4.12 Energy & Water Conservation & Renewable Energy

How will this policy affect the appearance of the conservation area.

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

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

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

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

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

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

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

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

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

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

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

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

2.14 Why not include Rayleigh.

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

2.21-22 Not relevant to older people.

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

2.24 Surely council housing is the answer.

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

Section 3 this is for the most part theory.

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

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

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

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

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

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

Essex Wildlife Trust supports initiatives to achieve reductions in energy and water consumption. Regarding renewable energy we are generally supportive, but the siting of wind turbines must be carefully considered on a case-by-case basis with respect to potential impacts on wildlife, particularly birds and bats.

The RSPB is supportive of renewable energy projects, providing that adverse impacts upon wildlife are avoided by appropriate siting and design.

Water resources are limited accross the south east of England and as such it is vital that technologies to increase the efficiency of water use are installed. We would recommend the Council include a specific policy to address this. minimum.

I write on behalf of my client Fairview New Homes Ltd.

Fairview New Homes Limited (FNH) is a leading house builder that specialises in the provision of new housing on previously developed land to provide accommodation at the more affordable end of the market. They are therefore very familiar with the issues arising out of the redevelopment of previously developed land and the costs that can often be involved. They are also a major provider of affordable housing and therefore it is hoped that their views will be appropriately taken on board during the progression of the LDF.

In relation to the Core Strategy Preferred Options consultation document, please find below on behalf of FNH the following comments:

Housing Numbers & Phasing

FNH considers that the most suitable and sustainable approach for the Council should be both the re-use of previously developed land and at the same time some greenfield land in sustainable locations. Further housing development is necessary, and Green Belt areas on the periphery of an urban area should be considered for housing. FNH would therefore support the option in paragraph 4.5.10 that would allow the release of land on the edge of settlements.

This approach is in accordance with PPG2 on Green Belts that states in paragraph 2.8 "...encroachment of the Green Belt may have to be allowed in order to accommodate future development. If boundaries are drawn too excessively tightly around existing built up areas it may not be possible to maintain the degree of permanence that Green Belts should have." PPG2 therefore suggests taking land out of the Green Belt that borders existing settlements.

FNH would request that the Council establishes a policy framework that would support the release of land Green Belt land on the edge of existing settlements for housing development.

FHN also request that the Council considers non-housing sites for residential development if they come forward for redevelopment.

Some non-housing sites in the Borough may be better used for housing or mixed-use development and so employment and commercial land should be released for housing where it no longer fulfils its commercial use. Paragraphs 38 and 44 of PPS3 require local planning authorities to consider whether sites that are currently allocated for commercial use be more appropriately re-allocated for housing development. Such an approach would support the deliverability of housing in the Borough. Through the re-use of non-housing sites for residential development, the Council would accord with paragraph 40 of PPS3, which states that a key objective for Local Planning Authorities is to continue to make effective use of land that has been previously developed.

FNH consider that the Council should allow for the release of such land only for housing if it is surplus to requirements.

Affordable Housing

Fairview object to the 'possible' option whereby 30% of all new homes in the district be affordable on all sites unless such a site is considered to be a rural exception site.

FNH consider it necessary to state that any affordable housing targets should be indicative and set at a maximum negotiation level at which point the characteristics and constraints of a site can be discussed with the local authority to determine an appropriate level of affordable housing for the development. This will accord with PPS3, which states that housing targets should reflect the economic viability of land for housing within the area taking into account risks to delivery.

FNH request that it is stated within the document and through policy that the level of affordable housing in development schemes is determined with regard to individual site characteristics such as site costs and constraints as well as financial viability.

FNH therefore consider that the affordable housing mix on new development sites should therefore be negotiated on a site by site basis.

Detailed Design Brief

FNH would object to the requirement that a detailed design brief on all major planning applications be submitted in advance of a planning application. This is an unreasonable request, particularly as Design and Access Statements are a compulsory requirement. The submission of a planning brief would constitute additional information that would add extra cost to the development.

Whilst it is right and proper that the level of design quality is considered within policy terms, it should not however stifle housing delivery. Design initiatives sometimes create an additional cost to the developer and together with Section 106 requirements, this could make some schemes unviable and as a consequence important housing sites would not come forward. FNH consider that the design of a particular scheme should be discussed and negotiated with the local planning authority at an early stage on a site-by-site basis.

Code for Sustainable Homes

FNH object to the inclusion of the Central Government's "Code for Sustainable Homes" initiative into the Core Strategy.

Fairview considers that the "Code for Sustainable Homes" (2006) initiative should remain voluntary as stated in the document and that Councils cannot require developers to comply with it. Such initiatives are a cost to the developer and the viability of delivering housing schemes must be a priority.



