4.6 General Development Locations

I would like to register my object to the proposed bulding of an additional 1800 more homes in Rayleigh. In recent years Rayleigh has already had a huge increase in new homes as well as flats, and there really is no room for additional homes, especially if they are to be built on the little remaining green belt land that we have.

Reading through Core Strategy Preferred Options Regulation 26 Draft it clearly states that the council is well aware that the road system in and around Rayleigh is not suitable for the current population let alone an increase in the population. With an additional 1800 more homes there will be around an additional 5400 vehicles in the region putting increasing pressure on the current road structure as well increasing the pollution in the area. With the higher rate of traffic also comes the danger problem. There is already a short fall in the number of jobs available to the current population this will only increase and we will have more of the population commuting to work and schools again increasing the traffic flow during both rush hours and school runs.

There are at present only two secondary schools in this region and no further plans or a site to place a new school, therefore the two current schools will either be overcrowded or we will have more children commuting out of the area to schools, again more cars on the road and additional pressure on the public travel system.

It appears that the main planning site for these 1800 homes will be along the A130 a main road leading onto the busy A127 at Rawreth, this is already a busy road only recently improved by the building of the new A130. This is one of the main roads exiting from the Rayleigh. There will be a huge increase in traffic on this road which in turn will cause traffic hold ups on other roads, also with more cars joining this road there is an increased danger to drivers and pedestrians.

Rayleigh does not have adequate facilities for the current population, we have no cinema or swimming pool despite both of these being popular ideas to most of Rayleigh. There are no real facilities for the young and already there are certain parts of Rayleigh which are a problem with young teenagers hanging around drinking at night and being a general nuisance. This problem will only get worse and should the rumoured merger of our Police station take place we will have even less of a Police force to tackle these problems.

Once again I strongly disagree with this proposal especially if more of our green belt land is used.

I am writing to state my objection to the proposal that new housing be built in the fields adjacent to St Clements Health Centre incorporating the mushroom farm and land behind Rectory Road, Hawkwell.

This particular area is a rural part of Hawkwell and Hockley. It is regularly used by horse riders, children and families on bikes, dog walkers and those out for a walk just because it is an enjoyable, peaceful and relaxing thing to do. This small amount of countryside should be protected.

With reference to the above due to unforeseen circumstances we are late in submitting our comments, which we hope you will accept.

The idea of another 1800 homes in Rayleigh, which is already becoming extremely built up, is utterly unacceptable. This committee feel that it will put intolerable pressure on the roads, G.P services and schools. The main roads entering Rayleigh are very congested and at times almost at a stand still.

Building this many homes can only mean one thing and that is the loss of large areas of green belt land, the lungs of our area, and just bury us and future generations under concrete.

We feel that the development should be spread more evenly over the county and indeed the country.

Re: King Edmund School - Direct Access for Vehicular Traffic.

With reference to a letter from Mr G Abel, Headmaster of the King Edmund School, we write in strong support of his endeavours to gain a new direct access to the school.

Having lived at this address for 32 years, we have long suffered from double-decker buses dropping pupils outside our property and in fact have lost count of the number of times this situation has been discussed with the school, always with the same outcome, no solution to this problem.

We have noticed the increase in the number of buses over the years, with its associated problems.

a) Inability to either get on and off of our drive at peak times.

b) Parked cars in Spencer Gardens, parent's cars dropping and collecting pupils, sixth form college students driving to and from the site and of course the buses. Rendering it impossible to navigate the very narrow roads surrounding the school.

c) Congregation of pupils {mainly those dropped off by buses} outside our property, resulting in constant rubbish and due to it being obscured from view of the school a haven for what we call the "smokers club".

d) Risk to pupils, the elderly and young children, attempting to cross the roads at the busiest times.

I am sure we are not alone in that we have had to change our lifestyle when making appointment, arranging deliveries, in fact anything which involves using our drive at peak times. It is plain for all to see this saturation of traffic, will lead to a serious accident one day.

The suggestion of increased housing will exacerbate an already serious situation and cause more misery to the residents. Perhaps when this school was built it was acceptable to place it's entrance in the middle of a residential area, but with the increase of drivers and pupil numbers, please let common sense prevail and at the very least let the buses go into a dedicated entrance.

We eagerly await your response.

We are writing to support The King Edmund School in their application for a new entrance to the school.

We have lived in Oxford Road for 33 years and over the past years the increase in traffic and school buses and become increasingly unpopular with the residents of Oxford Road.

We feel that they are a danger to the elderly and the young. The buses quite often mount the pavements. We are sure this can not be good for the roads or the pavements.

The parents who come and pick their children up are inconsiderate and park across driveways and on the pavements where the older generation try to get by on the mobility scooters and young mums try to get past with their pushchairs.

I really feel that it is time now for a new entrance and give the residents of Oxford Road and Spencer Gardens some peace of mind.

I know I am slightly late in putting in our representation on Local Development Framework Core Strategy (Reg 26), but my husband ha recently been in hospital for a major operation, so my thoughts have been elsewhere.

We have lived in Vaughan Close when King Edmunds land was green belt and when the school was built it had about 500 pupils, so the area has seen many alterations and the road system not built for the traffic that now uses it ie, large lorries for deliveries and building contractors, increased teacher transport with no time for the residnets needs, plus bus transport for Shoebury and Wakering pupils, estimated 1500 pupils now. The close is in need of serious repair, it has been neglected for many years, I omitted to mention parents vehicles which has increased two-fold over the year.

Several years we attended a meeting considering a new road and entrance with houses on field ajoining the school in Brays Lane, which seemed sensible to us, but was thrown out, surely if we need extra housing, which we do it would solve both problems in one go.

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

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

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

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

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

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

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

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

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

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

Policy Content

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

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

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

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

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

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

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

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

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

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

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

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


Future Process

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

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

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

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


2. MORE DETAILED COMMENTS

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

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

Spatial Vision

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

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

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

Green Belt

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

General development locations

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

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

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

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

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

Employment

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

Good design & design statements

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

Character of place & the historic environment

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

Energy & water conservation & renewable energy

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

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

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

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

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

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

Compulsory purchase & planning obligations

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

Policy Content

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

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

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

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

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

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

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

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

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

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

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

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


Future Process

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

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

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

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


2. MORE DETAILED COMMENTS

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

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

Spatial Vision

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

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

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

Green Belt

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

General development locations

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

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

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

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

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

Employment

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

Good design & design statements

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

Character of place & the historic environment

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

Energy & water conservation & renewable energy

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

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

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

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

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

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

Compulsory purchase & planning obligations

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