4.14 Community, Leisure & Tourism Facilities

If substantial areas of new housing are concentrated in some areas, there will also be the need for even more land to be 'set aside' for the provision of schools, churches, leisure/community centres, etc. Provision of small, local shopping areas may also be required to satisfy the requirements of those without access to adequate transport; this would include the elderly, but may also include mothers with small children whose husband/partner has taken the family car to get to work. In June 2007, parents are already struggling to get places for their children in good schools in the Rochford area and this is even more acute in the area of nursery education

Sport England is concerned that this section and policy does not have sufficient clarity or strength to set out the principles for provision in the district.

In particular:
a) the policy does not sufficiently define what is meant by community and leisure facilities - does this include indoor and outdoor sports facilities?
b) the policy does not include a reference to the need to protect and/or enhance existing facilities that make a significant contribution to leisure provision in the district.
c) The policy shoulds set out the evidence base requirements for establishing this policy - is this fully established or is further work necessary?
d) Although the policy refers to leisure facilities which could include facilitirs for sport and recreation, there is no reference to PPG17 in the section outlining relevant national policy (Paras. 4.14.3 - 4.14.6).

The RSPB believe that natural resources can offer big economic opportunties through eco-tourism iniatives.By ensuring the protection of natural habitats whilst supporting projects that enable, where appropriate, additional facilities, access and educational opportunties for visitors, both local wildlife and the economy can benefit.

The Core Strategy (4.14 Community, Leisure and Tourism Facilities)does not address the need for additional sites to be zoned for community use, including places of worship.

Section 1 Spatial Portrait

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

Section 2 Spatial Vision

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

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

Section 3 Relationship of Documents

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

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

Section 4 Core Strategy Issues

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

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

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

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

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

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

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

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

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

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

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

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

Clause 4.5.12. Windfall development should not be ignored.

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

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

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

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

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

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

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

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

Clause 4.6.23 Believe the figures are flawed and unbalanced

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

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

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

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

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

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

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

Section 5 Implementation & Monitoring

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

Thank you for your letter dated 21 May 2007 consulting Natural England on the preferred options report.

This letter is provided as our formal response of Natural England to your request for advice for this plan or programme and is intended to be considered in conjunction with previous English Nature consultation advice provided for the emerging Strategic Environment Assessment.

Natural England notes the significance of the nature conservation assets within Rochford District Council. We believe these assets significantly contribute to the character of the district and provide vital ingredients to the quality of life it offers. Opportunities exist to further enhance these qualities through an appropriate integration of measures towards economic, social and environmental aspirations.

Natural England encourages local planning authorities to include policies for the protection and enhancement of the natural environment and natural resources. We are likely to e supportive of suitably worded policies that seek to conserve environmental assets such as biodiversity, water, energy, air quality and promote effective flood risk management, appropriate landscaping and pollution control.

Consistent with PPS9 and the accompanying ODPM Circular 06/2005 we advocate adopting an informed approach utilising information about biological and geological assets, from sources such as Phase I surveys, Country Wildlife Site inventory's and previous geological surveys (RIGS - regionally important geological sites). In our previous advice about the Strategic Environmental Assessment we have advised that in addition to designated sites, other areas (notably local wildlife sites, local nature reserves, green corridors) can make a significant contribution to the green infrastructure of the district. Accounting for this, and the challenges of enabling progress towards growth targets we refer you to the following points for consideration:

i) Developing within the urban area is likely to involve development on brownfield land, which can be rich in biodiversity interest
ii) Different types of land may have strategic significance for the conservation of biodiversity assets.
iii) In some locations, the green belt can provide a significant buffer (and in some cases supporting habitat) for sites of national and international significance and opportunities may exist through landscape enhancement schemes for these areas to provide a more multifunctional accessible natural greenspace role.
iv) The requirements of the Habitat Regulations should be considered particularly if options for development are within or adjacent to intertidal areas.
v) The plan needs to account for environmental issues that span local authority boundaries. This is significant, noting Southend-on-Sea Borough Council's growth targets.

1. Assessment in accordance with Habitat Regulations

Where a plan may affect a European site, the European Court of Justice ruling (October 2005), has concluded Article 6(3) of the Habitats Directive provides that any plan or project not directly connected with or necessary to the management of a European site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, must be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In practice, the SEA should aim to be sufficiently detailed in its assessment to address the requirements of The Habitats Directive 92/43/EEC of 21 May 1992.