Lifetime Homes Standard

FNH consider that requirements relating to lifetime homes standards in new developments should be negotiated on a site by site. Such initiatives should not be enforced through policy as they constitute an additional cost to the developer. The viability of delivering housing schemes must be a priority.

Health Impact Assessment

FNH consider that requirements relating to the submission of a Health Impact Assessments with planning applications for new developments should be negotiated on a site by site. Such initiatives should not be enforced through policy as they constitute an additional cost to the developer. The viability of delivering housing schemes must be a priority.

Carbon Neutral Developments

FNH would object if a particular provision is stipulated in the Core Strategy for residential developments to be carbon neutral.

Whilst recognising that the construction industry need to become more proactive in promoting and incorporating the use of environmentally friendly technology in the built environment, whereby FNH has gone as far as to introduce a wide range of renewable energy measures in its recent developments. The use of a "blanket" policy to provide renewable technology should not stifle regeneration and development. Such rigid requirements may make some schemes unviable and as a consequence important housing sites may not come forward to be developed. Moreover, where difficult sites are being regenerated and the costs are significant, other issues may be more important to reduce, for example contamination and affordable housing. The viability of delivering schemes must be a priority.

FNH therefore require renewable energy generation to be negotiated on a site by site basis, taking into consideration the characteristics and viability of the site.

Fairview object to the 'probable' option whereby all new housing development to include renewable energy provision (page 38). Whilst it is right and proper that energy and sustainable issues are considered, they should not stifle regeneration and development. Such initiatives are a cost to the developer and the viability of delivering housing schemes must be a priority. FNH are of the view that this should be assessed on a site-by-site basis and should not be applied to all residential developments. FNH therefore object to such requirements unless the policy makes it clear that viability will be an issue to be considered.

Water and Energy Conservation

FNH consider that initiatives relating to water and energy conservation in new developments should be negotiated on a site by site. Such initiatives should not be enforced through policy as they constitute an additional cost to the developer. The viability of delivering housing schemes must be a priority.

I trust that Fairview's comments on the Core Strategy Preferred Options shall be considered, however should you require clarification on any matters raised above, please do not hesitate to contact me.

What is the point of having the expense of County Councils and Town Councils etc if Government Policy is going to be forced upon us anyway? What about infrastructure and the extra pressure on this that these extra houses will cause, especially on roads, sewers, health care, schools etc. Loss of Green Belt is unacceptable. There should instead be tax incentives (as this is driven by central government, tax incentives should come from central government also) to encourage the full use of all brown sites as a top priority before any other land is used.

All new houses should have high standards of insulation and energy saving devices now before planning permission is granted.

Any new land used must be more fairly spread over the whole of the Rochford District - Rayleigh is already to densely populated!

What is the definition of affordable housing? (Affordable to whom? Prices and specification of these houses must be clearly defined).

In general, the pubilc needs more detail to comment properly on this very important matter. Questionnair should have been more widely distributed - supermarkets, Echo and free local papers, all newsagents etc etc.

I have lived in Rayleigh for 28 years and am fed up with constant in fill and other building which is not supported by additional facilities - local shops rather than out of town stores and no thought resulting in progress to the increased traffic.

We lived in Hullbridge before moving here and each 'traffic scheme' has simply moved the congestion around so that each road has had a turn! Crown Hill being favoured at the moment.

Also no obvious 'green' housing nearly 40 years since 70's oil crisis when we were urged to save energy what happened?

1.1 To give a more informed idea of the size of the District, we suggest that the length of 26.5 miles east - west and that it covers 42,000 acres is inserted here.

1.4 As over 2/3rds of the working population work outside the District, it would be helpful to know what contribution the RDC makes to other LPA's infrastructure costs.

1.9 We agree. However, we were led to believe that the Ashingdon Road, Brays Lane to Wallasea Island road was a Heavy Lorry Route.

2.11 It is often claimed that RDC is not the Highway Authority. We welcome any encouragement to Essex CC and Southend BC to tackle the problems of traffic congestion as an urgent and ongoing process. Even if residents are offered public transport alternatives, the majority of traffic is "white van" type service vehicles and commercial users. This will not decrease and is not compatible with switching to public transport.

2.13 Visions. Whilst these time related visions may be useful progress markers, in respect of 2.25 planning needs to begin soon to achieve this road improvement, and should be brought forward to relieve existing pressures on Ashingdon Road and Bradley Way. This also would cover 4.6.20.

4.6.10 We agree with the Council's Preferred Option in respect of larger sites being able to deliver greater infrastructure improvements.

As regards Housing Allocations by area, we neither agree nor disagree without studying site availability across the District.

