4.6 General Development Locations

The inevitability of the housing stock
nust be accepted. However, in a semi-rural
area, the existing amenity of open spaces in close proximity are vital. Development of
of brown-field and poorly developed locations should be prioritised, such as Magnolia Road and the unmade roads running from it. Also
dilapidated property of which Brownfield
and under-utilised existing populated
and under-utilisedlocations to be used to the full before encroaching on 'new' sites.here is much in the district.In other words
Brownfield and under-utilised existing populated locations to be used to the full before encroaching on 'new' sites.

4.5.10 Proposal to release land from edge of settlements might produce coalescence and many live on such boundaries.

4.5.10 Proposal to release land from edge of settlements might produce coalescence and many live on such boundaries.

Comments from Councillor John Mason representing Hawkwell West Ward

Has Hawkwell already been chosen? It looks like it to me with the statement "Hawkwell is the best located part of the conurbation".

"Hockley/Hawkwell is less well located in relation to the existing highway network and close to its edges the conurbation has a more rural feel than Rayleigh and Rochford/Ashingdon. Hawkwell is the best located part of the conurbation, being only a short distance from the Cherry Orchard Way link road. There are a range of environmental designations surrounding the area from the Roach Valley and Hockley Woods along the southern boundary to a series of open spaces and wildlife sites elsewhere. The conurbation is significantly limited, as a result, in terms of opportunities for expansion."

There is no planning benefit for housing developments in Hawkwell West from the Cherry Orchard Way link road. This is a red herring and must be discounted.

The routes to and from Hawkwell are all seriously congested already. Ashingdon Road via Golden Cross is one example. Another is the Cherry Orchard Way link road which only goes to the already heavily congested A127 via three roundabouts which come to a standstill several times a day: Cherry Orchard Lane/Eastwood Lane/Nestuda Way/A127.

The access to the A130 and Rayleigh is via the B1013 and the congestion in Hawkwell/Hockley. The roundabout at Foxhunters is congested with serious tailbacks into Rectory Road several times a day.

It is understood that several large development sites in Hawkwell West have been notified to the Council. The sites in Thorpe Road are only accessible via a rural unmade road. This is not acceptable. Nor is the loss of green belt in this semi rural area.

The field to the east of the Clements Hall Leisure Centre has no access from there and only by a bridle way leading to Windsor Gardens. The Magees Mushroom Nursery is brownfield but again the access is via a bridle way.

Residents do not wish any of the green belt adjoining CHLC to be released for development.

Hawkwell West does not have any significant capacity for housing development and it is considered that the 400 house allocation for Hawkwell/Hockley is too high unless the District Council can forsee there being 20 or so small infill sites of average 20 houses which are already designated residential or brownfield sites with good access and infrastructure nearby.

On behalf of residents I object at this stage to the allocation of 400 houses to Hawkwell and Hockley.

I object with very great concern the development of the land which is east of Clements hall, Hawkwell.
We will lose more wildlife and rural ambiance,
as is the case in Eastwood.
I'TS ALL VERY WELL AND GOOD IF YOU DON'T ACTUALLY LIVE IN THE AREA.
Save our green/brown belt-think again!

I write with reference to the above Draft Core Strategy and wish to register my objection to the way the Planning Department is handling the development of Hawkwell especially in and around the Windsor Gardens and St Marys Church areas.

It is obvious that there will always be a "not in my back yard" objection to any redevelopment, but the plan to place four hundred dwellings in this area adjacent to Windsor Gardens Hawkwell is just ludicrous.

1. The area located from the Railway line through to Rectory Road including that of St Marys Church is the last rural open space of Green Belt land in Hawkwell, with pleasant views and many footpaths regularly walked by residents and visitors alike.

2. The area adjacent to the river (the proposed site alongside Windsor Gardens) has many low lying areas which become flooded in prolonged wet winter weather, indeed the Anglian Water Authority has already notified residents in Windor Gardens that the area is prone to flooding due to being the lowest part of Hawkwell.

3. The fields adjacent to Windsor Gardens (the proposed site) are all green belt land and should be retained as such for future generations and not sold off for the benefit of cash hungry developers that do not even live in Hawkwell. With many "Brown Field" sites available within the district and indeed even that of Magees Nurseries behind Windsor Gardens being available it is the Councils duty to use these sites rather than reduce the Green Belt areas further.

