4.2.7 Green Belt & Strategic Gaps Between Settlements Preferred Option

Whilst I fully support the concept of the buffers, it is difficult to see how Rawreth will be prevented from coalescing with Rayleigh, given the position and limited width of the proposed buffer to the west of Rayleigh, and the fact that much of Rawreth (eg, the old plotland trendyhays estate - Trenders Avenue, etc) lays off of Rawreth Lane, which is not covered by the proposed buffer to protect this part of Rawreth, the edge of the buffer should be extended much nearer to the existing built edge of west Rayleigh. The Green belt land on either side of the A129 will also be excessively vulnerable to development unless the edge of the proposed buffer is extended closer to the existing built edge of Rayleigh. The relaxation of the Green belt for renewable energy proposals and for green tourism is dangerous, unless the council makes clear what unacceptable, (for instance, a waste incinerator for domestic/commercial refuse which produced electricity as a by-product could be classed as "renewable energy", but RDC successfully objected to a proposed incinerator site near Rayleigh a few years ago on the grounds that it was in the Green belt - the last thing we want is for the Green belt to be relaxed, and an incinerator to sneak in by the back door!) Why should green tourism require a relaxation of the green belt anyway? There may be merit in the alternative of relying on schemes to justify their very special circumstances, unless the council can be clear about exactly what development would justify a relaxation. It regretably seems clear some Green belt will be lost to new residential development, but the council should limit this by allocating the minimum possible amount of green belt land for housing.

The buffer to the West of Rayleigh should be wider, so that it comes much closer to the built western edge of the town, thus more effectively preventing coalescence between Rayleigh and Rawreth along Rawreth Lane.

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

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

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

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

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

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

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

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

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

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

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

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

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

I do not agree with using the green belt for anything other than wind farms and only then if they do not have an adverse effect on wildlife in the area.
The granting of planning permission in the green belt for a car park (Southend United)for example, is bad planning and will obviously set a precedent.

Over the last few years a huge amount of housing has already taken place in West Rayleigh, on the edge of and into Rawreth. You have already completely filled this part of Rayleigh and built right up to the open farmed fields in Rawreth Lane, any further building in this area will remove any "strategic" gaps and will turn our village into a town - part of Rayleigh town. This will completely destroy the character of Rawreth.

I believe that putting 1800 houses to the west of Rayleigh will be so intrusive that the policy of stategic gaps is non viable - they will be non existant. further the policy states that one of the gaps will be between Rayleigh and Rawreth but does not mention a gap between Rawreth and Wickford. Wickford has already expanded and virtually joins Basildon so as it is not mentioned is it open for Rawreth to join Wickford making one large housing estate from Rawreth lane to Basildon town centre

I am strongly in favour of the strategic buffers between settlements. However, I was always under the impression that we already had buffers with the current green belt fields around Rayleigh. No more of these field should be given up to development. The strategy plan map does not show clearly exactly where the buffer boundaries will be.

This district has many woodland and park areas many more than most the green belt areas would not need to be taken over completly but houseing is now a issue which needs to be dealt withurgently all over the south east families are larger and need housing if people are to stay in the hometowns the green belt areas which are butting up to say housing already would be the only move forward these would then already have the facilities available and would cause a lot less built up feel.

There should also be a strategic buffer between Rawreth and Wickford.

i support the continuation of existing restrictions on development in the Green Belt. All existing Green Belt designations should be maintained.It is unclear whether what is being proposed is a reduction of existing Green belt boundaries or a general relaxation of policy within it.What is meant by "major developed sites"? Are these existing developments within the GB or new developments?
I find the use of the term "stategic buffers" confusing. How does this relate to green belt objectives set out in PPG2? The Council needs to be very clear about its Green belt objectives when Appeals arise, as they inevitably will.

POSITIVE COMMENT

LOCAL DEVELOPMENT POLICY - LAND at BULL LANE, RAYLEIGH
This representation is with regard to land at Bull Lane which has been put forward for release from Green belt for housing as a suggested and preferred site in answer to the Core Strategy Plan. This is an 11 acre field that is grassed and free of trees and buildings, it has also never had any farmer use for farm grazing or arable use. The land meets the criteria required as follows.

Policies HP8/HP9
As 1800 houses are required in Rayleigh alone; the land North of Bull Lane, Rayleigh which has been offered for building is in an ideal location. The plot of land is some 11 acres in size and will allow for affordable housing for local community needs as well as private residential development. It is very much suitable as it immediately adjoins the existing town in accordance to the criteria defined in Policy HP9. The release of the land would still allow presence of the openness of Green Belt. It would also not encroach on the "Green Buffer'' suggested in the councils preliminary publications.

The land North of Bull Lane is on the edge of town, with good access to:
Shops & Amenities
Local shops - a good range includes Butchers, Greengrocers, Post Office, Newsagents, Café and others, are all in walking distance of 0.4 mile

Town Shopping - Rayleigh Town Centre - itself with its wide range of shops is just 1 mile away.
The Local Park, Library, Community Centre, are also just a mile away.




Schools
Infants and Junior School are serviced by 'The Grove School' is 0.4mile distance from the site.
The Fitzwymark Senior School is local and just 0.5 miles away.

Travel Policy TP1
Roads - Bull Lane has a good road structure for traveling to Rochford - Southend - London- Chelmsford.

Buses - There are a variety of regular buses from Rayleigh which link the county in all directions, see attached routes.
Trains - The good train service carries passengers from Rayleigh to Southend and London directions.

Points raised here are within the East of England Plan, and for these reasons we believe that Bull Lane would be suitable for development.

POLICY TP1 - SUSTAINABLE TRANSPORT .

RAYLEIGH BUS ROUTES
A variety of regular buses from Rayleigh link the county .

NO BUS ROUTES RAYLEIGH PICK UPS
20 Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20C Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20X Southend-eastwood-Ray;leigh-Hullbridge BULL LANE
1 Rayleigh-Thundersley-Leigh-westcliff-Thorpe Bay-Shoebury Rayleigh Station
Rayleigh-Hockley-Ashingdon High Street/Hockley Rd
8 Rayleigh-Rochford-Southend-Thorpe bay-Shoeburyness High Street/Hockley Rd
9 Rayleigh-Eastwood-Southend-Thorpe Bay-Shoeburyness High St,Eastwood Rd
11A Southend-Westcliff-Rayleigh-Chelmsford Eastwood Road/Rayleigh Station

15,15A,15B,15C,16 Southend-Rayleigh-Pitsea-Basildon Eastwood Road/High St
Lower Hockley-Rayleigh-Southend High Street./Rayleigh Station
Southend-Rayleigh-Canvey

Metro 25 Southend,Rayleigh,Wickford,Basildon Rayleigh Station
35/35X Chelmsford-Great Baddow-Rayleigh-Southend Eastwood Rise/Rayleigh Station
Chelmsford-Rayleigh-Southend
200 Bradwell on sea-Maylandsea- Althorne-Sth Woodham-
Rayleigh-Southend Eastwod Rd,High St,Station
222 Southend-Rayleigh-Wickford-Billericay-Brentwood-Warley
825 Basildon-Westcliff High School-St.Thomas More School Eastwood Rise,Rayleigh Station
X30 Southend - Rayleigh- Stanstead Airport Rayleigh Station

Metro 25 BASILDON,BEACHAMPS SCHOOL,Southend Town Centre -Rayleigh Station

TRAINS
Local Railway station - direct to London - Southend
ROAD
It is easy to travel by road to Southend,Chelmsford, London with choices of routes to choose from.

It is considered entirely premature for the Council to suggest that there is no need to undertake a strategic review of the Green Belt. Whilst it is acknowledged that Policy SS7 of the Regional Spatial Strategy and the supporting text require the broad extent of the Green Belt to be maintained, Policy H1 requires, as a minimum, sites for 4,600 houses to come forward in the Rochford District between 2001 and 2021. In its Annual Monitoring Report of December 2006 the Council have suggested that, taking into account dwellings constructed to March 2006, the requirements will be for 3789 units.Para. 4.2.5. of the Core Strategy Preferred Options suggests that previously developed land has an important role to play in fulfilling housing and employment targets. However it also recognises that the scope for the use of such land appears to be diminishing as many major sites have been or are being developed. Para. 4.2.6 suggests that the creation of high quality developments at relatively high density would minimise the loss of Green Belt land. Yet, para 4.5.10 suggests that further intensification of the existing urban areas is not popular. There is no Urban Capacity Study or Strategic Housing Market and Land Availability Assessments available to demonstrate or illustrate how and where housing needs can be met throughout the Plan period. It is submitted that the absence of clear evidence and the Council's own uncertainties on the matter suggest that the Council's proposals to continue with a restrictive suite of policies for development within the Green Belt are without justification. Para 4.5.10 recognises that a compromise for the Council would be to release land from the edge of settlements which "does not have a significant impact on the Green Belt" which suggests that a review is to be considered. The repetition of national policy and that in the East of England Plan as currently set out does not equate to the local context and the policy needs adjustment to take into account local circumstances based on local evidence.The resistance to looking at the urban fringe and the Green Belt is certainly not underpinned by detailed evidence to demonstrate that the housing strategy, set out in Section 4 of the document, is robust and capable of delivery. It follows that a review of Green Belt boundaries should be undertaken or, at the very least, identified as a contingency in order for the required housing figures to be achieved. The Local Development Scheme suggests a review of the Green Belt Boundary is intended to be undertaken in 2011. Having regard to the issues on delivery of the required housing and those arising out of PPS3 for housing studies such a review is required now, before options are considered, to properly inform the Strategy. Similarly it is considered premature to propose Strategic Buffers between settlements until there has been a proper analysis of the ability and options to provide for housing requirements and a study of the landscape quality and value of such areas. Para. 25 of PPS7 is particularly relevant in considering proposals for the Strategic Buffers. To paraphrase the guidance, "Local landscape designations should only be maintained ... where it can be clearly shown that criteria-based planning policies cannot provide the necessary protection" and, "when reviewing their local ... plans ... planning authorities should ensure that such designations are based on a formal and robust assessment of the qualities of the landscape concerned". The thrust of the guidance in paragraph 25 is that there must be robust and compelling reasons for the introduction of strategic buffer. However, there is no suggestion from the Local Development Scheme that it is intended to prepare a landscape character assessment to inform the proposed designation of Strategic Buffers and this is considered essential before promoting such a policy.