4.7.10 We cannot agree that per se affordable houses in rural areas are always more sustainable than non-affordable homes. The rural areas are scattered with "family homes", which contribute to the general wealth of the District. These home owners may provide many of the business and employment opportunities in the District and neighbouring LPA areas.

We note that there is no consideration for the conversion of redundant farm buildings in the Core Strategy to non-agricultural uses in line with PPG7.

4.8.1 Employment. The Core Strategy appears to concentrate on the creation of new jobs, at the expense of retaining existing ones and encouraging company growth particularly for retail businesses in town centres. Too often we see companies achieve a certain level of activity and leave the District due to poor communications and road links. As the Chamber stated as its first comment, the District is 26 miles long. Although Rayleigh might be easily accessible, the eastern end of the District is certainly not, and depends on Southend BC for its road facilities.

4.8.6 Whilst the Core Strategy gives indications of where housing allocations might broadly be located, there appears to be no guidance on new industrial sites, if the concept of building on "tired" estates is promoted. Owing to the fragmented nature of tenancies and ownership of industrial areas, the issue of site deliverability at the next Site Allocation stage could be doubtful.

4.12. We would expect the RDC to promote timber framed houses to meet HMG guidelines for sustainable house construction.

4.13.7. Agree but suggest RDC uses best practice comparisons from other LPAs, rather than spending time "re-inventing the wheel".

4.14.3. Hotels in Town Centres. This policy is too restrictive and does not appreciate the contribution to the District that rural - located hotels can make to the District's tourism offer. The District is the Thames Gateway South Essex's centre for tourism, yet has currently no hotels to attract weekend visitors or those wanting to stay for longer periods. These hotels are commonly situated around the country, and there seems no reason why Rochford should be the exception.

1.1 To give a more informed idea of the size of the District, we suggest that the length of 26.5 miles east - west and that it covers 42,000 acres is inserted here.

1.4 As over 2/3rds of the working population work outside the District, it would be helpful to know what contribution the RDC makes to other LPA's infrastructure costs.

1.9 We agree. However, we were led to believe that the Ashingdon Road, Brays Lane to Wallasea Island road was a Heavy Lorry Route.

2.11 It is often claimed that RDC is not the Highway Authority. We welcome any encouragement to Essex CC and Southend BC to tackle the problems of traffic congestion as an urgent and ongoing process. Even if residents are offered public transport alternatives, the majority of traffic is "white van" type service vehicles and commercial users. This will not decrease and is not compatible with switching to public transport.

2.13 Visions. Whilst these time related visions may be useful progress markers, in respect of 2.25 planning needs to begin soon to achieve this road improvement, and should be brought forward to relieve existing pressures on Ashingdon Road and Bradley Way. This also would cover 4.6.20.

4.6.10 We agree with the Council's Preferred Option in respect of larger sites being able to deliver greater infrastructure improvements.

As regards Housing Allocations by area, we neither agree nor disagree without studying site availability across the District.

4.7.10 We cannot agree that per se affordable houses in rural areas are always more sustainable than non-affordable homes. The rural areas are scattered with "family homes", which contribute to the general wealth of the District. These home owners may provide many of the business and employment opportunities in the District and neighbouring LPA areas.

We note that there is no consideration for the conversion of redundant farm buildings in the Core Strategy to non-agricultural uses in line with PPG7.

4.8.1 Employment. The Core Strategy appears to concentrate on the creation of new jobs, at the expense of retaining existing ones and encouraging company growth particularly for retail businesses in town centres. Too often we see companies achieve a certain level of activity and leave the District due to poor communications and road links. As the Chamber stated as its first comment, the District is 26 miles long. Although Rayleigh might be easily accessible, the eastern end of the District is certainly not, and depends on Southend BC for its road facilities.

4.8.6 Whilst the Core Strategy gives indications of where housing allocations might broadly be located, there appears to be no guidance on new industrial sites, if the concept of building on "tired" estates is promoted. Owing to the fragmented nature of tenancies and ownership of industrial areas, the issue of site deliverability at the next Site Allocation stage could be doubtful.

4.12. We would expect the RDC to promote timber framed houses to meet HMG guidelines for sustainable house construction.

4.13.7. Agree but suggest RDC uses best practice comparisons from other LPAs, rather than spending time "re-inventing the wheel".

4.14.3. Hotels in Town Centres. This policy is too restrictive and does not appreciate the contribution to the District that rural - located hotels can make to the District's tourism offer. The District is the Thames Gateway South Essex's centre for tourism, yet has currently no hotels to attract weekend visitors or those wanting to stay for longer periods. These hotels are commonly situated around the country, and there seems no reason why Rochford should be the exception.

Core Strategy Preferred Options (Regulation 26) Consultation Response

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

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

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

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

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

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.

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.

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.

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.