4.6 General Development Locations

I should like to voice my concern and apprehension about the proposed development of housing in the Rochford District but particularly that affecting Rayleigh.

I attended the meeting at Rayleigh Windmill on Sunday 10th June but unfortunately the various charts on display made no reference to the possible locations for further housing which inevitably aroused unease and suspicion. Many people are fearful too about the inevitable vast increase in traffic further housing will cause which in turn will throw much strain on school, medical and social services. The traffic problem at present is making life difficult and a strain for many going to work every day so a future with more and more cars spilling on to the roads is hardly a welcome prospect.

Many of us suspect inevitably that the green belt is under threat in the light of what has happened elsewhere. One hopes of course, that brown field sites can be selected but we realise that often they are not an option because the land involved is toxic.

Community life as a whole will certainly suffer if the size of a town exceeds common sense limits.

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.

You may realise from my address that I live next door but one to the King Edmund School in Vaughan Close. I understand the RDC is consulting over its future plans for housing and the supported infrastructure.

Over the years we have seen the traffic attending the school, rise to unbelievable levels. All Teachers and deliveries come past our 12 little bungalows. Of the 12 homes only 3 households are of working age. Most of the main bedrooms of our dwellings are at the front, and obviously at floor level.

Delivery lorries rattle by from 7 am in the morning, followed by teachers who are asked to drive at 5 miles an hour within the school grounds, fly around the corner of Spencer Gardens and Vaughan Close at an alarming rate, never expecting a car to be coming the other way, or a child to be in the road. I should know, as I wait for a lift at 7.20am as the staff are arriving. We also have the 6th form children, newly passed their tests, who are not proficient enough to steer over to one side of the road, when something is coming the other way in the Close. We had to get out of the car the other day and ask the young driver to mount the pavement as she had not seen us coming, and we had a parked car to our left and she had totally blocked us.

Shortly after that the dreaded Buses arrive, spilling the children out on to rather narrow pavements, into Spencer Gardens. Half the children end up in the road anyway!

The traffic continues all day, with deliveries, builders (because the School is always building something), mothers, and other visitors. The School children mainly all leave at 2.00pm with eleven buses totally blocking Oxford Road. Other pupils leave later, because of school clubs etc. mothers picking them up from the pedestrian entrance blocking Vaughan Close.

Then the evening and weekend people are arriving right up to 10-10.30pm. No wonder the elderly residents of Vaughan Close look older than their years. Our road is falling into disrepair, and is badly in need of resurfacing, but we seem to be overlooked because of the constant traffic in our little narrow close.

If the Council is considering building houses in the area, the empty field in Brays Lane seems ideal. A new purpose built road, for the school and any new houses, could be incorporated, wide openings, 2 proper lanes, wide pavements and a turning area at the end for visitors, staff, buses and the pupils that drive to school.

Please consider my plea, I know you have the Brays Lane area earmarked as I attended a planning meeting several years ago. If you need housing, and the owner of that field will build your road for you if you give him planning permission, surely it resolves two problems in one go.

I would like to know more about the proposal to build houses on the farmland east of Clements Hall, behind Rectory Road and Magee's Nursery.

The reason being is that my wife and I have lived in Rectory Road for the last 44 years, and were here when we had the very bad flooding (up to our waists) in the late seventies, if it had not been for the fields around, the flooding would have been a lot worse.

I have grand children growing up and I understand that we do need affordable housing; my problem is with the infrastructure, I am sure the risk of flooding has been addressed but was the so called global warming effect taken into consideration at the time, we only have to see the tv news and the papers to see what can happen, the loss of life etc.

Yes we do need affordable housing but in the right place and I feel that Hawkwell has already had flood problems and this should be a lesson for the future.

I have no problem with the mushroom farm and the industrial units being used as they are already causing problems with the large lorries going backwards and forwards causing our property to shake, but the green belt area adjoining Clements Hall should be left alone for the above reasons.

I am writing in response to the King Edmund School request for a new access road to the school. Although I am in part against the building of new housing in this area because of over crowding I think that if this is the only way that a new access road can be built then it is a necessity. I have lived in Oxford Road for 23 years and in the past two to three years the amount of traffic comin gnad going from the school has tripled and is not at a point where leaving our own home has become a major headache.

Because of the amount of cars that homeowners now have in this road and therefore parked in the road, when the school is busy there are certain times when it is almost impossible to go out and use this road. We live quite close to this access road and witness people's anger at trying to use this road almost daily.

I feel that because of this problem the people of Oxford road and surrounding roads are being treated unfairly and do not deserve to have to change their daily arrangements to suit the schools needs, therefore, if there is an answer to it, even at the expense of having more building I feel it is time to do something about it.

