use of energy efficient transport, this is generally accepted by Swan Hill as it conforms with National policy guidance in PPG13, in locating developments that reduce the need to travel, particularly by private car.

9.3 In respect of the second issue, this policy position is an unnecessary duplication of policy provisions already set out in Section 4.9 above. Swan Hill accepts in general the provision of policies regarding the development of new houses compliant with the Code for Sustainable Homes, particularly given that this could become a mandatory requirement in the future.

9.4 In respect of the District Council's approach to seek that all new developments in the District are carbon neutral should not be set out as a policy of the Core Strategy, but merely defined as an aspiration of the Council. Seeking to require all new developments to be carbon neutral is unlikely to be achievable without resulting in it becoming a disincentive to developers to develop in the District. Swan Hill recognises the importance this position has taken recently by Government, and considers that it is important to incorporate within developments 'elements' of energy efficiency and means to reduce waste. However, in many instances it might not be a viable option to seek to impose such arduous requirements on all developments. This could ultimately result in the Council struggling to meet strategic requirements for housing and employment provision.

9.5 As set out above, whilst Swan Hill recognises the importance of including water and energy conservation measures within developments, it is considered that each development should be considered on its own individual merits and site specific circumstances. Given that Swan Hill accepts the approach that all new homes should be constructed in compliance with the minimum standards in the Code for Sustainable Homes, it is considered unnecessary to include policy provisions regarding water and energy conservation measures, as this already forms part of the minimum requirements under the Code.





10.0 Section 4.13: Compulsory Purchase & Planning Obligations

10.1 Swan Hill accepts that developments can have potential impacts upon existing infrastructure and as such developments should contribute towards improvements to, or contribution towards new infrastructure, commensurate with the level of need generated by the development.

10.2 Any form of planning contribution resultant from a planning application should be based on a site-by-site basis, and allow for a degree of flexibility so that contributions sought are achieved through negotiations between the developer and the District Council. All contributions should be based on an up-to-date assessment of existing services and facilities, in order to ensure developments do not result in a surplus or deficiency of provision or contribution.

11.0 Leisure, Tourism and Community Facilities:

11.1 In general terms, countryside policies should make provision for the allowance of leisure, recreation and tourism in the countryside, where a countryside location is essential. Swan Hill would support this approach. Further, it is considered appropriate to provide policy provisions for financial contributions in the Core Strategy towards leisure and community facilities, where appropriate. This policy approach should be flexible and the Council should seek to consider each application on its own merits, and how it would impact on existing leisure and community facilities.

We would like to put forward our land which we own in Bull Lane, Rayleigh to be considered for release from the greenbelt status and considered for possible development in the future. The land is located at the end of Bull
Lane. We are the owners of Plots 22 and 39 and are members of the Bull Lane Development Group. We understand that the majority of the owners of the entire site wish to have their land considered also. We believe there to be no reason for the land to be classified as "land included in special landscape" as it is of no special landscape value which becomes apparent
on visiting the site. The site backs onto the gardens of houses on the edge of the town and is therefore close to the local health centre, schools, bus routes and the local town centre. We think our land is ideally situated for consideration by the council.

Local Development Framework - Re Land north of Wren Close including Lichfield, Edwards Hall Park, Bosworth Road, Eastwood, Essex SS9 5AE

Further to our letter of 16th February 2007 concerning the above site, which you have agreed to kindly consider for possible future housing development as part of your preparation for the Allocations Document, we understand we shall be given the opportunity to expand on the merits of this potential site in due course.

However, at this stage, we feel it is appropriate to consider the potential of the above site for development within the context of the Draft Core Strategy options currently being considered by the Council.

Accordingly, we enclose our comments which we ask you to treat as being formally submitted in response to the current public consultation on the Councils Draft Core Strategy preferred options (Regulation 26) and trust this may encourage the Council to adopt an appropriate strategy sympathetic to our client's aspirations relating to the above mentioned site.