4. Massive developments of 400 houses in this extremely rural area will further devastate the natural flora and fauna which is abundant here with the trees, hedgerows and grassland which are encompassed within the scheduled green belt area. Although everyone realises that progress has to emcompass development and development means housing, sensitivity must be given to the immediate environment and with "infilling" most of this housing cuold be accommodated in already developed parts of Hawkwell alongside Main Road (between Nursery Corner and Mount Bovers Lane) and Rectory Road, apart from those of Victor Gardens, Thorpe Road, Mount Bovers Lane etc. and the many other developed areas within Hawkwell.

5. Four hundred dwellings mean a minimum of eight hundred vehicles all entering and traversing Rectory Road to leave the area. Already between 7.30am and 9.00am each weekday there is a tail back of vehicles from Nursery Corner of more than 400 metres with traffic trying to exit onto Hall Road for onward movement to Southend and London. Likewise traffic at Golden Cross and onward in Ashingdon Road and through Rochford is similarly congested.

In closing we the residents of Hawkwell look to you our Local Council to protect our environment for future generations, to protect the rural and peaceful Green Belt areas that this area is so lucky to still have within its boundaries and you the Planning Officers of our Council not accede to outside pressures from greedy developers to cover every green field site in the area with concrete so that we become another Basildon or Southend with designated small "leisure areas" and buildings and pollution rife, congested traffic gridlock and the loss of the already diminishing rural community and amenities we are so lucky to still have at present. Therefore please look again at the development of this small area and only allow building on already "Brown Field sites".

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

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

The plan used in the Core Strategy exhibition does not show the roads on the extreme edges of the area that is to be developed so that when looking at it you cannot define if your road is in or out of it.

Has the council considered allowing people who own land in unmade roads in the area to build?

Houses are being knocked down and flats are being built at an alarming rate in Rayleigh, this is altering the character of the area, in Downhall Road knocking down one house built in the 30's is a classic situation, at the moment 2 or 3 cars are used from this location if the development is allowed to go ahead there is a possibility of 30 cars being used. To reach your target of 1800 what percentage do you envisage will involve knocking down houses to build flats?

I can't believe the Council are even considering building 400 more homes in the Hawkwell/Hockley area. You will completely ruin the rural feel that Hawkwell has managed to maintain and is what makes living here as enjoyable. If you start destroying our small pockets of green space, we will just end up another overcrowded, overdeveloped village, attracting more crime to the area. People enjoy walking down unmade lanes like Thorpe Road because it takes them away from the noise and pollution of made up roads, if only for a short while. Destroy areas like this and people will soon jump back into their cars if there is nowhere peaceful to walk. Please don't spoil Hawkwell and please don't let our quiet country lane be turned into a made up road, lined with houses. This tiny piece of Hawkwell is a predominantly bungalow area, would be completely overwhelmed by housing development and it would be quite inappropriate to encourage more traffic to converge onto the already busy mini roundabout at the Rectory Road/Hall Road junction. Thorpe Road is just a small lane with a couple of areas of land containing trees and scrub and I was told by the Council when I moved here that it was Green Belt land and wouldn't be built on. It is a haven for wildlife which have a quiet undisturbed place in which to make their homes, away from the two busy roads. These include foxes, badgers, squirrels and muntjac deer, as well as a fine array of birds from the tiny goldcrest to birds of prey. We regularly have night time visits by foxes and badgers to our gardens. Horse riders, dog walkers children going to and from school all use this road and it is a safe way to Spencer's Park and Clements Hall away from traffic. Small areas like this help to keep the rural feel to Hawkwell, dividing up developments and stopping them from being overpowering, so please don't let this quiet spot be destroyed by greedy developers. Just think of the hundreds of years that this little lane must have been here - once lost, it can never be replaced. Thank you for listening and please fight to keep Hawkwell green.

Thank you for your letter of 21 May advising of the publication of the above document and seeking comments by 2 July 2007.