At certain times of the day or evening if there was a need for emergency vehicles to come into Oxford Road it would be impossible for them to get down here in a reasonable time. The traffic build up also encroaches on Ashingdon Road and when the school has a late night arrival back at the school it can be impossible to get into our own driveway.

As this problem is only going to get worse I feel action is needed for the sake of residents as soon as possible.

With reference to a new entrance for vehicles at King Edmunds School at the moment the congestion in Boswell Avenue, Spencer Drive and Oxford Road is getting worse.

Now that the function of Brays Lane and Ashingdon Road has been improved it would make would make sense to have the vehicles come in from Brays Lane, and it would be safer for the children.

I understand that R.D.C. are in consultation over future plans for the area, and I also understand that it is the King Edmund School's desire for a seperate road for access to the school. I write to you to state that I heartily endorse this wish.

Living in close proximity to the school, I am well aware of the hazards, annoyance, and inconvenience the present access causes.

We live on the corner of Vaughan Close and Spencer Gardens, and it is a nightmare for us elderly and infirm residents when the vast - and sometimes articulated-lorries turn into and use this narrow turning, often using the footpath to gain access to the school, and the increased amount of traffic caused my recently deceased, handicapped husband a great amount of anxiety, and damage to the road and footpath.

Also being on the corner, we have the added inconvenience of the many coaches dropping off hundreds of children, (numbers which will increase in future plans) at our doorstep and naturally with the wide pavement at this spot, it also a social meeting place during school times and after, with all that that entails, bottles, cans, wrappers and cig'e ends, often dropped into our garden, and u sing our wall as a parking seat.

The litter has improved, and if there has been any serious trouble the school have been helpful, but all this would be alleviated if there was an alternative, seperate access to the school, which is long overdue, especially with the size of the school now and more so with extensions that are planned for the future.

I do hope you will take all this into consideration and the urgency of the need, when proposals and plans are being discussed.

The exhibition in Rayleigh Mill was poorly organised, not well advertised, minute space, impossible to speak to anyone, or look at the map, which was very poor, no main roads marked and one would expect something of this importance to have been displayed on a map of at least 'A0' size. Due to the cramped space, short time etc it appears the intention was to minimise the time and chance to discuss the situation. Also there were no booklets. We avidly object to this amount of development. There is absolutely nothing we can see about upgrading infrastructure in the area.

1) Roads. What are you doing to stop any increase in traffic on the B1013, Main Road Aldermans Hill High Road Hockley? Any additional cars vehicles from any development to the east will use this road to go Rayleigh/London/Chelmsford way or further West South or North.

1.1 It is impossible for many hours a day 7 days a week 06:30-19:30 to hold a conversation in our front garden due to the excessive noise from traffic the noise level on this road continuously and frequently exceeds noise levels under the health & safety regulations of 80 decibels, if commercial or industrial premises hearing protection would have to be provided and worn by law. What are you doing about it!

Also the high pollution levels from fumes.

1.2 Rawreth Lane Area

At a recent meeting where the Chief Planning Officers for Chelmsford gave a talk on these developments, and when asked about the already chaotic traffic situation in Rawreth Lane jammed up like the High Road Hockley for hours on end.

They made a big ploy that money had been obtained from the developers of the recent development to improve the junction with Hullbridge Road. When quizzed why it was not done, it was evident they had no idea what to do, if when and how; yet they had allowed all the other works to progress and occupy the premises! This can only be described as totally unprofessional and negligent. So everyone else has to suffer, increased risks of accidents at a busy junction waste time and frustration. They both lived out of the area. On further questioning it was evident they had virtually no knowledge of the area at all. Very much a case of its not a problem on my doorstep! This type management does not instil a fraction of a % of faith in the planers and is about as much use as "second had toilet paper".

With this little inclination to sort things out logically and clearly appeasing the developers, as Scrutton does in RDC (26 High Road was a typical case). This development is going to be a disaster for many in the area, particularly anyone living on Main Roads junction etc as we do.

2. Housing Planning for example High Road, Hockley, you have repeatedly allowed developments to the South side - 2 for one etc enlarged drives - 100's of square meters, on very recent one by the water tower, to discharge all surface water from the bland landscaping out the High Road. In total contravention of the building regulation, for many years causing the inadequate surface drain to flood over. Tony Ciaburro of ECC Highways and Scrutton of RDC have been fully aware of this negligence for years and do nothing about it and let it be added to, yet you say about green development and saving water, yet you do nothing. Hundreds of thousands of gallons could be diverted to ground water.

2.1 You also allow development where surface water is put into the foul sewers overloading the system further and causing problems at the sewage works.