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

Rayleigh and Eastwood (the area around the boundary with Southend Borough Council)

Re land between 340/370 Eastwood Road, Rayleigh. This is a piece of waste land. It is ideal for use by a housing corporation for cheap social housing or perhaps for residential care. We always understood that the boundary between Rochford Council and Southend Borough Council was in the region of 459 Eastwood Road, Rayleigh that being the case, then the Silver Jubilee Public House has been allowed to develop on green belt land.

I fully support Rochford District Council's view of maintaining strategic buffers as listed in the Preferred Options Draft. It is very important that these buffers are well protected where they are located next to the boundaries with other districts as the policies of the other districts might well include development up to the district boundary. Notice how the Shotgate Industrial Estate reaches right up to the boundary between Rochford District and Basildon District to illustrate the importance of this point. The list of strategic buffers should therefore include "Shotgate & Rawreth (the area around the southern part of the boundary with Basildon Disctrict Council)".

It is very important to maintain a strategic buffer with Castle Point District all the way along the A127 to the west of the Rayleigh Weir underpass as it is quite probable that development of parts of the Thundersley Lake District (which is just to the south of the A127) may be allowed by Castle Point Borough Council.

These representations are made by Iceni Projects on behalf of Seaside Limited. Seaside is seeking to promote and ultimately deliver a private infrastructure-backed major regeneration opportunity to the south east of Rochford and on the northern edge of Southend-on-Sea, encompassing land both within Southend and Rochford District. Working in consultation with major landowners and key stakeholders, Seaside is looking to pursue the following:

* The delivery of comprehensive new highway infrastructure in order to provide a long-term solution to Rochford and Southend's traffic congestion and access difficulties;
* A willingness to incorporate high quality public transport and new technology, including the development of hybrid bus/tram systems, and a focus on improving connectivity between Rochford's railway station and the town centre;
* Working in tandem with Regional Airports Limited to help the expansion and function of London Southend Airport, and in particular, to help promote Rochford and Southend as dynamic employment locations within Essex Thames Gateway;
* A commitment to reverse out-commuting, and the growing dependence of London as an employment destination;
* A detailed assessment of town centre opportunity sites within Rochford as part of a comprehensive development framework master planning exercise;
* A strategic approach to accommodating a proportion of both Rochford and Southend's East of England Plan employment and housing growth targets;
* A commitment to the implementation of the South Essex Green Grid Strategy in respect of Rochford and Southend, including the provision of 'green-lungs' as part of a comprehensive review of the Green Belt boundary;
* The creation of a new district neighbourhood with supporting public infrastructure an services;
* The delivery of a wide range of residential accommodation, including a headline commitment to 40% affordable housing;
* A focus on the delivery of high quality employment land within close proximity of London Southend Airport, as well as a commitment to provide incentivised employment space for high-worth employment companies;
* A positive obligation to deliver sustainable means of construction, with the objective of providing a carbon-neutral development;
* Improvements to local education and healthcare facilities;
* A specific focus on quality urban design, acknowledging the importance of the Essex Design Initiative and Rochford's distinctive urban fabric;

A fundamental tenet of Seaside's proposals is the commitment to deliver employment-led, infrastructure driven development, financed by way of the strategic release of land from the Green Belt. This issue, together with the perceived benefits identified above, sets the context against which these representations have been prepared.

There are a number of factors that should additionally be highlighted at the outset of these representations:

* Seaside has received the findings of its web-based consultation exercise, which was undertaken by Resolex following the launch of 'South Essex Tomorrow' in November 2005. A full copy of the report will shortly be issued to all relevant stakeholders. Findings of importance include the fact that:

o More than 50% of respondents liked the Seaside vision, and less than 25% did not approve; the remainder were undecided;
o More than 70% of respondents thought that public transport needs to be improved in Southend/Rochford;
o More than 70% of respondents thought that better transport links would attract business to the area;
o Only 5% thought that traffic in Southend is free-flowing, while 80% reported a problem with traffic queuing;
o Only 13% of respondents found public transport to be satisfactory;
o More than 50% of respondents thought that Southend should be the capital of the Thames Gateway; and
o The proposals for the extension of the A127 were reasonably well-received overall.

In the recent publication 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' produced by the Planning Inspectorate (July 2007), it is clearly stated that 'The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved' (Paragraph 3.10). In respect of this, the following representations are made on the Draft DPD and are intended to be a positive contribution to the Local Development Framework process. The representations made follow the order of the Draft DPD.

a) Section 1: A Spatial Portrait of the Rochford District

Para 1.9

Seaside acknowledges that road infrastructure within the district is poor. A key element of Seaside's proposals is to provide improved access into the urban areas of Rochford and Southend from the A127, with a view to specifically enhancing surface access to London Southend Airport.

Para 1.10

Equally, public transport access is poor. Seaside is promoting the introduction of a new park and ride facility to the west of the Airport, which will assist in removing vehicles from the road network as soon as possible. This could provide links to Rochford Town Centre, Southend Town Centre and London Southend Airport. A series of new bus services could be introduced, to take advantage of the role of Rochford Railway station as a transport hub. The opportunity could also be taken to introduce, when operational, South Essex Rapid Transit, providing connectivity throughout the urban area of Rochford and Southend

Para 1.11

Seaside is working with the Airport to try and assist with the delivery of a new surface access strategy, and indeed on a wider scale, to provide the circumstances in which the Airport can flourish as an important regional airport and economic centre.

Para 1.12

Seaside supports the allocation of additional employment land within close proximity of the Airport, particularly where this can provide direct access to the runway and apron.

b) Section 2: Spatial Vision for the District

Para 2.6

Seaside supports the vision for the future of Rochford, and in particular the intention to focus development on a number of large sites. Seaside's proposals could potentially accommodate a large proportion of Rochford's housing and employment allocation, but for the avoidance of doubt, Seaside would not wish to preclude a reasonable amount of development in other locations across the District. Seaside's proposals provide the means to extract the maximum benefit from Green Belt land release, but if follows that the other major urban areas should also experience a level of growth in order to maintain shops and community facilities, including health and education.

Para 2.11

Seaside welcomes the Borough Council's commitment to tackle traffic congestion and the support for integrated public transport. These are significant elements of Seaside's proposals.

c) Section 3: The Relationship of Documents in the Local Development Framework

Para 3.9

In addition to a Joint Area Action Plan for land to the west of Rochford, Seaside contend that Joint Area Action Plan should be produced for land to the east of Southend Airport in Seaside Phase 1. A Joint Area Action Plan will help deliver the private infrastructure-backed major regeneration that is being promoted and provide readily available land for airport related uses.

d) Section 4: Core Strategy Issues

Para 4.2.2

Seaside questions the contention that the strategic review will not be required until 2021. This strategic review will occur during the East of England Plan Review stage and could emerge as early as 2008. Consequently, the implications of further growth should be built into the choice of options for the Core Strategy, as clearly this plan should be capable of modification in order to cater for potentially greater growth requirements.

Para 4.2.5

Seaside encourages the prioritisation of previously developed sites and the Council's recognition that the scope of achieving this aim is severely limited as many of the major sites have already been developed.

Para 4.2.6

Seaside supports the provision of high density development to minimise necessary land take but, equally acknowledges it will be important to rule out town cramming. Seaside considers that the scale of the District's existing urban areas, particularly Rochford, are not sustainable for major growth due to the lack of associated infrastructure.

Para 4.2.7

Seaside conclude that the Council's preferred options for the Green Belt are contradictory in nature stating their continued support for the restrictive suite of policies for development of the Green Belt whilst further stating that there will be some relaxation for major developed sites, green tourism and renewable energy proposals. This point should be amended for clarity.

Para 4.2.8

Seaside believe the alternative options for the Green Belt have failed to consider the option of formal Green Belt release tied to infrastructure improvements. Seaside have concerns about this omission in view of its ambitions to provide major infrastructure-backed regeneration and would question why such an option has been ruled out on the grounds of sustainability.

4.3.3

Seaside acknowledges the need for improved access, in any strategy, to focus economic growth around the Airport but would specifically encourage the Joint Area Action Plan to include land to the east of the Airport.

Para 4.5.1

Seaside supports the allocation of specific sites for housing need in the Allocations DPD.

Para 4.5.2

Seaside commends the clarity in which the previous Draft DPD dealt with the Borough's housing allocation, which can often be complicated by different start dates and completions. The Draft DPD made clear that Rochford's outstanding housing allocation was 3,699 units over the period 31st March 2006 to 2021. Seaside would encourage the District Council to update this figure to take account of developments in the interim period, and through subsequent LDF documents as and when developments are completed.