As you will be aware, the Highways Agency interest in the Local Development Framework process relates to the motorway and all-purpose trunk road network that it manages on the Secretary of State for Transport behalf. In the case of Rochford there are no trunk roads within the District although there are two strategic corridors namely the A13 and A127/A1159 which connect into the M25 motorway network at Junctions 30 and 29 respectively. Sections of these roads in the Thurrock and Brentwood borough areas are currently heavily congested, particularly during peak periods, and operate under considerable levels of network stress. Therefore it is important to the Highways Agency that the impact of major development proposals in the Rochford area is considered in the context of future impact on the M25 and the A13 Trunk Road.

The Core Strategy Preferred Options refers to infrastructure within the District being poor with some areas not being well served by public transport. Paragraph 4.6.1 states "To reduce reliance on motorised transport and to place development close to facilities and services, a development pattern needs to be sought which reflects this". However, paragraph 4.6.16 appears to be in conflict with this objective in that it refers to locating development at "top tier settlements" and to seeking infrastructure improvements, "particularly in relation to the highway network". This paragraph appears to be in conflict with Government and Council objectives to reduce reliance on motorised transport and improve public transport provision.

We are of course willing to expand on our comments if you would find it helpful at this stage of the LDF process, or discuss any other aspect relating to transport infrastructure in the area.

As you are aware, we have recently completed the analysis of the Hockley Parish Plan questionnaire, for which we had a 25% response, showing the enthusiasm of the residents to have their say in the future planning of Hockley.

Several questions were related to future development in and around Hockley, with particular reference to the proposed increase of 3700 new homes in the Rochford district. The related topics and the responses to questions on these topics can be summarised as follows:

1. Should Hockley remain as a distinct community?
It was unanimous with almost 100% of responses that Hockley should remain as a distinct community with clear boundaries and green spaces with no further infilling between Hockley and its neighbouring parishes.

2. Preferred methods of absorbing new homes
The most popular vote, with over 40% of responses, was that there should be no further development in Hockley. However, we are aware of the planned increase of 3700 new homes of which 50% seem to be in or east of Hockley, which will obviously have a serious impact.

The preferred methods for absorbing new developments were as follows:
* Building on plots that form part of existing property / industrial sites
* Small groups of houses
* Replacing houses with flats / apartments to protect greenbelt and open spaces
* Provision of a satellite village remote from Hockley
The least preferred methods were:
* Large housing estates
* Building on greenbelt and open spaces
* Infilling with mini-roads off main roads

3. Protection of old and historic buildings
There was strong support for preserving all the buildings that are currently listed. In addition, there were recommendations for several buildings that were previously put forward but rejected for listing, plus several buildings that have not previously been proposed. A list is currently under preparation for follow up with the appropriate departments to ensure their protection during development.

4. Appropriate development in terms of housing, leisure, community and business
The preferred types of appropriate development for Hockley were as follows:
* Youth centres
* Shops
* Restaurants
* Leisure facilities
* Starter homes
* Sports facilities
The least preferred appropriate development included:
* Workshops / Industrial Units / Business Parks
* Housing (except starter homes)
* Pubs
5. Appropriate infrastructure to match development
There was a major concern that infrastructure will not match housing developments in Hockley. The main issues included:
* Inadequate highways - need for a by-pass or alternative proposals to alleviate traffic congestion
* Insufficient medical centres
* Inadequate parking
* Inadequate community services
* Inadequate public transport
* Insufficient school places
The areas which seem to best match development include:
* Sewage disposal
* Water supply,
* Gas and electrical supply

6. Priority types of accommodation needed in future years
Apart from starter homes, there was very little support of additional housing in Hockley. However, assuming that the proposal for additional homes goes ahead, the preferred categories of accommodation needed in Hockley are:
1) Owner occupied
2) Private rented
3) Housing association
4) Shared ownership

The priority general types of accommodation needed are:
1) 2 Bedroom properties
2) 3 Bedroom properties
3) Retirement homes
4) 1 Bedroom properties
5) Sheltered accommodation
6) Homes for the disabled
7) 4+ Bedroom properties

The top 10 individual types of property needed are:
1) 3 Bedroom house - owner occupied
2) 2 Bedroom house - owner occupied
3) Retirement homes - owner occupied
4) 4+ Bedroom house - owner occupied
5) 1 Bedroom house - owner occupied
6) Retirement homes - private rented
7) 2 Bedroom flat / apartment - owner occupied
8) Sheltered accommodation - owner occupied
9) Sheltered accommodation - housing association
10) Retirement homes - housing association

7. Location of power cables
It was unanimous with almost 100% of responses that new power cables should be located underground.