2.2 Regarding green matters a typical situation was the development at 26 High Road. RDC approved full development 2 x 5 bed houses and subsequently a 4 bed and extended bungalow on the site of one bungalow. On 3 sheets of A3 of the application said quote "no tree cutting or removal", Scrutton went along 100% with the developers lie and every tree on the site was immediately bulldozed and you did nothing!

You initially approved 2, 5 bed houses on the whole site and could not even get the report to the voting councillors right regarding our house details, it had our wall adjacent to the building and the plans of our house were wrong, Scrutton did not care you subsequently bent over backward for the builders to squeeze a four bed bungalow on the site, even against some 40 objections. From many people in the area it was evident you bent over backward to accommodate the builders 100%.

3. From this situation and knowing personally of a few others, this is going to be a total disaster for the area, enough is enough and we have it. All the utility services in the area and infrastructure are at breaking point and if not sorted out properly first you will undoubtedly be 100% responsible for some serious problems.

4. Also in the Regulation 26 Draft I see no mention of a reduction in Council tax for increased pollution, inconvenience etc. You will be gaining at least another £5,000000 in council tax, and many places are likely to be over band 'D' apart from waste collections there will be little council cost, building control, developers pay the fee, no liabilities for the roads etc so what is going to happen? The pavements in the High Road have never been swept in 30 years, once every couple of years there's some litter picking, drain cleaning by ECC is only on complaint.

We await your reply regarding all the foregoing and how you plan to handle it.

You have literally doubled the council tax bill in 7 years, we have not seen one minute improvement in anything, if I had asked for 100% wage rise, I would soon be told where to go!

Hawkwell is a small rural village which could not easily support a largish settlement of houses. It has very little industry and most new residents would need to commute to London to work, not a desirable option, especially as the trains are already overcrowded at peak times. Hawkwell also has a poor bus service. The village currently has a pleasant environment despite its lack of public spaces and amenities. We do not see how more industry could be provided without losing more of our valuable open spaces. If housing estates are built, even more land will go and this would be environmentally damaging to our wild life, already endangered.

We are disappointed we did not have the opportunity to attend the meeting concerning the Core Strategy which was held at the village hall on 31 May. We understand this was poorly attended due to the poor advertising of this important event. please ensure we are placed on your mailing list so that we can attend the next meeting scheduled for this autumn.

We believe that we have enough housing in the area and more housing will cause the following problems.

More traffic the roads are currently too busy. Doctors/dentist will not be able to cope. It is already a problem getting a dentist. How safe is it to cycle on the roads, it is not! Where are the cycle paths?

Our new Prime Minister Mr Gordon Brown needs to review this policy as there is plenty of room in the North of England. The South is overcrowded.

Please rethink this whole policy. Our local MP's need to fight against this policy.

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.

Please find attached our representation in respect of the Core Strategy Preferred Options (Regulation 26) Draft, which have been submitted on behalf of our client (Aber Ltd).

The majority of the site indicated on Plan 1 is in the ownership of Aber Ltd, with the remainder owned by A W Squier Ltd; it is the intention that this site is brought forward as one. In addition, the land immediately to the east of the site is also in the ownership of A W Squier Ltd, which could be used to provide additional landscaping to the site.

4.2 The Green Belt & Strategic Buffers between Settlements

The policies of the East of England Spatial Strategy advise that there is not a requirement to undertake a strategic review of the Green Belt Boundary within Rochford at this point in time.

PPG2 (Green Belts), states that Green Belts should be designed to ensure that they will endure and should not include land which it is not necessary to keep open, and the boundaries should not be drawn excessively tight around the existing built-up areas, as it may not be possible to maintain a degree of permanence that Green Belts should have.

It is not considered that all the residential and employment development required over the plan period could reasonably take place on brownfield sites within the urban area, therefore, it will be necessary that there is some release of Greenfield land, which would be within the existing Green Belt. Sites located on the end of urban areas and would not be contrary to the objectives of including land in the Green Belt, eg result in urban sprawl or the coalescence of adjoining settlements should be considered to be sustainable locations.

With regards to the Council's preferred option we would agree that the strategic buffers should be identified on the Proposals Map and Allocations DPD. In terms of the list of strategic buffers, we require confirmation that the buffer between Rochford/Ashingdon and Hawkwell/Hockley, this does not relate to the area of land between Rochford and Ashingdon, as these settlements are already connected by existing development along Ashingdon Road.

4.3 Protection and Enhancement of the Upper Roach Valley

It is important that future development is directed away from the sites of special landscaped areas, ancient woodland and Country Parks, which should be protected, as together with their environmental interest they offer a 'green lung', offering opportunities for countryside recreation to the benefit of local residents.