The Assessment will require an initial screening of all policies alone and in combination with other plans and projects. This aims to establish whether any policies should be regarded as likely to cause/have a significant effect on the interest features of the European Sites, either alone or in combination with other plans or projects. Options should then be considered to establish whether amendments to individual policies, suite of policies or supporting text could effectively address concerns to 'not likely significant effect'.

Those policies that are still regarded as likely to have a significant effect will then require an appropriate assessment in accordance with Regulation 48 of the Habitat Regulations. National Government direction encourages local planning authorities to develop local development documents that clearly demonstrate that they avoid an adverse affect on the integrity of the Natura 2000 sites, either alone or in combination with other plans or projects. A summary diagram (Figure 1) of the processes within the assessment is attached for your consideration. Furthermore, consistent with the cross-border working that is necessary in delivering strategic solutions we recommend you gain a brief appreciation of the assessment from the developing Habitat Regulations Assessment for Southend on Sea Borough Council's Core Strategy (see Topic Papers for Examination in Public www.southend.gov.uk).

Our initial assessment indicates that the particular elements of the strategic direction could be likely to have a significant effect, either alone or in combination with other plans or projects and these are listed below:

1) Overall grown targets, alone and in combination with relevant Regional growth area targets, will lead to increased population and subsequent increased recreational pressure on Natura 2000 sites.

ii) The aspirations for significant growth in airport movements at Southend Airport, which may result in increased air quality and/or disturbance impacts on Natura 2000 sites.

iii) Development in, or immediately adjacent to, intertidal or coastal areas that either requires land-take through encroachment or exacerbates the effects of coastal squeeze.

2. Additional Advice

2a) Consistent with the point (ii) raised above, Natural England welcomes the proposed Joint Area Action plans for Southend Airport and Foulness MOD land. We recommended that the latter should include surface access. The Joint Area Action Planning process should provide opportunities for enhanced North-South links including greenways, as envisaged in the Thames Gateway South Essex Greengrid.

2b) Natural England supports the Council's preferred options for the enhancement and protection of the Upper Roach Valley including the Country Park. These are consistent with the objectives of the Thames Gateway South Essex Greengrid and it is recommended that wording to that effect should be included in the document. Natural England would be happy to advise with regard to a possible overall Upper Roach Valley Strategy as a means to delivering it's full potential.

2c) The Plan needs to align with the direction provided by PPS9 to conserve and enhance designated sites and biodiversity assets rather than merely to 'protect'.

2d) Consistent with the advice provided in paragraph 5 above we recommend that the environmental baseline is updated through a County wildlife site review and Phase 1 survey.

2e) Natural England encourages Rochford District Council to align with emerging strategic direction to address flood risk management. This includes principles set out in the Crouch and Roach Estuaries Strategy, the Essex ChaMP, the Great Wakering Flood Risk Management Strategy and the emerging Thames Estuary 2100 project.

2f) We encourage Rochford District Council to include specific measures and policy direction to promote the integration of biodiversity into development. This can be through a package of measures, outlined in the CD-Rom resource 'Integrating Biodiversity into development .....realising the benefits' available from www.essexbiodiversity.org.uk.

2g) Natural England supports the Council's strong promotion of good design with regard to new developments via the Essex Design Guide and Urban Place Supplement. Opportunities should be sought to promote accessible natural greenspace provision that meets local requirements and provides functional links for people and wildlife. Where possible these should also enable contributions to BAP targets. Natural England recommends that the authority should consider the use of policies to promote the delivery and long-term management and maintenance of greenspace and green linkages. These could be financed through planning gain/section 106 and would further encourage innovative and high quality design in new developments and regeneration initiatives.

2h) Rochford District Council's Option regarding leisure and tourism is consistent with the objectives of the Thames Gateway South Essex Greengrid and it is recommended that wording to that effect should be included in the document.

I trust that this is helpful, but please do not hesitate to contact me at the above Colchester address or telephone number should you wish to discuss this matter further. For further advice regarding greenspace/openspace strategy and implementation of the Thames Gateway South Essex Greengrid, please contact my colleague Pat Crosby (E-mail: partricia.Crosby@naturalengland.org.uk).

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.