Para 4.5.4

Seaside welcomes the common sense approach that the Draft DPD takes to windfall sites, as well as the acknowledgment that intensification is not always a positive outcome for existing communities.

Para 4.5.5

Seaside further supports the Draft DPD's strategy to rely on Greenfield sites to deliver the maximum possible benefits in infrastructure provision.

Para 4.5.6

Seaside encourages the Council to consider the relocation of existing sites which are considered to be bad neighbours but is concerned that there is no mention within the Draft DPD as to where these bad neighbour uses can be relocated to. The positive release of dated industrial sites is supported but there must be due consideration to the relocation of such uses in advance of the adoption of a definite policy approach.

Para 4.5.7

Seaside supports the Council approach to specifying the locations of proposed development in detail in the Allocations DPD.

Para 4.5.8

Seaside fully supports the intention of the Draft DPD to plan development in an environmentally and economically sustainable manner. Seaside would propose to finance the delivery of wider social infrastructure including retail and community facilities, health and education, and public open space.

Para 4.5.10

Seaside supports the claim that further intensification of the existing urban areas is not a popular strategy for future growth. To allocate the majority of additional growth onto the back of Rayleigh and Rochford will overload existing settlements of insufficient scale leading to unsustainable and inappropriate expansion of the District's main settlements.

Para 4.6.2

Seaside supports the Borough Council's intention to oppose the development of sites that are liable to flood. Virtually all of Seaside's land holding falls outside of the floodplain, and indeed marks the proposals out from virtually all others within the Essex Thames Gateway.

Para 4.6.6

Seaside partially supports the Draft DPD's intention to focus 90% of the Borough's housing allocation within the vicinity of the existing main settlements, albeit Seaside would contend that the majority of the allocation should be focused on land to the south east of Rochford, and tied to the provision of employment land within close proximity of London Southend Airport. Seaside's proposals clearly seek to accommodate some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this approach provides the best means of delivering a step change in road and public transport infrastructure.

With the above in mind, Seaside are conscious that one of the possible options identified is a new settlement. Seaside do not believe that its proposals constitute a new settlement, albeit there are elements of its proposals - particularly the scale of growth proposed - that reflects some of the attributes of a new settlement. In particular Seaside's proposals will be linked to the provision of public transport, and new community facilities, but unlike a stand alone community, Seaside is intent on linking these benefits to Rochford railway station and Rochford town centre, thereby strengthening the role and function of the town in a sustainable and manageable manner.

Para 4.6.9

Seaside believe the results of its initial consultation should be fully considered. It is not sustainable to concentrate additional growth in and around existing settlement areas. Seaside contend that the most appropriate area for growth and expansion is to the south east of Rochford focussed around the new Rochford railway station.

Para 4.6.10

Seaside disagree with the housing allocation figures set out in this section of the Core Strategy. Specifically by focussing 1000 units around Rochford/Ashingdon and 1800 units at Rayleigh, sustainable growth will not be achieved. This approach to development will overload the existing settlements, which are of insufficient scale and will not provide the additional benefits in terms of infrastructure improvements that the Seaside Phase 1 development can deliver.

Para 4.6.11 and 4.6.12

Seaside consider that the proposed Core Strategy is unsound in dismissing the expansion of one settlement to create a significant urban expansion on the grounds of it being unsustainable. As previously mentioned, concentration of growth around existing settlements will overload these areas.

Seaside's proposals seek to take in some of both Rochford and Southend's housing and employment allocations (across both administrative areas), and it is considered that the critical mass of this strategic approach provides the best means of delivering a step change in road and public transport infrastructure. Provision of growth in a significant urban expansion, as proposed in Seaside Phase1, far from being unsustainable, creates the critical mass and economies of scale which allow an integrated form of development providing significant transport and community facilities whilst still maintaining active links to Rochford railway station and the existing town centre. It would also maintain the form and function of Rochford, more so than a piecemeal extension as proposed by the Core Strategy.

Para 4.6.16

Seaside acknowledge that top tier settlements are better located in relation to the existing highway network but argue that the concentration of growth around these existing settlements will not deliver the necessary infrastructure improvements which are needed in the Borough. A comprehensive new development focussed around the growth and expansion of the south east of Rochford will provide greater infrastructure improvements and a more appropriate form of development.

Para 4.6.20 and 4.6.21

Seaside recognise that Rochford/Ashingdon are heavily congested areas in practice and physical restraints exist to future infrastructure expansion. As well as physical constraints, there is a need to protect the conservation area around Rochford Town Centre. Focussing future housing growth in the proposed Seaside Phase 1 development will provide the benefits of delivering essential infrastructure provision as well as reducing the impact upon the environmental designations and conservation area. Relying on future growth around existing built up areas will unacceptably overload these areas and will not deliver the desired infrastructure improvements.

Para 4.6.23

Seaside Phase 1 redevelopment can come forward in the immediate term and will provide the necessary infrastructure to provide sustainable levels of future growth over the specified plan period.

Para 4.7.5

Seaside does not support the proposed affordable housing threshold of 25 units at a rate of 30%. Setting a higher threshold and lower rate of delivery than the Regional target will never provide a reasonable level of affordable housing to meet the needs of the Borough. It is not considered that the Council has produced a sustained enough evidence base to justify this lower threshold and accordingly the Core Strategy is considered to be unsound in this regard. Non compliance with Regional guidance will not deliver satisfactory levels of affordable housing and a headline target of a least 35% for schemes of 15 units or more is needed to make the Core Strategy sound and ensure sustainable future growth of the Borough.

Para 4.7.11 and 4.7.12

Seaside consider the discounting of a 40% provision of affordable housing on all sites of 15 or more units to be unsound and not supported by a robust evidence base. Seaside would encourage the Local Authority to reconsider this preferred option in accordance with Planning Inspectorate guidance 'It should be clear to consultees at preferred options stage that it remains open for them to express a preference for any option, including those the LPA suggest be rejected and that response may lead to the LPA to re-think the option pursued at submission stage' (Local Development Frameworks: Lessons Learnt Examining Development Plan Documents, Para 1.6). The current approach to affordable housing is considered unsound and impacts upon the soundness of the entire Core Strategy.

Para 4.8.5

Whilst Seaside supports the Council's backing for London Southend Airport, the employment generating potential of the Airport is dependent on a number of significant factors, including a runway extension, significant improvements to surface access, including a road closure, the construction and operation of a new railway and terminus, and scope for on-site employment expansion. Seaside will be working with the Airport to bring forward these proposals, and recognises that the Airport has the potential to form a significant component of its employment-led growth proposals. However, it also follows that even if the Airport and Rochford Business Park are as successful as the Draft DPD anticipates, there will still be a requirement to identify opportunities for a further 1,000 jobs. Seaside is seeking to bring forward additional employment land to the east of the Airport, and this provides the opportunity to develop out a state of the art employment park.

Para 4.8.6

Seaside supports the Council's approach to reviewing the condition and location of existing industrial estates and where appropriate considering the creation of new employment areas in more sustainable locations. Seaside Phase 1 will provide significant employment numbers in appropriate locations.

Para 4.9.9

Seaside believe the preferred options for good design and design statements should include additional information on eco excellent standards and carbon neutral practices.

c) Conclusion

Seaside fully supports the long term regeneration and growth of Rochford, and wishes to work with the District Council to make this common objective a reality.

In consideration of these representations, reference has been made to the recent guidance published by the Planning Inspectorate 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents' (July 2007). In conclusion, I wish to draw your attention to a number of paragraphs of this guidance specifically:

Paragraph 3.11: 'Many of the early Core Stratagies are somewhat general and contain "policies" that are in reality aspirations' - The Rochford core strategy must not fall within this trap and Seaside would argue that the current Core Strategy proposals run the risk of doing exactly this in their approach to future housing growth. The proposed concentration of growth in and around the existing urban areas is extremely ambitious and largely an aspiration of the Council. There is no specific mention as to exactly where this growth will go and the Council's approach is unsustainable in this regard.

Paragraph 5.1: 'The Core Strategy should provide a clear guide for the preparation of the subsequent DPDs or provide a base against which those DPDs can be assessed' - At present, the Core Strategy incorporates a number of principles which will not support the sustainable and balanced future growth of the District. The proposed strategy of focussing growth around the existing urban areas will not provide a clear base for the preparation and assessment of future DPDs, namely the Site Allocations documents.

Paragraph 5.2: 'Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site allocations DPD. The strategy should be driving the allocation of sites not the other way around' - In view of this advice, Seaside argue that the current approach of the Core Strategy is unsustainable in focussing future growth around existing settlements. This approach will overload existing settlements and will not ensure the sustainable future growth of the Borough. A more appropriate and sustainable approach to future growth is to focus growth to the south east of Rochford around London Southend Airport in Seaside Phase 1. Future Growth around this area will ensure a highly sustainable form of development with associated infrastructure improvements.

The guidance also refers to the need for Local Development Frameworks to build in flexibility to DPDs and address the issues that could arise if the chosen option cannot be delivered when required. The Core Strategy does not presently allow for flexibility around the preferred options for future growth and should look to adopt a more flexible approach. In considering land to the south east of Rochford, significant flexibility is built into the system allowing a responsive DPD capable of reacting to future changes in policy.