We would agree with the Council's preferred option to protect and enhance the Upper Roach Valley, as a location suitable of providing informal recreational opportunities.

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

As the Special Landscape Areas (SLA) historic landscapes and habitats are important natural assets and provide valuable habitats to the District, their conservation is important to the District, and development should not be permitted in these areas, as this would have a detrimental effect on the areas natural heritage.

We would agree with the Council's preferred option which seeks to protect and enhance the Districts special landscapes and habitats, by seeking to develop policies to ensure the protection of these areas and only permitting development which is considered appropriate to these locations.

4.5 Housing Numbers & Phasing

In order to ensure that sufficient housing is provided in the District, the East of England Plan advises that 4,600 new dwelling units are required over the period 2001-2021; 901 dwellings were completed between the period of April 2001 and March 2006, which has left a residual of 3,699 units. These housing figures should be seen as minimum targets, rather than ceilings that should not be exceeded.

Whilst, it is noted that site specific details will be included in the Allocations DPD, it is important that the right approach is adopted by the Council to ensure that these dwellings are provided in the most sustainable manner.

In accordance with Government advice contained within PPS3 and the East of England Plan, the priority is to ensure that brownfield sites in urban areas are developed in the first instance and then sites that would result in a sustainable form of development.

The Council has made reference to the significant role of the use of previously developed land and these sites will generally be bigger sites within the urban areas. Our concern is that large urban brownfield sites may be more difficult to develop and delivery within the relevant timescales; as these sites could be in multiple ownerships and have a number of constraints that need to be resolved prior to the site being developed. These issues can have adverse affect on the deliverability of the site, and in turn a detrimental impact on the supply of new housing.

The Council has indicated that is wishes to restrict Green Belt development, however, it is not realistic to expect that all 3,699 additional dwellings can be accommodated on previously developed sites in the urban areas and given the fact that the Green Belt is currently drawn tightly around the existing settlements, means it is likely that there will be a need for the localised release of site(s) from the Green Belt.

PPS3 (Housing) advises that priority is given to developments on previously developed land, particularly where vacant and derelict; however, it does go on to state that at the regional level, broad strategic locations should be identified for new housing developments, these should ensure that the needs and demands for housing can be addressed in a way that reflects sustainable development principles. In selecting suitable locations for new housing it is necessary to consider the contribution to be made to cutting carbon emissions by focusing new development in locations with good public transport accessibility and/or by means other than the private car, and to maintain sustainable, mixed and inclusive communities.

Sites adjacent to the urban areas are considered to represent a sustainable form of development, particularly where they have access to local shops, services, community facilities, green and amenity space and public transport and would be in accordance with the provisions of PPS3 and Policy SS7 of the East England Plan.

As stated previously in order to provide sufficient sustainable sites to meet the needs and demands for new housing around Rochford, there will be a need for the release of selective site(s) from the Green Belt. Such sites are suitable for release from the Green Belt where they do not have a significant affect on the Green Belt or the reasons for including the land on the Green Belt.

The provision of the required number of additional dwellings to meet the Regional Spatial Strategy housing requirement is only half the picture, as it is also as important that they are provided throughout the plan period. In order to achieve an acceptable delivery of dwellings, it is necessary to ensure that there is a constant supply of housing land, as such we would recommend the following approach:
* Short term (0-5 yrs) - existing permissions and smaller brownfield sites
* Medium term (5-10yrs) - non-strategic Greenfield sites
* Long term (10-15yrs) - strategic sites (including large/complex brownfield sites)

In terms of the Council's preferred option we would agree that it is important that sufficient land is allocated to accommodate the housing figure cascading down from the East of England Plan. Although there is a priority to reuse existing brownfield sites in urban areas efficiently, due to the number of dwellings required over the plan period it will also be necessary to allocate suitable site(s) from the Green Belt on the edge of existing settlements.

4.6 General Development Locations

In order meet the objectives of sustainable development and reduce the reliance on private cars, it is important that where it is necessary to allocate new housing sites these are located adjacent to existing settlements (to offer a wide as choice of shops and service), and public transport. However, any new housing site should be located away from areas that are subject to specific landscape/habitat/biodiversity designations or areas that are subject to unacceptable levels of flooding.

PPS7 (Sustainable Development in Rural Areas), one of its main objectives is to promote more sustainable patterns of development and focus most development in, or next to, existing towns and villages, and where it is required to use Greenfield land, ensure that it is not used wastefully. Furthermore, to promote more sustainable patterns of development the focus of most additional housing in rural areas should be on existing town.

Policy SS4 of the East of England Plan advises that outside the Regions Key Centre, it would seek that other towns have the potential to increase their economic and social sustainability by ensuring appropriate amounts of new housing and local facilities and improving the town's access to public transport.