8. Location of mobile phone masts
The most popular vote, with 64% of responses, was that there should be no additional mobile phone masts in Hockley. If there has to be more mobile phone masts, then there was a strong recommendation that they should be located remote from people and animals. As such, they should be remote (by at least 500 metres) from residential areas, schools and medical centres.

9. Pollution issues related to traffic and businesses
The main pollution issues were attributed to traffic (noise, smells and fumes) and businesses (smells and fumes). Any future development in or around Hockley is likely to increase pollution issues, and every effort must be made to offset pollution effects. In addition, any expansion at Southend Airport will increase pollution, and must be considered in any planning applications.

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

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

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

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

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

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

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

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

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

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

2.14 Why not include Rayleigh.

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

2.21-22 Not relevant to older people.

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

2.24 Surely council housing is the answer.

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

Section 3 this is for the most part theory.

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

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

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

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

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

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

4.6.3 talks about GOOD range of services. In terms of utilities, some of them in the Rochford/Ashingdon area are barely adequate and substantial upgrading would be required to satisfy the needs for water, sewerage, etc. Overhead electricity cables provide inherently unstable power supplies, but they are being used to provide services to Ashingdon Road and its surroundings.

Essex Wildlife Trust is pleased to note that sustainable development principles are being followed in 4.6.2, where the Council will not allocate sites which are considered sensitive due to landscape designations, biodiversity issues or where they may be at risk of flooding.

Section Four. General Development Locations

Para 4.6 The Council's intentions to allocate land sequentially and not to allocate land which is subject to landscape designations, biodiversity issues or at risk of flooding is supported. However, it should be accepted that such requirements will limit land available for allocation, particularly where priority is to be given to large previously developed sites within settlements. There should be an acknowledgement that these policy requirements should also apply to any edge of settlement allocations. Edge of settlement allocations will need to be subject to sustainability criteria and be able to demonstrate that they are equally close to existing public transport opportunities, employment, shopping and close to a good range of general facilities and services. Edge of centre sites of this nature, which can also meet deficiencies in community facilities or public open space provision or where they can facilitate the resolution of existing difficulties in access or highway improvements, should be given priority.

We support the Council's three tier settlement hierarchy in principle and in particular, the statement at paragraph 4.6.8 which states that the majority of new development will be focused on the most sustainable locations around the top tier settlements. The Council in making this statement appears to accept that the development will need to be, as it states, "around" these settlements, as opposed to being "within" them. This appears to be an acknowledgement that sufficient land may not be available from urban intensification.

The preferred option of a 90/10 split between the two top tiers is also generally supported. However, the subdivision of the 90% of the top tier, as set out in the preferred option table, is considered to be premature. The Council is not able at this time to accurately predict whether the number of units allocated to the individual settlement locations can actually be delivered. The evidence base for the subdivision is not currently available and the split may need to be re-allocated.

Furthermore, Rayleigh and Hockley/Hawkwell are to be further contained within Strategic Buffers, making any necessary edge of settlement releases more difficult. The Council will need to revisit the split within the top tier once reliable evidence is available. Any capacity which cannot be met in Rayleigh or Hockley/Hawkwell should be reallocated to Rochford/Ashingdon, in particular, the east of Rochford, where capacity is not constrained by Strategic Buffers. Furthermore, the land to the east of Rochford/Ashingdon provides a number of opportunities to connect successfully with the existing urban grain and infrastructure. Edge of settlement development east of Rochford/Ashingdon also provides opportunities to deliver many benefits, which can offset the minimal impact on the Green Belt in the Rochford district. These benefits include:-

• Ability to deliver long-standing open space/playing field deficiency
• Enhanced access to school
• Improved access to the countryside
• Alternative pedestrian/cycle access to Rochford town centre
• Direct access to mains sewer
• Ability to provide traffic relief via new infrastructure

4.6.3 - Agree with top tier of settlement hierarchy including Rochford in the top tier as a settlement with a good range of facilities and services as well as access to public transport. Rochford is considered to be capable of sustaining expansion, including a site which has been put forward within a previous LDF consultation to the south of Stambridge Road, abutting the settlement boundary.