In addition to these representations, please find enclosed a map of Seaside's proposals, illustrating the specific area of land which is being promoted to accommodate the future growth of the Borough.

Should you wish to discuss any aspect of these representations, or alternatively arrange a meeting to understand more fully how Seaside can contribute to the Council's growth and regeneration objectives, please do not hesitate to contract me.

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

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

4.2 The Green Belt & Strategic Buffers between Settlements

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

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

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

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

4.3 Protection and Enhancement of the Upper Roach Valley

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

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

4.4 Protection and Enhancement of Special Landscapes, Habitats & Species

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

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

4.5 Housing Numbers & Phasing

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

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

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

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

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

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

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

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

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

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

4.6 General Development Locations

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

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

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

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

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

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

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

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

* Access to countryside and informal recreational opportunities

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

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

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

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

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

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

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

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

4.7 Affordable Housing

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

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

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

4.8 Employment

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

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

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

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

4.9 Good Design & Design Statements

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

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

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

4.10 Character of Place & Historic Environment

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

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

4.11 Landscaping

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

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

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

4.11 Energy & Water Conservation & Renewable Energy

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

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

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

4.12 Compulsory Purchase & Planning Obligations

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

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

Representation from Savills on behalf of Martin Dawn Plc

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy. Comments are submitted in relation to the following paragraphs in section Four:

4.27 and 4.28 - Object
4.5.11 and 4.6.12 - Object
4.6.10 and 4.6.11 - Support
4.7.10 - Support
4.7.11 - Object
4.9.9 - Object
4.9.10 - Support
4.11.6 - Object
4.12.11 - Object

These representations were also sent by fax and e-mail on 2 July 2007.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

4.27 AND 4.28 - OBJECT

Whilst Martin Dawn supports the principles of continuing to maintain the purposes of including land in the Green Belt as required by PPG2 and seeking to prevent the coalescence of settlements, paragraphs 4.27 and 4.28 do not recognise the Council's need to consider release of Green Belt land to meet regional housing and employment land where there is a sequential case proven for sustainably located land.

The alternative options for Green Belt set out in the paragraph do not reflect this need and will be inadequate for reviewing the Green Belt boundaries in the Site Allocations DPD at the appropriate time.

4.5.11 AND 4.5.12 - OBJECT

Paragraph 4.5.11 does not contain an approach to address the housing needs of the District. PPS3 requires that LPAs identify at least a five year supply of housing land. The Council's site allocation document must therefore be capable of identifying land to meet strategic housing numbers otherwise applications can legitimately be determined in line with the status of the housing supply numbers. This paragraph should therefore refer to the need to identify Greenfield/Green Belt land in accordance with strategic housing numbers and sustainable location criteria.

Paragraph 4.5.12 and the alternative options for housing numbers and phasing, does not meet PPS3 guidelines and is unlikely to be acceptable to the Government Office.


4.6.10 AND 4.6.11 - SUPPORT

Martin Dawn supports the Council's identification of the priority and hierarchy of Rochford and Rayleigh. It is clear that the established settlements will be able to respond to sustainable development criteria where there are existing public transport services and social and community facilities.

4.7.10 - SUPPORT

Martin Dawn supports the affordable housing policy in line with local housing needs.

4.7.11 - OBJECT

Martin Dawn objects to the alternative higher level affordable housing percentage and lower threshold in line with local housing needs.

4.9.9 - OBJECT

Martin Dawn objects to the need for a Design Brief to be required in advance of the submission of all major applications. This is an unnecessary requirement and a hindrance to the planning process which will delay the progress of the delivery of housing and employment sites. There is no requirement within national planning policy guidance or the Planning & Compulsory Purchase Act (P&CPA) for this process. The legislation requires a Design & Access Statement for major applications and this is all that should be required (in addition to any other technical or EIA documentation).

4.9.10 - SUPPORT

Martin Dawn supports the options set down in paragraph 4.9.10 as both the P&CPA, Building Regulations, PPS1 and PPS3 contain sufficient guidance and requirements to enforce high quality design. The LDF documents are required not to repeat national guidance and be brief in their structure. Paragraph 4.9.9 is therefore unnecessary in this context.

4.11.6 - OBJECT

Whilst Martin Dawn agrees that landscaping is an important consideration in the determination of applications, paragraph 4.11.6 takes away the legislative rights set down in the P&CPA for outline applications to chose whether landscaping is determined within the outline application or as a reserved matter. LDF documents should not prevent the application of the Act and its legislation. The paragraph also does not define what application types will be required to provide landscape details in advance.

4.12.11 - OBJECT

Martin Dawn supports the sustainable development principles of paragraph 4.12.11 but it is too prescriptive in its requirements. Not all development will be able to meet the paragraph objectives and therefore it should recognise that an assessment to be submitted with major applications, should demonstrate how or why not the sustainable objectives can or can not be met. It is widely recognised that renewable energy technologies are not yet sufficiently advanced to meet legislative requirements and that generally only major applications will be capable of making a contribution to energy efficiency and renewable energy strategies. This paragraph is too prescriptive.

Rochford Core Strategy Preferred Options

Thank you for consulting the Home Builders Federation (HBF) on the above, particularly given that you seemingly failed to do so at the Issues and Options stage.


Background:

The Council must carefully consider the extent to which the objectives and content of the draft document are consistent with the latest national Government and other important policy guidance.

PPS1

There have been many recent substantive changes in government policy including the proposed supplement to PPS1 'Planning and Climate Change'.

PPS3

PPS3 (November 2006) requires local authorities to balance the need to provide affordable housing in association with new development against the need to ensure that housing requirements are met. It advocates making provision for housing over at least a 15-year time period.

It also emphasises the importance of the role of Strategic Housing Market Assessments in the evidence base for DPD policies. The Council will need to ensure that policies are underpinned by a sound and up to date evidence including such an Assessment. It will also need to have sound housing trajectories to show when the overall housing numbers are likely to be delivered.

The Council will need to:

* have a flexible responsive supply of land managed in a way that makes efficient and effective use of land, including the re-use of previously developed land, where appropriate;

* be market responsive;

* work collaboratively with stakeholders (such as the HBF);

* take account of the need to deliver low-cost market housing as part of the housing mix;

* set separate targets for social-rented and intermediate housing;

* take into account any physical, environmental, land ownership, land-use, investment constraints or risks associated with broad locations or specific sites, such as physical access restrictions, contamination, stability, flood risk, the need to protect natural resources e.g. water and biodiversity and complex land ownership issues;

* undertake a Sustainability Appraisal to develop and test various options, considering, for each, the social, economic and environmental implications, including costs, benefits and risks;

* include housing and local previously-developed land targets and trajectories, and strategies for bringing previously-developed land into housing use;

* identify broad locations and specific sites that will enable continuous delivery of housing for at least 15 years from the date of adoption, taking account of the minimum level of housing provision stipulated in the RSS;

* identify deliverable sites to deliver at least 5 years supply that are - available, suitable and achievable;

* identify a further supply of specific, developable sites for years 6-10 and, where possible, for years 11-15;

* exclude sites granted planning permission unless it can be demonstrated that they are developable and likely to contribute to housing supply within the appropriate timescale;

* exclude allowances for windfalls in the first 10 years of land supply; and

* set out a housing implementation strategy.

The new Policy Statement heralds several new changes, these are:

* The requirement for a robust evidence base;

* A partnership between local authorities, developers, and other stakeholders to establish a more transparent assessment;

* An emphasis upon sustainable locations; rather than just the prioritisation of previously developed sites, or sequential test; and

* The identification of constraints (physical and housing market) on sites, and considering how these might be overcome during the plan period.

It will be necessary for both brownfield and greenfield sites to be released in good time if the overall housing requirement is to be met.

The Council will need to demonstrate in its Core Strategy that its assumptions with regard to the future housing supply in its new housing trajectories are accurate and realistic, and that identified sites are readily available for development.

The Council will need to ensure that it provides a suitable range of housing localities to meet the needs of their current and future residents. It should make decisions based upon a sound evidence base. A SHMA (Strategic Housing Market Assessment) will be a very important source of information.

Annex C of PPS3 states, "a Strategic Housing Land Availability Assessment should:

- Assess the likely level of housing that could be provided if unimplemented planning permissions were brought into development.

- Assess land availability by identifying buildings or areas of land (including previously developed land and greenfield) that have development potential for housing, including within mixed-use developments.

- Assess the potential level of housing that can be provided on identified land.

- Where appropriate, evaluate past trends in windfall land coming forward for development and estimate the likely future implementation rate.

- Identify constraints that might make a particular site unavailable and/or unviable for development.

- Identify sustainability issues and physical constraints that might make a site unsuitable for development.
- Identify what action could be taken to overcome constraints on particular sites".
PPS12

Regard will need to be had to PPS12 in terms of ensuring that planning documents produced fully comply with national planning policy statements in their content and preparation.

PPS12 test of soundness vii requires DPD policies to represent the most appropriate in all the circumstances, having considered the relevant alternatives, and that they are founded on a robust and credible evidence base. The Council will have to balance the need for any planning gains against the financial implications of any policy requirement on development viability.

PPS25

PPS25 sets out policies for planning authorities to ensure flood risk is properly taken into account at all stages in the planning process; prevent inappropriate development in areas at high risk of flooding and direct development away from areas at highest risk. It is accompanied by Circular 04/2006.