1. We support the broad approach of directing future housing growth towards established settlement areas and avoiding any significant growth within or around the more modest rural settlements situated within the eastern part of the district.
2. However, in view of the recent housing growth which has taken place within the District's main urban areas, together with the planned future demand for housing, it is felt future residential development should be more widely distributed around the fringes of the established urban areas.
3. The current strategy is felt to be too rigid in this respect and a more flexible approach is needed to avoid an over concentration and to make best use of existing services, facilities and communication links.
4. We suggest some loss of the existing Green Belt in appropriate fringe locations adjacent to the existing establish main settlement areas is unavoidable and, given the limited opportunities for redevelopment or windfall sites remaining within the settlement areas, a controlled and orderly adjustment to the Green Belt boundaries around some of the existing urban areas, in appropriate sustainable locations, is felt to be necessary.
5. This will give an opportunity to provide much needed affordable housing and create mixed high quality and attractive sustainable schemes within such locations, at appropriate densities to ensure the efficient use of land. This approach is more likely to safeguard the residential amenity and character of established residential areas, whilst safeguarding the vast majority of the surrounding countryside and protecting the rural character of the district.
6. It is apparent from the Councils analysis (4.2 - 4.5) that the local authority can no longer rely on regeneration within established settlement areas alone, without some release of the Green Belt.
7. The Councils spatial vision for the district appears to envisage development opportunities on existing Green Belt sites around the urban fringe can achieve attractive sustainable environments which can be landscaped and connected to the green grid and public open space. In addition such projects can incorporate enhancement to public open space and make a positive contribution towards community facilities, in appropriate locations. This can help to address the recognised deficit of playing pitch provision in the district.
8. Without seeking to deny the protection of the Green Belt is an important consideration, by adopting a sensitive and careful approach, some rounding off of existing settlements and limited residential expansion into the Green Belt is felt to be necessary and reasonable within the plan period, as is implied in paragraph 4.26.
9. Sites located at the northern fringe of the neighbouring built up areas of Southend-on-Sea Borough can provide a valuable source for future housing, making use of the facilities and infrastructure established to the south of the District, while integrating with the Rochford District's open space network.
10. The combination of generally maintaining the existing Green Belt boundaries but allowing some release of fringe sites to enable appropriate residential expansion to take place is considered to be an appropriate approach, particularly when reinforced by the inclusion of strategic buffers to ensure adequate separation is maintained between neighbouring settlements.
11. Whilst accepting the need to adhere to national policies and guidelines in respect of the protection of the Green Belt and the need to safeguard the rural character of the district, in view of the demand for housing which must be accommodated in the most appropriate way, we respectfully submit that the Development Control Policies DPD should allow for some relaxation of Green Belt control, particularly with regard to sites to be identified on the proposals map, taking into consideration the sites allocation DPD process. We feel it important that the Core Strategy at this stage should not rule out such an approach.
12. Such an approach can be adopted, in suitable locations so as to integrate new housing together with Green Tourism and leisure facilities, in order to provide a viable framework for the provision of facilities which would not otherwise become available to benefit existing communities.
13. We note the Council's intention to make sites specific allocations in the allocations DPD in order to accommodate the housing provision for Rochford for the period 2001-2021.
14. Flexibility is needed at this stage, particularly bearing in mind the Councils review of its Urban Capacity Study prepared in 2001 has not yet been completed and the planning circumstances have significantly moved on since the last study was carried out.
15. The Council's proposed compromise referred to paragraph 4.5.10, to release land from the edge of settlements, will inevitably mean the loss of some Green Belt land. Nevertheless, this approach will ensure high quality development can be achieved with minimal impact on openness and rural character or Green Belt objectives.
16. It is noted that the Council have excluded the policy option to prevent the need for any Green Belt Release (para 4.5.12).
17. In this respect we suggest the Council should not exclude the contribution which medium sized sites can make, subject to the merits of each individual case being carefully considered (para 4.5.11).
18. The need for the strategic buffers is recognised but they should not preclude any reasonable development proposals brought forward during the allocations DPD process. In this respect it will therefore be necessary to retain a degree of flexibility as to the precise location of the boundaries of these "buffers".
19. We respectfully suggest the 90% figure referred to in 4.6.6 should be treated as indicative only since much will depend on the outcome of the above mentioned Urban Capacity Study and the quality and range of sites which come forward at the site allocations stage. Having said this we accept it is sensible to channel the majority of new housing development within and adjacent to the main settlements.
20. The possible development of the area envisaged would closely relate to the established urban area within the Borough of Southend and would not represent any strategic encroachment into the countryside towards existing settlements within the Rochford District. Furthermore, the existing Edwards Hall Park could be enhanced as a result of any release of the land we have previously suggested for housing.
21. This could help facilitate an enlarged Country Park with green corridors to other existing public open spaces within the southern part of the district.