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

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

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

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

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

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

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

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

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

Core Strategy Issue: Affordable Housing

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

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

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

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

Core Strategy Issue: Landscaping

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

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

Core Strategy Issue: Energy and Water Conservation and Renewable Energy

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

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

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

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

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

Core Strategy Issue: Compulsory Purchase and Planning Obligations

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

Core Strategy Issue: Community, Leisure and Tourism Facilities

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

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

Introduction

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

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

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

Green Belt & Strategic Buffers Between Settlements

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

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

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

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

Housing Numbers and Phasing

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

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

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

General Development Locations

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

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

Employment

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

Community, Leisure & Tourism Facilities

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

Land at Home Farm

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

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

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

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

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

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


Spatial Vision

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


Core Strategy Issues

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

Affordable Housing

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


Employment

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




Good design and Design Statements

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

Community, Leisure & Tourism Facilities

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

On Behalf of The Hockley Parish Council
Cllr R Vingoe.

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.

Please keep the overall character of houses and locations as they have been for many years - remember new design must be in harmony and sympathy as Rayleigh has years of history to upkeep - no other town is quite like it.

Rochford District Core Strategy Preferred Options (Regulation 26) Draft:
Consultation Development Plan Document (DPD)

I refer to your recent statutory consultation on the above Development Plan Document
and subsequent telephone conversation with Bob Preston about Southend's delay in
making formal representations.

Please find attached Southend Borough Council's representations on your Core Strategy
Preferred Options Draft and trust that they will be given due consideration.

For your information, these comments at this time are still subject to approval by
members. I will confirm the Council's agreed position after their Cabinet meeting on 25th
September 2007.

I trust this is in order.

Main Points

1.1 The Rochford District Core Strategy should address:
* The expansion plans for London Southend Airport and related development. There should be a Core Strategy Policy stating clearly that a Joint Airport Area Action Plan (JAAAP) is being developed with Southend on Sea Borough Council. The policy would need to be clear about the potential for change within the area covered by the Area Action Plan. This should include Airport expansion plans, the development potential for additional employment land and the implications in terms of rolling back the green belt boundary in this area. The broad location of the JAAAP should be shown on the Key Diagram;
* transportation and accessibility issues including strategic road and rail links and address associated cross boundary issues such as SERT. For example the core strategy should identify potential locations for a Park and Ride Scheme on the A127 as part of 'SERT' and surface access improvements to London Southend Airport, including the new railway station. These elements should also be shown on the Key Diagram;
* the proposal within the Southend on Sea Core Strategy Core Policy CP7 to support development of a new Country Park facility located between Great Wakering and Shoeburyness and show the broad extent of the proposed Country Park on the Key Diagram.

Specific Comments

1. A Spatial Portrait of the Rochford District

para 1.4 The spatial portrait of Rochford provides an insight to the district and provides a context in which planning policy in the Core Strategy needs to be developed. As such it would be helpful if there was more detailed information about where the district's residents work and their mode of travel as well as commuting patterns into the district if significant. Further description could then follow about the district's role and connectivity with London, Essex Thames Gateway and the rest of the region. This would link with the discussion about transport infrastructure in paragraphs 1.9 to 1.11.

para 1.9 In light of the above comments it would also be helpful to set out, in the paragraphs about transport infrastructure, key linkages with areas outside the district such as London and Thames Gateway South Essex and Chelmsford. Clearly the A127 and A130 and the Southend Liverpool Street railway line are strategic transport linkages to London and the rest of the Gateway. These, together with national and regional cycle routes, should be identified on the Key Diagram.

Paras 1.11
& 1.12 Also significant to transport linkages is London Southend Airport which lies within the district. Whilst it is mentioned here, both its current and future significance, through expansion plans, for both transport (including surface access) employment generation, and the Green Belt is not addressed fully. Clearly the Core Strategy will need to consider these issues and establish a policy context within which the Joint Airport Area Action Plan can be developed. It would be helpful therefore for this section to fully develop the context in which London Southend Airport sits.