The East of England Plan

The Proposed Changes to the Draft RSS make it clear that local authority housing requirements must be treated as an absolute floor, rather than ceiling figures. Therefore, the Council's dwelling requirement must be fully recognised as being an absolute minimum housing provision figure.

PINS

The Planning Inspectorate published 'Local Development Frameworks: Lessons Learnt Examining Development Plan Documents (June 2007)'. It makes a number of very important points that Local Authorities need to have very careful regard to, it states:

1.11 "...Evidence should be complete on submission. LPAs should be clear that evidence should inform the Plan and not be put together after submission to justify what is already in the submitted document.

1.12 PINS expectation is that the LPA will provide a full and comprehensive evidence base with the submitted DPD. Given that the options should also be informed by evidence, we would expect the evidence base to be substantially completed at preferred options stage. The "Evidence" boxes on pages 15-21 of the Planning Inspectorate's guide "Development Plan Examinations - A Guide to the Process of Assessing the Soundness of Development Plan Documents"6 (PINS DPD guide) suggests the range of evidence which may be required, depending on the type of DPD and nature of the area. It will be difficult for an LPA to argue the plan is based on evidence which was not available when the plan was submitted - the implication will be that the evidence has not informed the content, but rather has been produced to retrospectively justify the content.

1.13 All material to be relied upon by the LPA needs to be in the submission evidence base. .....As the LPA is expected to submit a "sound" document it is not appropriate for the plan making authority to provide additional unasked for material in this way.......

1.14 .....LPAs should recognise that the submitted plan should be the last word of the authority (Section 20(2)(b) of the Planning and Compulsory Purchase Act 2004 Act and paragraph 4.15 of Planning Policy Statement 12). Post-submission changes should be the exception8 (box under paragraph 4.18 PPS12).

1.19 LPAs which rely on making considerable post-submission changes, even if relatively minor, should bear in mind that a document may be found to be unsound if it requires so many changes that the final document no longer closely resembles the submitted version......

3.10 From the material that we have seen it is clear that there remains some lack of appreciation of the need for a radically different approach to plan making. LDFs are not meant to be LP/UDPs in new clothes. Some LPAs seem to be finding it difficult to move from an approach which seeks to produce a document that will allow development control decisions to be taken (the negative regulatory approach) rather than starting with the concept of providing a picture of how the area will develop spatially over the plan period and providing a policy framework that will deliver it (the positive delivery approach). The aim of the Core Strategy should be to articulate what the area should be like in the future and how this is to be achieved.

3.11 Core Strategies should be focussed on spatial policies that are very specifically aimed at addressing the issues identified as relevant to that area. They should also, where appropriate, refer to specific 'strategic' sites (i.e. those which are key to the delivery of the overall strategy). DPDs are intended to be about delivery and hence need to be rooted in what can be achieved and how this is to occur. Many of the early Core Strategies are somewhat general and contain "policies" that are in reality aspirations. For example many Core Strategies contain general "good design policies" but are silent on how the LPA is going to implement and monitor this "policy".

3.12 There is a widespread failure to appreciate that Core Strategy policies need to add a local dimension to national or regional guidance/policy. If there is no specific local dimension there is no need for the national/regional policy to be repeated. ....

3.14 ..The Inspector will not be able to recommend changes in a binding report unless he/she can be sure the plan as changed would not be vulnerable to challenge on the grounds that the proper procedures had not been followed [in particular the SA process and proper community involvement].
4.4 ...Core strategies are where tough decisions need to be made: strategic decisions cannot be left to subsequent DPDs.

5.2 Taking housing as an example, the Core Strategy must not leave the question of the general allocation of the level of housing to settlements open on the grounds that this can only be done once housing sites have been identified in a housing or Site Allocation DPD. The strategy should be driving the allocation of sites not the other way around. In this way, where it is clear that there are certain sites, key to the delivery of the overall strategy, whose location is not open to extensive debate (either because of existence of barriers to growth elsewhere or because of overwhelming positive qualities of the site), then it is entirely appropriate for such sites to be mentioned in the Core Strategy.

5.4 ...The Planning Advisory Service published "Core Strategy Guidance"14 in December 2006 which aims to assist LPAs by providing an idea of what parts of a Core Strategy might look and feel like.....

5.7 Core Strategies should not contain bland general policies that are little more than public relations statements. For example "Housing development must contribute to the creation of sustainable and mixed communities. Proposals must provide housing types and tenures that address local housing needs".....

5.8 ....Inspectors need to establish whether the plan will achieve what is intended by being able to measure the policies/proposals. Derivation of targets should be properly explained. There should also be a clear evidence base for specific numbers and percentages.

5.9 DPDs should be firmly focused on delivery. Thus the implementation and monitoring section of a DPD is of equal importance as the policies in the DPD. A number of Core Strategies seen to date have been particularly weak on implementation and monitoring. It is not adequate to deal with monitoring in a Core Strategy by simply saying that it will be dealt with in the Annual Monitoring Report (AMR). The Core Strategy needs to set the framework for the AMR by identifying key targets and indicators against which the LPA can measure the effectiveness of the strategy/policies and proposals.

5.12 For Core Strategies, Site Allocation DPDs and perhaps some Area Action Plans, this potential for change does make it more difficult to offer consultees certainty about the precise implications of developing plans. In these circumstances, it may be appropriate to set out how the DPD, once adopted, would be used to manage the changing circumstances. So a Core Strategy might describe the general approach to meeting need for additional housing provision based on current RSS requirements. It could also explain how the approach could be adjusted in practical terms if housing provision needed to change or be phased differently once the RSS review has concluded. In other words, that it is not constrained by one set of figures for housing development in the area or by political rather than planning considerations.
5.13 Flexibility is also about considering "what if" scenarios, e.g. if the strategy is heavily reliant on a specific type of infrastructure or a major site. The plan should address the issues that could arise if the chosen option cannot be delivered when required.


General:

Whilst there may well be local support for the re-use of brownfield sites, it is essential that where any such sites are identified and allocated, they are readily and realistically available for housing development. The over-riding objective must be to comply with the overall housing requirement. Consequently, in order to so do the Council will realistically need to ensure a range of both brownfield and Greenfield sites are available.

Furthermore, the Council must seek to ensure that a range of different types of housing are provided in different forms and in different localities in order to meet the various needs of its population. To this end a Strategic Housing Market Assessment is likely to be an essential tool and evidence base.

It is crucial that any planning gain requirements are fully considered in relation to site viability. Whilst the public inevitably wants developers to fund all sorts of facilities and services in their areas, it must be remembered that developers can only be asked to fund these where need directly relates to new development. Furthermore, if planning gain requirements are unrealistic then landowners won't sell their sites, and developers won't find them profitable enough to develop. As a direct consequence, the Council would then be likely to struggle to meet its housing supply requirements.

With regard to affordable housing provision, proper and full regard must be had to the overall viability of schemes in setting any requirements. It should be remembered that in order to make housing more affordable, there needs to be more housing built in total. There should also be a flexible approach to the delivery of any affordable housing requirement, taking on board whether or not public grant funding is available. If not, then an alternative approach/requirement has to be properly considered.

It must be remembered that affordable housing requirements must not be so onerous that they threaten the delivery of the Council's overall housing requirement.

The Council should also ensure that a proper Strategic Housing Market Assessment is undertaken with the full involvement of the property industry so as to underpin the evidence base for any policies and requirements.

In order that the LDF is sound and consistent in approach as well as monitorable and deliverable, there will need to be a link between the housing policies in the Core Strategy and the individual housing allocations. In other words, the allocations must contain some indication of the numbers of dwellings the Council anticipates are capable and likely to be delivered from each site. Either that or there should be a table in the core strategy which summarises all the housing allocations giving their site name and reference and an indicative dwelling total. Or both.

Only with this information can the robustness of the Core Strategy's approach to housing delivery be properly tested.

Sustainability standards are already being set by Building Regulations, and are being supported in the new Code for Sustainable Homes, the Council's planning policies should not seek to directly replicate or replace these (as PPS1 makes clear).


Options & Vision:

Many of the various options identified seem to often list the Council's future actions and aspirations, rather than identify in specific spatial strategy details.


Specific matters:

4.2.7

The Council needs to ensure that a Strategic Housing Land Availability Assessment and a Strategic Housing Market Assessment are undertaken.

PPS3 now requires the production of Strategic Housing Land Availability Assessments, again with key input from key stakeholders such as the development industry. These are far more vigorous in their approach, and make it clear that existing commitments will only be able to counted, where there is evidence that they will actually be deliverable.

Consequently, the overall housing requirement figure to be found may be higher than the one that the Council envisage. Therefore, the HBF does not consider that the Council can necessarily delay the green belt review to after 2021. It believes that the overall housing requirement will necessitate sites in the green belt being allocated as housing allocations. It should also be recognised that green belts can by their very nature promote much greater carbon emissions as people are forced to travel further between their homes and work.

Additionally, the precise role and purpose of 'green wedges' acting as strategic buffers is unclear. The HBF objects to them as they could limit growth options.

4.5.2

The text fails to make any reference to the fact that provision will need to be made for a supply of at least 15 year's housing supply from the Plan's adoption date. Therefore, such provision will need to be identified beyond the year 2021. Consequently, a higher housing number will need to be identified.

4.5.3

The Council states an Urban Capacity Study is currently being undertaken. The HBF is surprised that as an important stakeholder it has not been consulted in respect of the content of this document.