Hawkwell/Hockley, Rayleigh, Rochford/Ashingdon are the largest settlements within the District, and have the most extensive range of goods and services, as well as access to public transport. In order to offer both the most sustainable option and ensure that future residents have the greatest access to shops and services the majority of new housing sites should be focused around these three settlements.

With specific regard to Ashingdon/Rochford, this settlement is considered to capable of accommodating significant residential growth and expansion as it benefits from:

* Good transportation:
* Rail links - London to Southend line; and
* Road connections - access to the highway network;

* Good level of community facilities (including educational establishments);

* Existing local services will be strengthened by the expansion of the settlement; and

* Access to countryside and informal recreational opportunities

The Core Strategy seeks to set out both the number of additional dwelling units that need to be provided and develop a locational strategy for how these additional units can be distributed throughout the District.

In order to demonstrate that this is the right approach to find the necessary site(s) for the required housing number, it is important to identify suitable locations where these units can be accommodated. To this end we would propose a site to the northeast of Rochford, located to the east of Ashingdon Road, between Rochford and Ashingdon - see Plan 1.

This site would allow for a medium sized urban extension, providing for approximately 500 homes, together with a neighbourhood centre, community facilities, and associated open and amenity space. The particular benefits of this site include:

* Located on the edge of the existing settlement(s) and has good access to public transport compared to the rest of the District; the site is approximately a 15 minutes walk to the train station, and 3 no. bus services (routes 7, 8 & 20X) travel along Ashingdon Road;
* The site is located well in terms of accessing Rochford town centre, which can be reached by public transport, cycle and foot;
* Due to its proximity to Ashingdon Road there is an ability to get access off the main highway relatively easily. In addition, there is also the option to get secondary accesses in from the area to the south, off Rochford Gardens Way;
* The site is surrounded on three sides by built form, and as such the site would be a classic 'rounding off', and would not result in an intrusion into the countryside, and have the minimum impact on the Green Belt;
* There would be no loss of specific landscape/habitat/biodiversity designations;
* The land is not within a functional flood plain and is not liable to flooding;
* The site has the ability to link-up existing areas of open space, and create 'green links', with access to the wider countryside beyond, taking into account the needs of children;
* It is a regular shaped site, which is also relatively flat, this would enable a sufficiently diverse development to ensure that the site is used efficiently but with a landscape setting, notably along the eastern boundary, which would form a landscape buffer/green link;
* The site is of sufficient scale to ensure a wide mix of housing in terms of tenure, type and price to cater for a wide range of needs and demands, including households with children, single people and elderly and ensure that it would result in a balanced community;
* The scale of the site is of sufficient to pay for improvements to infrastructure costs, and would allow it to be undertaken as a viable phased development;
* The site is in two ownerships; there an understanding between both parties to bring this site forward, this will ensure that it is available and deliverable; and
* The relationship of this site would mean that not only would it result in a sustainable development, within easy walking distance of schools, shops and open space but will also marry in well with existing settlement.

We would comment that historically this site was seen as a natural expansion to the settlement of Rochford, however, the outbreak of World War II prevented the development of this site at this time.

The additional units proposed would bring more households to the area and in turn spending power, which would bolster the local parade of shops on Ashingdon Road.

Furthermore, the development of this site would be compatible with the Districts evolving employment strategy for the area, as it would not result in the loss of an existing employment site and would permit more residents to work in the District as opposed to commuting to out to other places of work.

We are in agreement that the vast majority of new housing should be split between the three main settlements (with an approximate number of dwellings allocated per settlement), and that this should be achieved by a smaller number of larger site(s), which should include the area to the northeast of Rochford. However, the timescale and phasing of these housings site(s) will be subject to a more detailed policy.

4.7 Affordable Housing

In accordance with the provisions of PPS3 (Housing), local planning authorities are required to include an element of affordable housing on all sites that would generate over 15, The Regional Spatial Strategy advises that the aspiration regional target for affordable housing should be 35% of all new housing.

Taken into consideration the character and make up of the residential areas the Council has indicated that, the threshold should be set at development over 25 units and at a rate of 30%. It is noted that the Allocations DPD will provide a minimum figure for the number of affordable units to be completed on each of the specified sites.

In order to ensure mixed communities we would agree with the Council's preferred option that of all new housing, 30% of the units should be affordable on all developments of 25 units or more. Whilst we agree that in order to create inclusive communities the affordable housing should be spread throughout the development, this should be done in such a manner to take into consideration the future management and maintenance of these units.

4.8 Employment

The Draft East of England RSS advises that over the period 2001 to 2021, 3000 new jobs should be provided within the District.