2. Spatial Vision for the District

Paras 2.7
& 2.17 The Southend on Sea Core Strategy DPD Policy CP7: 'Sport, Recreation and Open Space' supports the development of a new Country Park facility, as part of the development of a Green Grid of open spaces and associated linkages throughout Essex Thames Gateway. This is nominally located towards the north east of the borough, with potential to cross the border into Rochford district and shown on the Key Diagram. Southend Borough Council considers that such a proposal aligns with Rochford Council's objective of preventing coalescence in the area between Southend/Shoeburyness and Great Wakering and reinforces the visitor recreation and leisure role that Rochford uniquely holds both for its own residents and those of Southend. It would be helpful, therefore, if the spatial vision in either the 5 or 10 year periods reflected the proposal for a Country Park between Southend/Shoeburyness and Great Wakering.

3. The relationship of documents in the Local Development Framework

Para 3.9 In the text box detailing the set of Development Plan Documents there is reference to a 'Joint Area Action Plan covering land to the west of Rochford'. It is unclear whether this refers to the Joint Airport Area Action Plan or not. It would be helpful if this is the case that the word 'Airport' is included within the title of this AAP. If it is not, then clearly the Joint Airport Area Action Plan should be included within this section, particularly as there has been a formal resolution by both Councils. In addition, it is considered essential that the broad locations of the proposed Area Action Plans are shown on the Key Diagram.

4. Core Strategy Issues

Para 4.1 Rochford District contains an Airport and strategic road and rail links with demanding cross boundary issues that need to be addressed. The spatial portrait also highlights issues of congestion and accessibility both in terms of the road infrastructure and the inadequacies of public transport. Southend Borough Council considers it essential that 'transport infrastructure and accessibility' should be a key policy area within the Core Strategy and it should address strategic issues such as support for the Airport expansion and surface access solutions, SERT, public transport improvements and cycling and walking.

It is noted in paragraph 3.10 that the Core Strategy intends to avoid duplication between local and National policies particularly in relation to green belt and development in flood risk areas. However, flood risk and climate change are key challenges for all LPAs particularly in this area and the Core Strategy should specifically refer to how it will address flood risk locally.

There also appears to be a lack of consideration of sports and recreation provision outside the management of protected open spaces which are intrinsically attractive because they are natural habitats.

4.2 The Green Belt & Strategic buffers between settlements

Para 4.2.1 Southend Council agrees that as a matter of principle, Green Belt land should be protected, and where possible brownfield land should be given priority for development. It is also noted that a Strategic Review of the green belt boundary is not considered appropriate at this stage in line with RSS Proposed Changes Policy SS7 and that the preferred option is to continue its restrictive suite of policies for development within the Green Belt.

Para 4.2.7 However, the preferred option indicates that there may be some relaxation for major developed sites, green tourism and renewable energy proposals. Southend Borough Council considers it essential that the Core Strategy specifically addresses the need to review the Green Belt boundary within the proposed boundary of the Joint Airport Area Action Plan. The preparation of this AAP has been agreed by both Councils and work is underway on developing the plan. It would be inconsistent therefore not to address Green Belt boundary review in this area within the Core Strategy both in policy terms and on the Key Diagram.

Para 4.2.4 In addition, Southend Borough Council is unclear as to the need for another tier of protection to land already identified as Green Belt, as implied by the proposed designation of Strategic Buffers, particularly as these areas are subject to a continued application of Green Belt policy. However, should they be areas where particular enhancements or management for recreation were needed then this Council would recommend that the proposed Strategic Buffer between Great Wakering and North Shoebury be proposed as a Country Park to complement Policy CP7 in the Southend on Sea Core Strategy DPD.

4.8 Employment

para 4.8.3 The recognition of the potential of London Southend Airport to be a catalyst for employment generating uses providing jobs for local people is welcomed.

Para 4.8.5 This paragraph indicates that additional jobs growth in the district will be accommodated within, London Southend Airport, Rochford Business Park, and various locations throughout the district. These locations should be shown on the key diagram. In addition
Southend Borough Council consider that the Core Strategy Policy dealing with employment should state clearly that a Joint Airport Area Action Plan is being developed with Southend on Sea Borough Council and both show the broad area that the AAP will cover on the Key Diagram and be clear within the policy about the proposal in terms of the expansion of the Airport, the development potential for additional employment land etc and the implications in terms of rolling back the green belt boundary in this area.

4.14 Community, leisure & tourism facilities

The approach to the provision of community (which should include education, health and social care facilities) and leisure facilities appears to be criteria based approach for dealing with planning applications for such uses in an appropriate manner. Whilst this is necessary, it would also be helpful to have an overview as to the locational requirements of other agencies dealing with health and social care provision.