However, the Council now needs to ensure that a Strategic Housing Land Availability Assessment and a Strategic Housing Market Assessment are also undertaken.

PPS3 now requires the production of Strategic Housing Land Availability Assessments, again with key input from key stakeholders such as the development industry. These are far more vigorous in their approach, and make it clear that existing commitments will only be able to counted, where there is evidence that they will actually be deliverable.

4.5.4

The Council states that it will take into account the number of housing units granted planning permission. However, it will only be able to include those that meet the tests set out in PPS3 (i.e. deliverable and available).

4.5.7

The text fails to make any reference to the fact that provision will need to be made for a supply of at least 15 year's housing supply from the Plan's adoption date. Therefore, such provision will need to be identified beyond the year 2021. Consequently, a higher housing number will need to be identified.

Phasing should only be used where necessary in order to allow for infrastructure provision e.t.c., the main focus must be upon ensuring that the overall housing requirement is delivered.

4.5.11

It is unclear what the Council means in terms of the 'cascaded' figure for homes from the East of England Plan.

Phasing should only be used where necessary in order to allow for infrastructure provision e.t.c., the main focus must be upon ensuring that the overall housing requirement is delivered.

Reference is made to the expected phasing of development being slightly increased from 2009-2021. However, the Council must remember that the housing requirement is a minimum figure, and that it is behind in delivery. Consequently, supply will need to be significantly increased from recent numbers if the overall delivery requirement is to be met.
4.6.10

The strategy is neither underpinned by a Strategic Housing Land Availability Assessment, or a Strategic Housing Market Assessment. It is also unclear as to the implications of making no housing allocations in a number of settlements.

The Council will need to ensure that suitable housing provision is made to meet a range of different housing needs (including for family housing), this will require a variety of different types of sites in different localities. Given that the housing requirement is based upon a minimum figure, the Council should place its efforts on ensuring that this is achieved. It should not seek to overly control and manage housing delivery where there are not direct infrastructure issues or problems that first need resolving.

4.7.4

The Council has set an arbitrary 30% affordable housing requirement for the district. Yet this is not underpinned by either any recent Housing Needs Study or Strategic Housing Market Assessment to provide the necessary evidence base.

4.7.6

Reference is made to the Allocations DPD setting minimum figures for the number of affordable units to be completed on each of the sites specified. However, the precise number that can be delivered will be dependent upon site viability, the availability (or not) of grant funding, and other competing planning gain requirements.

4.7.10

The Council has set an arbitrary 30% affordable housing requirement for the district. Yet this is not underpinned by either any recent Housing Needs Study or Strategic Housing Market Assessment to provide the necessary evidence base. However, the precise number that can be delivered will be dependent upon site viability, the availability (or not) of grant funding, and other competing planning gain requirements. Thus the wording of the preferred option is contrary to PPS3 as it fails to take such factors into account.

4.9.9

design briefs - the HBF would query whether the Council can require a detailed design brief in advance of the submission of all major planning applications (rather than alongside the application for instance). It is not clear what the Council considers to constitute a 'major' application.

lifetime homes - The lifetime homes standard has no status as far as town and country planning legislation is concerned. PPS1: Delivering Sustainable Development states in paragraph 30 that "...planning policies should not replicate, cut across, or detrimentally affect matters within the scope of other legislative requirements, such as those set out in Building Regulations for energy efficiency". PPS12: Local Development Frameworks states in paragraph 1.8 that "...planning policies should not replicate, cut across, or detrimentally affect matters within the scope of other legislative requirements..".

The HBF considers that this is largely a matter already dealt with by way of Part M of the building regulations. Developers must, as a matter of law comply with the Building Regulations and they are subject to frequent change and update unlike local plans. The purpose of these references in the two Planning Policy Statements is to avoid confusion and potentially conflicting advice being given by different regulating authorities.

Thus whilst it may be appropriate for planning authorities to seek to negotiate with developers for a proportion of dwellings to be built to lifetime homes standards, it is considered excessive and unwarranted to require a specific percentage to be built to such standards.

I would draw your attention to an appeal decision concerning a reference to the provision of lifetime homes on land at former RAF Quedgeley, Gloucester. In paragraph 27 of the decision notice (see attached copy) the Secretary of State said that "it is not appropriate to include this matter, for the reason that the internal layout of buildings is not normally material to the consideration of planning permission. PPG3 gives advice about the assessment of need for housing for specific groups including the elderly and disabled".

No evidence base is put forward in order to justify the 25% lifetimes homes standard requirement.

Code for Sustainable Homes - The relationship between the Code for Sustainable Homes and planning policies being interpreted in an inconsistent way throughout England (and, indeed, Wales) is becoming increasingly problematic for the house building industry. In their attempt to be seen to be rising to meet the challenges set by climate change many regions, sub regions and local authorities are taking it upon themselves to try to move faster than the timetable attached to the Code for carbon reduction.

It is similarly curious as to how, or why, regional or local planning bodies could, or should, set their own carbon emission targets for the performance of buildings. The national application of the Code for Sustainable Homes quite clearly sets targets and milestones that together are a national trajectory, culminating in zero carbon homes by 2016.

Following on from the HBF summit on zero carbon homes, a Task Force was set up co-chaired by Yvette Cooper MP and Stewart Baseley (HBF Executive Chairman). It met for the first time on 31 January 2007. Alongside the HBF and DCLG, membership includes the Construction Products Association, the DTI, John Callcutt (in respect of his new housing review), WWF, the UK Business Council for Sustainable Energy and the Local Government Association.

Members of the Task Force will focus on work in relevant areas. HBF will lead on research issues, including those relating to housing and urban design. Our short-term objective is to reach agreement on a Concordat between the main parties, which can be published in the summer alongside the Government's final policy proposals on the timeframe and approach to zero carbon homes.

The HBF is extremely concerned that regions and local authorities are seeking to amend and shorten the agreed zero-carbon timeframe. It has written to Yvette Cooper MP reaffirming the point that multiple targets will critically undermine our prospects of achieving the Government's overall objective. It is crucial that this fact is taken on board. The 2016 Taskforce will, inevitably, want to address this issue as well since it is considered to be unhelpful and unnecessary for each region to set its own targets for implementation of the Code.

Fundamentally the Industry has signed up to a deal with the Government to achieve Carbon Neutrality within the next ten years. Local Authorities should also sign up to this objective in order for consistency and certainty with regard to long-term investment in new technologies and skills that will be essential in order to deliver Carbon Neutrality in the 10 year time-span envisaged.

Furthermore, Carbon Neutrality is best achieved through Building Regulations and not via unsubstantiated planning policies. In this regard the Code for Sustainable Homes has largely somewhat overtaken the Council's previous commitment to producing an Energy Efficiency SPD.

Technological innovation is moving rapidly in the sector of energy generation. It is, therefore, the HBF's view that planning policies should not try to "back winners" by specifying one type of technology over another in terms of types of energy generation or types of renewable energy generation.

Emerging practice is becoming confusing, in part due to a lack of sufficient clear guidance by central government in the context of energy policy. We have thus seen the emergence of myriad definitions used to calculate energy use of development proposals.

Planning policy should not be a tool to define and control what are essentially energy generation considerations. That is the role of national energy policy and regulation and the role of planning is to facilitate the delivery of the energy supply solutions that stem from national energy policy.

The debate over the benefits (and pitfalls) of on site, local, regional or national energy generation is still ongoing, as are the issues surrounding the long-term costs/benefits of individual renewable energy technologies. We believe the key in this field is a national strategic vision of how we can achieve an efficient low carbon energy supply for the country. Local authorities should not seek to second guess such thinking through adopting prescriptive local policies on energy supply. We also consider that the expert capacity to determine such matters is, in any case, not something that currently exists, especially within LPA planning departments.

It is, therefore, considered that planning policy should be concerned solely with removing barriers to the siting or development of new innovations such as wind turbines, CHP plants and other energy generation development. It should not seek to control the use of power within dwellings (since this would, in any event, be unenforceable) or be concerned with the fabric of the building, which is covered adequately by the Code for Sustainable Homes as discussed above.

There are many examples of such confusion arising in attempts by local authorities seeking to set and implement "Merton Rule" style policies for a proportion of "on site" renewable energy. Indeed, even Merton Borough Council relies solely on independent consultants reports to assess energy use of dwellings to calculate compliance with their 10% target for on site renewable energy. It is quite obvious that this issue is not one that can be adequately controlled through planning measures and is an example of how planning is being used to inadequately address issues that are better dealt with through other legislation and controls.

Planning does, of course, have a role to play in allocating sites suitable for the establishment of renewable technologies for energy generation, both in themselves (such as sites for large wind farms and district CHP plants) and in areas that may benefit from access to renewable sources for on site generation, such as sites near to biomass generation sites.

However, the debate over whether wind turbines are more or less efficient than photo voltaic cells, whether ground source heat pumps are more effective than solar heat transfer technology or other similar discussions should not an issue for consideration under planning powers available to local authorities.

In such a fast moving field of technological innovation planners and the planning system should be open to discussion about the most appropriate issues and solutions on a site by site basis rendering any blanket proportional target unnecessary and, indeed, potentially restrictive on emerging new solutions.

The HBF has very strong views on this subject matter. The Code for Sustainable Homes sets clear standards, and dates by which they need to be reached. It is therefore clearly inappropriate for Councils to seek to set their own alternative standards and requirements. It is especially inappropriate to do so via SPD rather than through the statutory process.