Land off The Poyntens - Part of Great Wheatleys Farm, Rayleigh, Essex SS6 7DH Local Development Framework

Further to our letter of 16th February 2007 concerning the above site, which you have agreed to kindly consider for possible future housing development as part of your preparation for the Allocations Document, we understand we shall be given the opportunity to expand on the merits of this potential site in due course.

However, at this stage, we feel it is appropriate to consider the potential of the above site for development within the context of the Draft Core Strategy options currently being considered by the Council.

Accordingly, we enclose our comments which we ask you to treat as being formally submitted in response to the current public consultation on the Councils Draft Core Strategy preferred options (Regulation 26) and trust this may encourage the Council to adopt an appropriate strategy sympathetic to our client's aspirations relating to the above mentioned site.

1. We support the broad approach of directing future housing growth towards established settlement areas and avoiding any significant growth within or around the more modest rural settlements situated within the eastern part of the district.
2. However, in view of the recent housing growth which has taken place within the District's main urban areas, together with the planned future demand for housing, it is felt future residential development should be more widely distributed around the fringes of the established urban areas.
3. The current strategy is felt to be too rigid in this respect and a more flexible approach is needed to avoid an over concentration and to make best use of existing services, facilities and communication links.
4. We suggest some loss of the existing Green Belt in appropriate fringe locations adjacent to the existing establish main settlement areas is unavoidable and, given the limited opportunities for redevelopment or windfall sites remaining within the settlement areas, a controlled and orderly adjustment to the Green Belt boundaries around some of the existing urban areas, in appropriate sustainable locations, is felt to be necessary.
5. This will give an opportunity to provide much needed affordable housing and create mixed high quality and attractive sustainable schemes within such locations, at appropriate densities to ensure the efficient use of land. This approach is more likely to safeguard the residential amenity and character of established residential areas, whilst safeguarding the vast majority of the surrounding countryside and protecting the rural character of the district.
6. It is apparent from the Councils analysis (4.2 - 4.5) that the local authority can no longer rely on regeneration within established settlement areas alone, without some release of the Green Belt.
7. The Councils spatial vision for the district appears to envisage development opportunities on existing Green Belt sites around the urban fringe can achieve attractive sustainable environments which can be landscaped and connected to the green grid and public open space. In addition such projects can incorporate enhancement to public open space and make a positive contribution towards community facilities, in appropriate locations. This can help to address the recognised deficit of playing pitch provision in the district.
8. Without seeking to deny the protection of the Green Belt is an important consideration, by adopting a sensitive and careful approach, some rounding off of existing settlements and limited residential expansion into the Green Belt is felt to be necessary and reasonable within the plan period, as is implied in paragraph 4.26.
9. The combination of generally maintaining the existing Green Belt boundaries but allowing some release of fringe sites to enable appropriate residential expansion to take place is considered to be an appropriate approach, particularly when reinforced by the inclusion of strategic buffers to ensure adequate separation is maintained between neighbouring settlements.
10. Whilst accepting the need to adhere to national policies and guidelines in respect of the protection of the Green Belt and the need to safeguard the rural character of the district, in view of the demand for housing which must be accommodated in the most appropriate way, we respectfully submit that the Development Control Policies DPD should allow for some relaxation of Green Belt control, particularly with regard to sites to be identified on the proposals map, taking into consideration the sites allocation DPD process. We feel it important that the Core Strategy at this stage should not rule out such an approach.
11. Such an approach can be adopted, in suitable locations so as to integrate new housing together with Green Tourism and leisure facilities, in order to provide a viable framework for the provision of facilities which would not otherwise become available to benefit existing communities.
12. We note the Council's intention to make sites specific allocations in the allocations DPD in order to accommodate the housing provision for Rochford for the period 2001-2021.
13. Flexibility is needed at this stage, particularly bearing in mind the Councils review of its Urban Capacity Study prepared in 2001 has not yet been completed and the planning circumstances have significantly moved on since the last study was carried out.
14. The Council's proposed compromise referred to paragraph 4.5.10, to release land from the edge of settlements, will inevitably mean the loss of some Green Belt land. Nevertheless, this approach will ensure high quality development can be achieved with minimal impact on openness and rural character or Green Belt objectives.
15. It is noted that the Council have excluded the policy option to prevent the need for any Green Belt Release (para 4.5.12).
16. In this respect we suggest the Council should not exclude the contribution which medium sized sites can make, subject to the merits of each individual case being carefully considered (para 4.5.11).
17. The need for the strategic buffers is recognised but they should not preclude any reasonable development proposals brought forward during the allocations DPD process. In this respect it will therefore be necessary to retain a degree of flexibility as to the precise location of the boundaries of these "buffers".
18. We respectfully suggest the 90% figure referred to in 4.6.6 should be treated as indicative only since much will depend on the outcome of the above mentioned Urban Capacity Study and the quality and range of sites which come forward at the site allocations stage. Having said this we accept it is sensible to channel the majority of new housing development within and adjacent to the main settlements.
19. The indicatively shown Strategic Buffers would not seem to precluded some modest expansion to the west of Rayleigh, as envisaged.