4.6.3 - Agree with top tier of settlement hierarchy including Hawkwell in the top tier as a settlement with a good range of services and facilities. Hawkwell is considered to be capable of sustaining expansion, including a site which has been put forward within a previous LDF consulttaion to the south of Ironwell Lane.

The RSPB is pleased to see that poliy 4.6.2 ensures the use of sustainable development principles. We support the Councils decision to not allocate sites which are considered sensitive due to landscape designations, biodiversity issues or where they may be at risk of flooding.

I agree with the majority of your respondents. On the other hand, if this is to be a "fait accompli" then we must provide solutions that we can live with, for now and in the future. I am a great lover of the countryside, and Essex has much to offer. In particular, I am very fond of Roach Valley. It is an oasis in the middle of the terrible urban sprawl we recognise as RDC and SOS. I know it as well as I know my own home! And yet, there is one anomaly that could very well be of benefit to the Local Plan. I speak of a plot of waste-land at the "bottom" of Bull Lane, along a paved track that leads to a Farm. It is approx 100m X 100m and has been neglected for many years. It serves no useful purpose, and has nothing to recommend it. It is bordered on one side by a housing development and on the remaining three sides by farmland. It is probably a 1/3 mile to what anyone would consider to be the boundary of the Roach Valley public area. This is supposedly within the green-belt, but only in the very loosest sense of the word. In other respects it might be ideal for development. Amenities and transport links all all within easy reach. If it were to be developed then I would want the developers to understand that there should be absolutely no encroachment beyond the boundaries of this field - that would be unthinkable.

General Development - Hawkwell/Hockley cannot be said to have a good range of services. Doctors surgeries are full, schools are full; water pressure is low; and roads are at capacity. It cannot sustain 400 more houses.

Employment - Should Southend Airport be further developed it would increase the already congested traffic and of course air traffic - causing both noise and air pollution. We do not need the airport expanded.

Thank you for informing me of the new document "Rochford Core Strategy (Reg 26) - Preferred.

I have read the docment and also visited the exhibition in the WI Hall yesterday.

I note the intention to provide 400 new homes in the Hawkwell area. It is difficult to comment constructively without details of the actual sites which may be identified. Like most people I do not really wish to see green belt land taken, but do appreciate that there may be little alternative witin the Hawkwell area.

I also would wish to protect the existing residentail areas and the grass verges which are all of good quality.

My main concerns would be the supporting infrastructure:

Effect this would have on Educational provision at Holt Farm Primary School, and also King Edmunds School.

Effect on Health Care/GP surgeries. I am unsure about the continued provision of the surgery in Leecon Way Rochford after the death of Dr Sen.

Additional congestion of roads especially the Ashingdon Road and side turnings during times of the school run. (eg Wheatley Close is used for parking during these times).

Police and Fire Services may need additional resources.

On a big site local shops may be required.

Would like to request some additional provision of a Youth Facility or Family Centre to support young families requiring social support, within the new plan.

I hope these thoughts are of some help and will be keen to follow the next steps of the plan later on.

Whilst the Council's Preferred Option of focusing the majority of development in the district's principal settlements is acknowledged as being in accordance with national guidance, the Council has not provided any evidence to demonstrate whether the Option is achievable. More specifically, the Council have not updated their Urban Capacity Study to establish whether capacity exists within the district's principal settlements to accommodate 90% of the forecast development, or whether it will be necessary to make more use of settlements to the east of the district or release land from the Green Belt.

In addition, the Council have not identified when, or how, essential infrastructure improvements required to support future development within the district's principal settlements will be achieved.

Therefore, the Council's Preferred Option is not based on local evidence and only reflects national and regional objectives. Given that it is understood that the Council's Urban Capacity Study - the findings of which are essential to guiding future development within the district - is shortly to be finalised, the publication of the Preferred Options is both premature and prejudicial and denies members of the public an opportunity to comment on Preferred Options that are based on credible evidence before they are submitted to the Secretary of State for consideration.