Planning and Climate Change (December 2006) has recently been published as a draft supplement to PPS1. The document supports the HBF's viewpoint that the draft PPS should clearly recognise the need for planning policy not to duplicate the role of national building regulations. It states in paragraphs 27-39 that in determining planning applications LPA's should ensure they are consistent with the PPS and avoid placing inconsistent requirements on applicants. Paragraph 30 says that with regard to the environmental performance of new development, planning authorities should "engage constructively and imaginatively with developers to encourage the delivery of sustainable buildings. They should be supportive of innovation".

Paragraph 31 of the aforementioned draft document states that "LPA's should not need to devise their own standards for the environmental performance of individual buildings as these are set out nationally through the Building Regulations".

Furthermore, it must be recognised that if carbon emissions are to be properly tackled then there needs to be a concerted effort to reduce carbon emissions from the existing housing stock, which is far less environmentally friendly than any modern housing now being built.

The Federation does not consider it appropriate for the Council to set its own sustainability standards for new development as these are set out within the Code for Sustainable Homes and Building Regulations. It is inappropriate for local authorities to replace national targets with there own particular standards. To do so is likely to hinder the delivery of more sustainable development, rather than help it. There will be no certainty or economies of scale for companies to take the investment steps necessary in order to ensure that new technologies can be developed and delivered to meet the targets outlined.

It is unclear as to why the Council should seek to require compliance with the minimum standards set out in the Code for Sustainable Homes via a spatial policy. The Code lies outside of planning legislation, and developers already have regard to it, as well as to Building Regulations.

4.11.6

The Council states that it wishes to push landscaping details to the fore of the planning application process and make them a prerequisite for determination for certain application types. It is unclear as to why the Council believes that it is no longer acceptable to deal with any landscaping issues by planning condition to be agreed after planning permission is granted. The appropriateness of such an approach in a Core Strategy is strongly questioned.

4.12.11

It is unclear as to why the Council should seek to require compliance with the minimum standards set out in the Code for Sustainable Homes via a spatial policy. The Code lies outside of planning legislation, and developers already have regard to it, as well as to Building Regulations.

It is stated that the Council will produce policies that require all new homes to be carbon neutral. There is no evidence as to how it will seek do this, or by when.

The Council also seeks to produce all sorts of other policies that seem incapable of being implemented given that they are seeking to control matters outside of the planning system, and or which are covered by other regulatory regimes.

5.

The section on monitoring fails to provide any detail on how it will be used to actually implement the Core Strategy so as to ensure that delivery is achieved. The Core Strategy needs to set the framework for the AMR by identifying key targets and indicators against which the LPA can measure the effectiveness of the strategy/policies and proposals.



Consultation

I look forward to being consulted on all future relevant DPD and SPD consultation documents (and any relevant background documents and studies) in the future, and would appreciate being notified in writing wherever these documents are being either submitted to the Secretary of State, or being Adopted.


I also look forward to the acknowledgement of these comments in due course.

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.

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

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.

On behalf of Aston Unit Trust and Mr J Needs, I enclose representations in respect of the Rochford Core Strategy Preferred Options.

As you will be aware from previous correspondence, my clients have a particular interest in land at Wellington Road, Rayleigh. Should you require any further information on this particular site or this batch of representations, please do not hesitate to contact me.

On behalf of Aston Unit Trust and Mr J Needs, I enclose representations in respect of the Rochford Core Strategy Preferred Options.

As you will be aware from previous correspondence, my clients have a particular interest in land at Wellington Road, Rayleigh. Should you require any further information on this particular site or this batch of representations, please do not hesitate to contact me.

POSITIVE COMMENT

LOCAL DEVELOPMENT POLICY - LAND at BULL LANE, RAYLEIGH
This representation is with regard to land at Bull Lane which has been put forward for release from Green belt for housing as a suggested and preferred site in answer to the Core Strategy Plan. This is an 11 acre field that is grassed and free of trees and buildings, it has also never had any farmer use for farm grazing or arable use. The land meets the criteria required as follows.

Policies HP8/HP9
As 1800 houses are required in Rayleigh alone; the land North of Bull Lane, Rayleigh which has been offered for building is in an ideal location. The plot of land is some 11 acres in size and will allow for affordable housing for local community needs as well as private residential development. It is very much suitable as it immediately adjoins the existing town in accordance to the criteria defined in Policy HP9. The release of the land would still allow presence of the openness of Green Belt. It would also not encroach on the "Green Buffer'' suggested in the councils preliminary publications.

The land North of Bull Lane is on the edge of town, with good access to:
Shops & Amenities
Local shops - a good range includes Butchers, Greengrocers, Post Office, Newsagents, Café and others, are all in walking distance of 0.4 mile

Town Shopping - Rayleigh Town Centre - itself with its wide range of shops is just 1 mile away.
The Local Park, Library, Community Centre, are also just a mile away.




Schools
Infants and Junior School are serviced by 'The Grove School' is 0.4mile distance from the site.
The Fitzwymark Senior School is local and just 0.5 miles away.

Travel Policy TP1
Roads - Bull Lane has a good road structure for traveling to Rochford - Southend - London- Chelmsford.

Buses - There are a variety of regular buses from Rayleigh which link the county in all directions, see attached routes.
Trains - The good train service carries passengers from Rayleigh to Southend and London directions.

Points raised here are within the East of England Plan, and for these reasons we believe that Bull Lane would be suitable for development.

POLICY TP1 - SUSTAINABLE TRANSPORT .

RAYLEIGH BUS ROUTES
A variety of regular buses from Rayleigh link the county .

NO BUS ROUTES RAYLEIGH PICK UPS
20 Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20C Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20X Southend-eastwood-Ray;leigh-Hullbridge BULL LANE
1 Rayleigh-Thundersley-Leigh-westcliff-Thorpe Bay-Shoebury Rayleigh Station
Rayleigh-Hockley-Ashingdon High Street/Hockley Rd
8 Rayleigh-Rochford-Southend-Thorpe bay-Shoeburyness High Street/Hockley Rd
9 Rayleigh-Eastwood-Southend-Thorpe Bay-Shoeburyness High St,Eastwood Rd
11A Southend-Westcliff-Rayleigh-Chelmsford Eastwood Road/Rayleigh Station

15,15A,15B,15C,16 Southend-Rayleigh-Pitsea-Basildon Eastwood Road/High St
Lower Hockley-Rayleigh-Southend High Street./Rayleigh Station
Southend-Rayleigh-Canvey

Metro 25 Southend,Rayleigh,Wickford,Basildon Rayleigh Station
35/35X Chelmsford-Great Baddow-Rayleigh-Southend Eastwood Rise/Rayleigh Station
Chelmsford-Rayleigh-Southend
200 Bradwell on sea-Maylandsea- Althorne-Sth Woodham-
Rayleigh-Southend Eastwod Rd,High St,Station
222 Southend-Rayleigh-Wickford-Billericay-Brentwood-Warley
825 Basildon-Westcliff High School-St.Thomas More School Eastwood Rise,Rayleigh Station
X30 Southend - Rayleigh- Stanstead Airport Rayleigh Station

Metro 25 BASILDON,BEACHAMPS SCHOOL,Southend Town Centre -Rayleigh Station

TRAINS
Local Railway station - direct to London - Southend
ROAD
It is easy to travel by road to Southend,Chelmsford, London with choices of routes to choose from.

POSITIVE COMMENT

LOCAL DEVELOPMENT POLICY - LAND at BULL LANE, RAYLEIGH
This representation is with regard to land at Bull Lane which has been put forward for release from Green belt for housing as a suggested and preferred site in answer to the Core Strategy Plan. This is an 11 acre field that is grassed and free of trees and buildings, it has also never had any farmer use for farm grazing or arable use. The land meets the criteria required as follows.

Policies HP8/HP9
As 1800 houses are required in Rayleigh alone; the land North of Bull Lane, Rayleigh which has been offered for building is in an ideal location. The plot of land is some 11 acres in size and will allow for affordable housing for local community needs as well as private residential development. It is very much suitable as it immediately adjoins the existing town in accordance to the criteria defined in Policy HP9. The release of the land would still allow presence of the openness of Green Belt. It would also not encroach on the "Green Buffer'' suggested in the councils preliminary publications.

The land North of Bull Lane is on the edge of town, with good access to:
Shops & Amenities
Local shops - a good range includes Butchers, Greengrocers, Post Office, Newsagents, Café and others, are all in walking distance of 0.4 mile

Town Shopping - Rayleigh Town Centre - itself with its wide range of shops is just 1 mile away.
The Local Park, Library, Community Centre, are also just a mile away.




Schools
Infants and Junior School are serviced by 'The Grove School' is 0.4mile distance from the site.
The Fitzwymark Senior School is local and just 0.5 miles away.

Travel Policy TP1
Roads - Bull Lane has a good road structure for traveling to Rochford - Southend - London- Chelmsford.

Buses - There are a variety of regular buses from Rayleigh which link the county in all directions, see attached routes.
Trains - The good train service carries passengers from Rayleigh to Southend and London directions.

Points raised here are within the East of England Plan, and for these reasons we believe that Bull Lane would be suitable for development.

POLICY TP1 - SUSTAINABLE TRANSPORT .

RAYLEIGH BUS ROUTES
A variety of regular buses from Rayleigh link the county .