Policy Content

The main comments concerning the content of the published consultation document are as follows:

1. To satisfy government guidance, the Core Strategy Preferred Options stage should have moved significantly on from the previous Issues and Options stage in terms of scope, content, and process as outlined below.

2. The evidence base should be substantially expanded and rolled forward to ultimately justify the selection of the Preferred Option. In particular, further evidence involving urban capacity, strategic housing market assessment, strategic housing land availability, town centres & retailing, employment land review, and transport studies is required. The whole evidence base should also be extended and rolled-forward well beyond 2021 so as to comply with PPS3 Housing guidance (namely that adopted DPDs should look forward at least 15 years' ahead at the date of their adoption).

3. Rochford district has significant functional economic relationships with Southend, Basildon, and other parts of Essex Thames Gateway, as well as parts of Greater London. The evolving Core Strategy should consider how these relationships might change and develop up to 2021, and what the practical implications might be for job/home alignment, commuting patterns, transport, and patterns of development provision.

4. The urban capacity study needs urgent updating before the broad direction of any Preferred Options can be confirmed. It also needs to be linked into a strategic housing market assessment and strategic housing land availability assessment in accordance with PPS3. In this way, the re-use of previously-developed land (PDL) and the consequential need for any greenfield site releases in the district can be properly clarified. At present there is inadequate information about this issue to inform discussion of Preferred Options.

5. The Preferred Options stage should also investigate the spatial planning implications of the RSS jobs figure. It should identify where the net jobs increase will come from within different economic sectors, and what the corresponding land-use implications might be for B1 employment uses, office development, retail and services, tourism, and the public sector (such as education and health). The District Council should undertake an employment land review to assess the extent to which existing employment areas will remain suitable and which new or existing locations would best support the future economic strategy of the district. This should then feed into the consideration of the future accessibility of employment sites to housing locations.

6. The Preferred Options should contain policy guidance regarding the preferred strategy for the district's town centres. This should include discussion of strategic options and choices for the amount and location of retail provision and other town centre uses. The policy approach towards out-of-centre development should also be explored and clarified.