Assuming that housing targets must be met, I think the strategy of concentrating development around the larger existing settlements is probably correct.
However, the document gives no indication of how the apportionment between Rochford, Rayleigh, Hockley,etc. was arrived at.Presumably, the Council have done capacity studies looking at the development potential of specific sites, but this information is not made available.Without site-specific proposals showing, for example how much green belt land would need to be taken, it is impossible to comment on the "general development locations", except to re-iterate that the district is already overdeveloped to the point where quality of life suffers.

One of the principal aims of National Policy is to encourage a thriving local economy, however, as with the Issues and Options version of the Core Strategy, there is no mention within the Preferred Options of the economy, and more specifically how it can be ensured that the district has a successful retail sector.

At present the Core Strategy does not cover future retail development within the district. PPS6 sets out the Government's key objectives for town centres and new retail development, seeking the continued vitality and viability of existing centres. This will be achieved by planning for the growth and development of theses centres through focusing development in them and encouraging a wide range of services in an environment, accessible to all.

PPS6 states that in order to promote social inclusion, policy should seek to ensure that communities have access to a range of uses and that deficiencies and provision in areas with poor access to facilities are remedied. PPS6 encourages local authorities to plan positively for growth and development including developing a hierarchy and network of centres.

For promoting growth and managing change in shopping centres, PPS6 states that a key aspect will be to plan for new centres, of an appropriate scale, in areas of significant growth where there are deficiencies within the existing network of centres.

Section 4.6 of the Preferred Options deals with the general location of development, specifically the location of new housing in sustainable locations Paragraph 4.6.3 refers to three tiers of settlement within the district, however there is no mention within the document of the hierarchy of the district's retail centres.

PPS6 encourages local planning authorities to adopt a positive and proactive approach to planning for the future of all types of centres within their areas. This must reflect the community strategy, setting out how the role of different centres will contribute to the overall spatial vision for their areas.

With specific regard to Rochford, the district is currently experiencing a significant level of trade leakage to dominant retail centres in the sub region, such as Southend on Sea. This current trend is unacceptable and unsustainable and in light of this background we consider that the Core Strategy should pay specific regard to the need to retain existing and future retail within the district to help secure a vibrant local economy.

We draw attention to the Park School site which is currently being built-out for a mixed use development. Currently the site is allocated for mixed use development within the latest Local Plan, however we consider that this should be taken forward within the LDF process to reflect the latest development on site and the latest Government guidance. The ceighbourhood centre element of the mixed use proposals was approved in December 2006 and is now under construction. We consider the Core Strategy should recognise such shopping centres and the role they will play in securing a vibrant local economy for the district. As such we propose that the approved Park School neighbourhood centre be hereon referred to as a district centre and allocated as such within the emerging LDF to reflect the latest guidance in PPS6.

Thankyou for consulting Network Rail on the Core Strategy Preferred Options.



We will take this opportunity to promote the attached sites once again for allocation.



In terms of the core strategy my comments are as follows.



Location of new development

Network Rail favours the direction of higher density development to areas with good access to public transport. This meets many of the national and regional planning objectives for sustainable development and also encourages the re-use of previously developed land, rather than expanding into green field areas. High density development around train stations could directly (where Network Rail estate land is used) or indirectly (through Section 106 contributions) support station improvement and interchange works.



Section 106 contributions

Network Rail considers that it is essential to provide for the pooling of contributions that are taken from developments in order to fund significant improvements to transport infrastructure.



With regard to the uses that will be considered for the application of contributions, Network Rail considers that there should be some provision for projects which are initiated to achieve an improvement in local infrastructure for example, where the development is proposed in order to facilitate infrastructure improvement, such as station upgrading work. Network Rail is funded to maintain the existing railway and do not have monies for enhancements, and therefore it looks to redevelopment with third parties or maximising the commercial value of its estate, to fund improvements.



To cover these circumstances it would be appropriate for there to be policy to assess developments which incorporate infrastructure improvement work, so that some (or all) of the suite of planning contributions may be waived in cases where mixed use or residential development is generated to enhance public transport facilities.



Station parking

Network Rail would like to comment that station car parking should be provided for in the LDF. People are more likely to use the national rail network if they are able to leave their cars at the station, in a safe, secure environment, and continue their remaining journeys by train. Providing park and ride facilities for passengers is preferable to them completing their whole journey by car, and clearly facilitates more sustainable travel patterns - an objective shared by Network Rail and the Council. The Council also needs to recognise that commuting is now an important part of people's lives, and has to be taken into account in the form of development it approves.