It is considered that two locations where the majority of new jobs can be generated include London Southend Airport, and Rochford Business Park, which between them will create in the order of 2000 jobs, with the remainder of the jobs created throughout the rest of the District.

Proposals for major new residential developments will include a neighbourhood centre and community facilities, which will be generators of new jobs in their own right. In addition, the occupiers of the new residential will also be future employees of the existing and proposed employment areas.

We would agree with the Council's preferred option, with regard to the provision of new jobs within the District, and the preparation of a Joint Area Action Plan to cover employment uses within west Rochford.

4.9 Good Design & Design Statements

In order to promote sustainable development, proposed developments should include good designs that in keeping with scale and character of their surroundings, and sustainable development principles.

In order to ensure that major sites are developed appropriately and to involve stakeholders in the development of the proposals, there is a need for Design Briefs to be prepared for such sites.

We are in agreement with the council's preferred option to require that planning applications are accompanied by design statements. These should ensure that there is good design, which is fundamental to the development of high quality housing and contributes to the creation of sustainable, mixed communities.

4.10 Character of Place & Historic Environment

As stated in PPS1 the appearance of proposed development and its relationship to its surroundings is a material consideration in the consideration of development proposals. As such the relationship with the local setting is more important that 'in house building style'.

In order to ensure that new development takes into account the District's identity we agree with the Council's preferred option.

4.11 Landscaping

In order to ensure that the landscape quality of the District is both maintained and enhanced, developments must contain well considered and high quality landscape content. This is important when assimilating a new development into its surrounding, particularly when located on the urban fringe.

With regard to the proposed housing location to the northeast of Rochford; three sides would be bound by built-form, however, the fourth side would adjoin open countryside. In order to ensure that this site would have the right appearance it is important that this boundary is made up of a sufficient landscaping belt (including trees). This will not only form a substantial landscape buffer (assist in softening the transition between the urban area and rural landscape), but would also form part of the green link, linking existing urban areas.

On major sites as the relationship of the site with its surroundings both urban and rural is important, we agree that in the consideration of such proposals sufficient information should be submitted in order that the landscaping can be properly assessed.

4.11 Energy & Water Conservation & Renewable Energy

In order to address the issue of climate change and conserve natural resources, it is important to ensure that future developments are designed with this in mind, as this will contribute to a more sustainable form of development.

With major developments the preparation of development briefs should include the requirement to address sustainable layouts and construction, together with the requirement for renewable energy, which dependent on the location should include amongst other things, wind energy, solar power and ground heat. In addition, to the energy produced by these means it would also be important to consider any possible adverse effects they could have on local and visual amenity.

We agree with the Council's preferred option that seeks to locate development in sustainable locations and reduce the need to travel by private vehicles. In addition, new developments should be designed so that they have an energy efficient layout and construction, seek to conserve water and energy and generate energy from renewable sources.

4.12 Compulsory Purchase & Planning Obligations

Planning obligations will be used to deliver compensatory or mitigatory measures in order to permit development or to reduce the impact of development to an acceptable level.

We are in agreement with the production of a strategic policy detailing the working of planning obligations in the district.

As a tennant of 55 years I have seen the King Edmund School expand to its present size, without any thought about neighbours and the narrow roads which serve us. I fully agree that a new direct access should be put in while the ground is still available, if you miss this opportunity you will have gridlock in a very short time.

The council may also consider a 10mph speed limit on the 3 school approach roads.

If there is to be an increase of housing in this area then the infrastructure also needs upgrading. This is not only roads, water, electricity etc but also the social side plus doctors, dentists, etc. During the 'rush hours' ie commuters and schools Hockley and Hawkwell often come to a very, very slow crawl at the spa junction. If the Government school policy means that more out of area children have to travel into the area plus extra families this will mean more grid lock on the roads, more strain on local services.

A sudden influx of people would need to be very carefully managed.

Our 'green' areas are of great importance and will become more so as time and climate changes will show. This is such a historical wooded area it would be a shame if this generation is the one to destroy it - or at least start the destruction.

Representation forms

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.

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

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.

Rochford District Core Strategy Preferred Options Draft - Representations on behalf of Cherry Orchard Homes and Villages PLC

I refer to the above consultation document and set out below our comments on behalf of Cherry Orchard Homes and Villages PLC:

Spatial Vision

* Para 2.6 - we support the stated objective of providing a mix of housing, but we consider that specific mention should be given to the need for specialist housing to meet the various needs of different sectors of the community. We suggest the opening sentence should read "Residents will see new development schemes incorporating a mix of housing to meet the needs of all sectors of the community and required local facilities ..."
* Paras 2.23 and 2.24 - we support these paragraphs for the reasons stated above. Providing for the housing needs of the elderly and other groups is not something that should only happen in 15 years time, however, hence our suggestion that paragraph 2.6 be altered as suggested above.