7. The range of alternative options for the development strategy should be explained much more explicitly. This includes identifying and quantifying how much new housing should to be provided on PDL and greenfield sites, respectively; and the development provision required for employment, offices, town centre and retail uses, and other major development. Having established the broad quantum of new development required in the district, the Preferred Options stage should set out the reasonable alternatives for the location of new development in terms of its spatial pattern. This includes both the numeric distribution between individual key settlements and the broad locations for any major development. The latter would include identifying the geographical sectors on the edge of major settlements. The reasoned justification for any preferred option(s) should also be set out explicitly by drawing on the results of technical studies, SEA and sustainability appraisal, transport studies, and the results of public consultation at previous stages.

8. The practicality and desirability of designating 'buffers' in policy terms within the Metropolitan Green Belt (MGB) is unclear. The stated purposes of the MGB already include preventing the coalescence of existing settlements plan situated within the MGB, so the proposed use of 'buffers' represents a duplication of existing policy. Alternatively, if the proposed 'buffers' are to perform a different policy role this is not adequately explained. Since greenfield land releases may be required in the district up to 2021 and beyond, it is unclear whether the proposed use of 'buffers' would be incompatible with such an approach or not.

9. The approach towards the provision of new affordable housing is based upon specific local size thresholds in terms of site size. However, the proposed local thresholds are different from those set out in PPS3 Housing. The use of local thresholds departing from national guidance requires special justification, but this is not provided. It is also unclear whether the proposed affordable housing could be delivered in the absence of clear mechanisms for its delivery.

10. The Preferred Options should set out much greater consideration of the elements of a sustainable transport strategy to support the 5, 10 and 15 year visions. The County Council would be willing to assist Rochford District Council in preparing this material to support its Core Strategy DPD submission.

11. The Core Strategy will require more consideration of implementation and monitoring in accordance with government guidance. In particular, the actions necessary for delivery, any absolute dependencies on infrastructure, and the timescale should be identified. The recent White Paper (Planning for a Sustainable Future, May 2007) is proposing that detailed implementation plans should be prepared alongside Core Strategy DPD preparation.


Future Process

In view of the above comments, Rochford District Council is recommended to:

a) Commission additional technical studies to support and supplement the evidence base, and extend the base well beyond 2021;

b) Give more explicit guidance about the range of future development options in the district for different types of new development, including a more fuller reasoned justification at arriving at any preferred option(s);

c) Carry out further public consultation on (a) and (b) before proceeding to the preparation of a Core Strategy DPD for submission to the Secretary of State.


2. MORE DETAILED COMMENTS

Spatial Portrait
Para 1.9 The sentence "Within the district road infrastructure is poor" should be deleted, as there is no evidence that Rochford's roads are particularly poor.

Para 1.9 The sentence "There are no designated Heavy Lorry Routes in the District and many routes are unfit for their current level of use" should be amended to "The district's road network is under pressure from increasing private car and commercial traffic."

Spatial Vision

Para 2.6 After second sentence add, "The larger new development sites will have been designed with priority access to public transport, pedestrians and cyclists in mind".

Para 2.14 Add "The South Essex Rapid Transit (SERT) project, enhancing the use and attractiveness of public transport in the Thames Gateway area, will have entered the District."
Para 2.24 Amend "Public transport is well used and has been enhanced by the completion of the South Essex Rapid Transit (SERT), which serves most of the population of the district." to "Public Transport is well used and has been enhanced by further South Essex Rapid Transit services."

Para 2.27 The phrase "Despite travel times to and from the airport increasing " should either be explained or deleted.

Green Belt

Para 4.2.7 The expansion of King Edmund School would require extra land in the Green Belt. Therefore, it may be helpful to include community facilities in the consideration of relaxation of policy.

General development locations

Para 4.6.2 The Rochford Core Strategy should have regard to the existing Brickearth Consultation Area when identifying new locations for development.

Para 4.6.1 Add at end: "embodying priority access by sustainable transportation modes consistent with Local Transport Plan policies as far as practicable where appropriate. Development will also be progressed with regard to highway development control policies to be defined in detail within the Development Control policies set of documents outlined in paragraph 3.9."