PPG 13 identifies the importance of interchanges, stating that "Quick, easy and safe interchange is essential to integration between different modes of transport". Long-term parking is required at stations to accommodate private cars for rail users for exactly this reason. Furthermore, for commuters who live in areas that are not well served by public transport or use the station at hours when there is little or no bus service, adequate station parking is essential.



Station car park users typically arrive at their local stations before the morning peak (for road traffic), and leave after the evening peak. It therefore follows that their movements do not occur within the peak periods for general road traffic, and should not be restricted by general policies or mechanisms that attempts to reduce the overall amount of road traffic. This is especially important when considering the role station car parking plays in supporting sustainable transport objectives, described above.



I would be grateful if you would retain Network Rail on your list of consultees and keep me informed on the progress of the Core Strategy.

Having regard to the representations submitted in respect of 4.5 and 4.5.11 it is considered premature to make judgements on Preferred Options for the distribution of development without first undertaking or publishing the Urban Capacity Study, Strategic Housing Land Availability and Market Assessment, a Sustainability Appraisal and Strategic Landscape Analysis.Whilst the general intentions to focus growth to the main large settlements follow soundly based sustainability principles there should be a proper assessment to inform a settlement hierarchy and the ability of those settlements to accommodate growth, examining opportunities for extensions to settlements to meet housing objectives.

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

Section 1 Spatial Portrait

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

Section 2 Spatial Vision

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

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

Section 3 Relationship of Documents

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

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

Section 4 Core Strategy Issues

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

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

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

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

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

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

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

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

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

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

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

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

Clause 4.5.12. Windfall development should not be ignored.

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

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

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

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

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

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

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

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

Clause 4.6.23 Believe the figures are flawed and unbalanced

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

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

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

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

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

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

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

Section 5 Implementation & Monitoring

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

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.

This school, with Essex Councy Council, has reviewed the draft form of your Core Strategy Preferred Options. It is obvious that Education was not a separate chapter heading within the framework and needs to be addressed in terms of:

Necessary developments in Education including Vocational Education.
The need to provide school places for the additional housing with 1000 dwellings in Rochford (4.6.22)
Employability and workforce needs (4.8)

As the pathways in education change, particularly to accomodation, vocational education and the vocational diplomas, th school must develop its facilities and resources and particularly its accessibility.

Essex County Council have indicated that whilst there is capacity within the primary schools in Rochford, this school is already accommodating more more students than is recommended by the DfES for our site area. Student numbers, including those from 1000 new homes, would indicate that we would remain oversubscribed. If we are to expand we would need to protect our playing fields and look to the area of the field to the north of the school, between our site and Brays Lane.

As you are aware we are desperate for new access to our site. The King Edmund School was built in 1962 at the end of a cul-de-sac in Vaughan Close with only 400 students and very little vehicle movement. We are now a school of 1550 students and we employ 180 staff, all of which currently access our site through Vaughan Close. We also host Rochford and Rayleigh Delivery Group and, as from this summer, the Rochford TASCC group.

Our local residential roads are grid locked in the mornings with 7 double decker buses endeavouring to disembark our students. This is a major Health and Safety concern. The very narrow Vaughan Close access is complicated by residents parking, thus causing real problems for delivery vehicles, causing them to often mount the pavements being used by students. In the afternoon, coaches can access the site through the narrow Oxford Road entrance but this can sometimes clash with visitors and sixth formers car parking.

Since the situation on site cannot be improved we need to:

Separate buses and other vehicles from pedestrians and staff traffic.
Provide access to parking areas without using the same paths as students
Provide an entrance space for access for deliveries and contractors
Provide access and parking for the increased community visits to the site.

Most of these issues could be addressed by new vehicular access from Brays Lane which would facilitate a turning circle and parking for buses, and would deliver students to the site rather than the surrounding streets. It would also provide access for deliveries but, most imporatantly, would provide access for our parents and community visitors.

Finally the Governing Body would ask you to very seriously and urgently consider the current and future needs of The King Edmund School, which is the main provider for secondary education for the children of the Rochford District residents.

The Governing Body and Management of the school would welcome a visit by members and officers of RDC to discuss the above matters.