Strategic Buffers Between Settlements

* We support the concept and broad extent of the strategic buffers shown on the Key Diagram and listed at Section 4.2

Upper Roach Valley

* Para 4.3.3-4.3.8 - We welcome the Council's stated intention of producing a Joint Area Action Plan for Southend Airport and the surrounding area, which includes part of the Upper Roach Valley. However, we are concerned that the proposed text makes no reference to the future of the Cherry Orchard Brickworks, which represents a major 'brownfield' site within the Green Belt, and an opportunity for redevelopment in a manner that meets the Council's wider objectives for bringing forward a range of housing opportunities, and helping to deliver enhancement of the Upper Roach Valley.

* We suggest an additional sentence should be added to paragraph 4.3.3, as follows: "The Joint Area Action Plan will also need to consider the future of the Cherry Orchard Brickworks, which forms a large area of previously developed land within the AAP area." We also suggest an additional bullet point to the text box at paragraph 4.3.8, to state:

§ "The Council will bring forward proposals for the redevelopment of the Cherry Orchard brickworks site as part of the comprehensive proposals for the Area Action Plan"

Housing Numbers and Phasing

* Para 4.5.9 - This paragraph begins by stating the Council's objection to its East of England housing allocation. The Council's previous objection is a matter of public record, and it is not really necessary to restate this as part of the Core Strategy, which is a forward looking plan for the delivery of the housing requirement. We suggest the first two sentences of paragraph 4.5.9 be deleted.

* Para 4.5.10 - This paragraph refers to the Council's stated intention to release land from the Green Belt on the edge of settlements which does not have a significant impact on the Green Belt. If as stated the intention is to minimise the impact on the Green Belt, then it is primarily the relative Green Belt merits of land that are the most significant factor, not whether the land is on the edge of a settlement (which in itself is something of an imprecise term). We also suggest that as a guiding philosophy for the subsequent selection of development sites at the Site Allocations stage, the twin criteria of "edge of settlement" and "no significant impact on the Green Belt" are somewhat limited (particularly when much of the urban edges of the district are subject to other environmental and policy constraints). We suggest instead that paragraph 4.5.10 be redrafted to set out more fully the considerations that will be applied to the selection of sites beyond the existing urban area, and which inter alia we would suggest would include;

(a) The relative impact of development on the purposes of the Green Belt;
(b) The ability of the site to accommodate development in physical and environmental terms;
(c) The potential for the re-use of previously developed land; and
(d) The relative sustainability of the proposed development, and its ability to contribute towards the spatial vision.

General Development Locations

* Para 4.6.3 - 4.6.23 - Whilst we agree with the general settlement hierarchy identified in paragraphs 4.6.3-4.6.5, we disagree with the crude methodology subsequently established for the distribution of development. Specifically:

(1) We do not see that any justification exists for the expansion of second tier settlements, if land exists at first tier settlements, and which would be more sustainable. The analysis provided by the Council already accepts that the spatial strategy should not be based upon dividing up the growth on the basis of an "equal share", and that the objectives of sustainable development should come first. In each of the second tier settlements there is likely to be some scope for new development by means of infilling and redevelopment within the existing settlement boundaries, but even were that not the case, we cannot see any evidence to support 10% of the district's growth being directed to locations that the Council acknowledges are not particularly sustainable settlements.

(2) The subsequent analysis that divides up the 90% of new homes proposed between the first tier settlements is also unjustifiably crude and unnecessary. There is no need for this Core Strategy to set out at this stage a distribution between the three main settlements, even if that is "indicative" and particularly not where it relies upon a methodology that does not have a sufficiently robust evidence base to support its conclusions. The selection of the sites at the Site Allocations DPD should be based upon a set of relevant criteria, such as we suggest above, and it should be the application of those criteria and the subsequent selection of the most beneficial/sustainable development sites that should dictate the distribution of development between the three main settlements, not the use of such a crude and subjective distribution at the Core Strategy stage.

Meeting Housing Needs

* As noted previously, the vision for the Strategy identifies the desirability of meeting a wide range of housing need. Although section 4.7 deal with affordable housing, sections 4.5 and 4.6 make no mention of the need for a range of housing opportunities to be provided to meet the needs of all sections of the community. When read in conjunction with the Council's statement at paragraph 4.5.9, to the effect that the Council never wanted this level of housing anyway, the whole of this section comes across as being focussed on the easiest way to deliver the requisite number of homes, rather than any recognition of the opportunities that exist from the East of England allocation to provide positively for a range of new housing to meet the needs of current and future generations. Providing the East of England housing requirement should not be a simple exercise of mathematics, but should be about genuinely striving to achieve a better range and choice of housing to benefit the community. We suggest an additional section on Meeting Housing Needs should be inserted, to refer to the above objectives and to link back to the Strategic Vision, perhaps incorporating the issue of Affordable Housing under the same general heading.