Para 4.6.3 While schools are included in the 'good range of facilities' alluded to, these settlements are only 'capable of sustaining some expansion' if the number of school places is increased. The document needs to be clear that there are insufficient surplus places to accommodate 3,900 additional homes.

Para 4.6.10 Significant additional schools capacity will be needed as set out below. In addition, Early Years and Childcare facilities will need to be provided in each case. Financial and land contributions from developers will be needed to deliver this infrastructure. The allocation of 300 more units than proposed to Hockley and 300 less to Rayleigh would provide a better fit in terms of maximising the use of current schools' capacity. Rochford/Ashingdon:- 1,000 UnitsThe capacity of Doggetts Primary can potentially be expanded to meet the needs of up to 1,000 new homes. If the sites are poorly located for this school, a new single form entry primary school would be needed (site area required 1.1 hectares). At secondary, King Edmund is already accommodating significantly more pupils than is recommended by the DfES for their site area. The school is forecast to remain oversubscribed. To expand, the school will need to obtain additional land. Land to the north and east of the school is open. The school has access difficulties with significant vehicle / pedestrian conflict and congestion at the start and end of the day. Incorporation of land to the north into the school site would allow the school to expand to serve new housing while at the same time providing improved access via Brat's Lane. The plan should allocate a minimum of 2.7 hectares of land for this purpose based on 1,000 new homes. RDC will need to consult with the School as to the precise piece of land needed. Hockley/Hawkwell: - 400 UnitsDemand for both primary and secondary places in the area is forecast to fall, which should allow this number of new dwellings to be accommodated without the need for significant additional capacity. Rayleigh: - 1,800 UnitsThis quantum of new development is likely to require an additional two forms of entry to be added to permanent capacity across the town at both primary and secondary levels. Half of this requirement at primary level can be met by expanding existing schools. The allocation of a single housing site of around 700 units would be needed to deliver a new single form entry primary school (1.1 hectares) to make up the anticipated shortfall. Limited expansion of Fitzwimarc and/or Sweyne Park can probably be achieved with careful planning/ negotiation with the schools. Smaller settlements: - 500 UnitsThe allocation of units to smaller settlements could help sustain rural primary schools within the District but would impose long term school transport costs upon the County Council that should be mitigated through developer contributions. Specific locations will require careful consideration.

Para 4.6.18 Reference to public transport should be added, as Rayleigh has excellent access by rail both towards London and Southend.

Employment

Para 4.8.8 Regional Employment Strategy should be amended to Regional Economic Strategy.

Good design & design statements

Para 4.9.9 Architects and developers should be required to design their new developments with the use of recycled and alternative materials in mind, as efforts to increase recycling will only be worthwhile if there is a local market for recycled products.

Character of place & the historic environment

Para 4.10.8 The policy bullet points should include reference to historic heritage (e.g. historic landscape and archaeology), not just identity and buildings.

Energy & water conservation & renewable energy

Section 4.12 It is considered the Core Strategy for Rochford should provide the basis of policy guidance for accommodating waste management facilities within the District in order to be consistent with the RSS and PPS10. Policies should address the following:

- Resource reduction, re-use and recycling during construction of new developments as a way of driving waste up the waste hierarchy. This should be a primary objective.

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

- Appropriate layout and design of buildings, external spaces and roads to allow for waste storage and collection and to facilitate waste separation and recycling. PPS10 contains guidance with regard to what facilities should be incorporated into non-waste related development.

- The recommendations on pages 91 - 94 of The Essex Design Guide Urban Place Supplement, which is being adopted by Rochford District Council as a Supplementary Planning Document.

4.12.11 The first bullet point relates to much wider issues than the energy conservation heading under which it appears. It should be a core policy in its own right, and include aspects such as safe routes to schools.

Compulsory purchase & planning obligations

4.13.7 Add education to list of justifications for compulsory purchase. As stated above, The King Edmund School needs to secure additional land.

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.

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.