Health Impact Assessment

* Para 4.9.9 - this paragraph refers to Health Impact Assessments with major applications, but it is not clear from the supporting text what this refers to or why such assessments are justified.

Energy Conservation

* We generally support the intentions of this section, but query the suggested inclusion at 4.2.11 of a policy requiring all new development to be carbon neutral - it is not clear from the draft Plan what that actually means, what it involves, what type of development it would refer to, and whether it is actually deliverable in practice.

Compulsory Purchase

* We note the Council's proposal to use compulsory purchase powers if need be to secure its objectives (including in relation to the expansion of the Cherry Orchard Jubilee Country Park). Any individual CPO would obviously need to be justified, having regard to the individual circumstances of the case, and we question the need for a specific policy or statement in the Core Strategy regarding possible locations for the use of CPO powers. Although paragraph 4.13.8 attempts to explain why the first option of "no CPO policy" has been rejected, the explanation offered does not actually justify why a Core Strategy policy is required, in our view.

Cherry Orchard Brickworks Site

* As set out in our original submissions to the Issues and Options draft, we enclose a brochure providing a summary of our proposals for a Retirement Village at Cherry Orchard. This development would assist in meeting the housing needs of the district on a large 'brownfield' site, in accordance with the objectives of the strategy, and with particular regard to the growing requirement for specialist accommodation for the elderly.
We trust the above comments will be taken into account in advance of the preparation of the Submission Draft DPD.

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.

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.

Plots 1,2&3 New Hall Estate,
Trinity Wood Road & Greensward Lane.
Hockley
Essex.

In view of the proposed development of land in Hockley with planning for four hundred houses I would like to put forward the position of the above plot of land on the corner of Greensward Lane and Trinity Wood Road which is surrounded by housing.

On the opposite corner to the plot on Trinity Wood Road, a metalled road, is a very large bungalow with a swimming pool Behind this is a large house with swimming pool Further along Trinity Wood Road are large executive type houses. .

Right behind the plot is a chalet type house.

Next to the plot on the West side another house with swimming pool and beyond this house more large houses.

On the North side of Greensward lane there is ribbon development towards Hockley.Town Center which is about a kilometre away. Greensward Primary School, shops and the railway station are within walking distance. an asset in these days of fuel economy.
If public transport is needed there is a bus stop in the immediate vicinity.

With land being made available for the large number of affordable houses there will be some need for infilling for upgraded development and this plot is in an excellent position for a family house with a large garden with trees fitting to the area.

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.

I am writing in support of King Edmunds School in their attempt to get a new access for the bus service to the school.

The access in Oxford Road, Spencer Gardens and Boswell Avenue is an accident waiting to happen. The entrance in Oxford Road is far too narrow and more children are using this entrance and the movement of buses, it is dangerous. It is also I understand having a damageing effect on the sewage pipe to the school.

If an access was made available in Brays Lane this would be outside the residential area therefore safer for both children and residents.

Having recently opposed the proposed parking restrictions in Spencer Gardens we were please to learn that The King Edmund School remains intent in its endeavours to ...

Obtain a new direct access to the school site so that they can separate pedestrians and vehicular traffic to the school, thus removing the need for seven double decker buses to drive through the residential streets of Boswell Avenue, Spencer Gardens and Oxford Road.

Having lived at the above address for more than twenty years we have experienced a steady growth in both the size and facilities offered at The King Edmund School but unfortunately additional feeder roads as necessary for such a large premises have never been built.

As you can imagine Spencer Gardens and the surrounding roads were never designed to accommodate the extra traffic that comes with such growth and residents have had to tolerate an increasing amount of staff, pupils, school buses, service vehicles, noise and disruption over the years.

With this in mind we would welcome your help with regard to the possibility of building a direct access road as necessary to serve The King Edmund School.

I believe there may be plans for a new entrance to the school for transport via Brays Lane for King Edmund. Having been an Oxford Road resident for 35 years I believe this will relieve the heavy traffic also maybe the students cars/m/cycles that race up and down the road. All this can cause danger and a hazard to children and adults who are pedestrians. Also not to mention the parking of vehicles where buses in particular are unable to pass causing blocking of the road. Therefore I fully support there proposed plans.

I forgot to mention the noise and exhaust pollution between 7.45-8.15am and 12.30-2.30pm, a reduction in this would be very welcome for residents of the top end of the road.

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