NO BUS ROUTES RAYLEIGH PICK UPS
20 Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20C Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20X Southend-eastwood-Ray;leigh-Hullbridge BULL LANE
1 Rayleigh-Thundersley-Leigh-westcliff-Thorpe Bay-Shoebury Rayleigh Station
Rayleigh-Hockley-Ashingdon High Street/Hockley Rd
8 Rayleigh-Rochford-Southend-Thorpe bay-Shoeburyness High Street/Hockley Rd
9 Rayleigh-Eastwood-Southend-Thorpe Bay-Shoeburyness High St,Eastwood Rd
11A Southend-Westcliff-Rayleigh-Chelmsford Eastwood Road/Rayleigh Station

15,15A,15B,15C,16 Southend-Rayleigh-Pitsea-Basildon Eastwood Road/High St
Lower Hockley-Rayleigh-Southend High Street./Rayleigh Station
Southend-Rayleigh-Canvey

Metro 25 Southend,Rayleigh,Wickford,Basildon Rayleigh Station
35/35X Chelmsford-Great Baddow-Rayleigh-Southend Eastwood Rise/Rayleigh Station
Chelmsford-Rayleigh-Southend
200 Bradwell on sea-Maylandsea- Althorne-Sth Woodham-
Rayleigh-Southend Eastwod Rd,High St,Station
222 Southend-Rayleigh-Wickford-Billericay-Brentwood-Warley
825 Basildon-Westcliff High School-St.Thomas More School Eastwood Rise,Rayleigh Station
X30 Southend - Rayleigh- Stanstead Airport Rayleigh Station

Metro 25 BASILDON,BEACHAMPS SCHOOL,Southend Town Centre -Rayleigh Station

TRAINS
Local Railway station - direct to London - Southend
ROAD
It is easy to travel by road to Southend,Chelmsford, London with choices of routes to choose from.

POSITIVE COMMENT

LOCAL DEVELOPMENT POLICY - LAND at BULL LANE, RAYLEIGH
This representation is with regard to land at Bull Lane which has been put forward for release from Green belt for housing as a suggested and preferred site in answer to the Core Strategy Plan. This is an 11 acre field that is grassed and free of trees and buildings, it has also never had any farmer use for farm grazing or arable use. The land meets the criteria required as follows.

Policies HP8/HP9
As 1800 houses are required in Rayleigh alone; the land North of Bull Lane, Rayleigh which has been offered for building is in an ideal location. The plot of land is some 11 acres in size and will allow for affordable housing for local community needs as well as private residential development. It is very much suitable as it immediately adjoins the existing town in accordance to the criteria defined in Policy HP9. The release of the land would still allow presence of the openness of Green Belt. It would also not encroach on the "Green Buffer'' suggested in the councils preliminary publications.

The land North of Bull Lane is on the edge of town, with good access to:
Shops & Amenities
Local shops - a good range includes Butchers, Greengrocers, Post Office, Newsagents, Café and others, are all in walking distance of 0.4 mile

Town Shopping - Rayleigh Town Centre - itself with its wide range of shops is just 1 mile away.
The Local Park, Library, Community Centre, are also just a mile away.




Schools
Infants and Junior School are serviced by 'The Grove School' is 0.4mile distance from the site.
The Fitzwymark Senior School is local and just 0.5 miles away.

Travel Policy TP1
Roads - Bull Lane has a good road structure for traveling to Rochford - Southend - London- Chelmsford.

Buses - There are a variety of regular buses from Rayleigh which link the county in all directions, see attached routes.
Trains - The good train service carries passengers from Rayleigh to Southend and London directions.

Points raised here are within the East of England Plan, and for these reasons we believe that Bull Lane would be suitable for development.

POLICY TP1 - SUSTAINABLE TRANSPORT .

RAYLEIGH BUS ROUTES
A variety of regular buses from Rayleigh link the county .

NO BUS ROUTES RAYLEIGH PICK UPS
20 Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20C Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20X Southend-eastwood-Ray;leigh-Hullbridge BULL LANE
1 Rayleigh-Thundersley-Leigh-westcliff-Thorpe Bay-Shoebury Rayleigh Station
Rayleigh-Hockley-Ashingdon High Street/Hockley Rd
8 Rayleigh-Rochford-Southend-Thorpe bay-Shoeburyness High Street/Hockley Rd
9 Rayleigh-Eastwood-Southend-Thorpe Bay-Shoeburyness High St,Eastwood Rd
11A Southend-Westcliff-Rayleigh-Chelmsford Eastwood Road/Rayleigh Station

15,15A,15B,15C,16 Southend-Rayleigh-Pitsea-Basildon Eastwood Road/High St
Lower Hockley-Rayleigh-Southend High Street./Rayleigh Station
Southend-Rayleigh-Canvey

Metro 25 Southend,Rayleigh,Wickford,Basildon Rayleigh Station
35/35X Chelmsford-Great Baddow-Rayleigh-Southend Eastwood Rise/Rayleigh Station
Chelmsford-Rayleigh-Southend
200 Bradwell on sea-Maylandsea- Althorne-Sth Woodham-
Rayleigh-Southend Eastwod Rd,High St,Station
222 Southend-Rayleigh-Wickford-Billericay-Brentwood-Warley
825 Basildon-Westcliff High School-St.Thomas More School Eastwood Rise,Rayleigh Station
X30 Southend - Rayleigh- Stanstead Airport Rayleigh Station

Metro 25 BASILDON,BEACHAMPS SCHOOL,Southend Town Centre -Rayleigh Station

TRAINS
Local Railway station - direct to London - Southend
ROAD
It is easy to travel by road to Southend,Chelmsford, London with choices of routes to choose from.

POSITIVE COMMENT

LOCAL DEVELOPMENT POLICY - LAND at BULL LANE, RAYLEIGH
This representation is with regard to land at Bull Lane which has been put forward for release from Green belt for housing as a suggested and preferred site in answer to the Core Strategy Plan. This is an 11 acre field that is grassed and free of trees and buildings, it has also never had any farmer use for farm grazing or arable use. The land meets the criteria required as follows.

Policies HP8/HP9
As 1800 houses are required in Rayleigh alone; the land North of Bull Lane, Rayleigh which has been offered for building is in an ideal location. The plot of land is some 11 acres in size and will allow for affordable housing for local community needs as well as private residential development. It is very much suitable as it immediately adjoins the existing town in accordance to the criteria defined in Policy HP9. The release of the land would still allow presence of the openness of Green Belt. It would also not encroach on the "Green Buffer'' suggested in the councils preliminary publications.

The land North of Bull Lane is on the edge of town, with good access to:
Shops & Amenities
Local shops - a good range includes Butchers, Greengrocers, Post Office, Newsagents, Café and others, are all in walking distance of 0.4 mile

Town Shopping - Rayleigh Town Centre - itself with its wide range of shops is just 1 mile away.
The Local Park, Library, Community Centre, are also just a mile away.




Schools
Infants and Junior School are serviced by 'The Grove School' is 0.4mile distance from the site.
The Fitzwymark Senior School is local and just 0.5 miles away.

Travel Policy TP1
Roads - Bull Lane has a good road structure for traveling to Rochford - Southend - London- Chelmsford.

Buses - There are a variety of regular buses from Rayleigh which link the county in all directions, see attached routes.
Trains - The good train service carries passengers from Rayleigh to Southend and London directions.

Points raised here are within the East of England Plan, and for these reasons we believe that Bull Lane would be suitable for development.

POLICY TP1 - SUSTAINABLE TRANSPORT .

RAYLEIGH BUS ROUTES
A variety of regular buses from Rayleigh link the county .

NO BUS ROUTES RAYLEIGH PICK UPS
20 Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20C Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20X Southend-eastwood-Ray;leigh-Hullbridge BULL LANE
1 Rayleigh-Thundersley-Leigh-westcliff-Thorpe Bay-Shoebury Rayleigh Station
Rayleigh-Hockley-Ashingdon High Street/Hockley Rd
8 Rayleigh-Rochford-Southend-Thorpe bay-Shoeburyness High Street/Hockley Rd
9 Rayleigh-Eastwood-Southend-Thorpe Bay-Shoeburyness High St,Eastwood Rd
11A Southend-Westcliff-Rayleigh-Chelmsford Eastwood Road/Rayleigh Station

15,15A,15B,15C,16 Southend-Rayleigh-Pitsea-Basildon Eastwood Road/High St
Lower Hockley-Rayleigh-Southend High Street./Rayleigh Station
Southend-Rayleigh-Canvey

Metro 25 Southend,Rayleigh,Wickford,Basildon Rayleigh Station
35/35X Chelmsford-Great Baddow-Rayleigh-Southend Eastwood Rise/Rayleigh Station
Chelmsford-Rayleigh-Southend
200 Bradwell on sea-Maylandsea- Althorne-Sth Woodham-
Rayleigh-Southend Eastwod Rd,High St,Station
222 Southend-Rayleigh-Wickford-Billericay-Brentwood-Warley
825 Basildon-Westcliff High School-St.Thomas More School Eastwood Rise,Rayleigh Station
X30 Southend - Rayleigh- Stanstead Airport Rayleigh Station

Metro 25 BASILDON,BEACHAMPS SCHOOL,Southend Town Centre -Rayleigh Station

TRAINS
Local Railway station - direct to London - Southend
ROAD
It is easy to travel by road to Southend,Chelmsford, London with choices of routes to choose from.

POSITIVE COMMENT

LOCAL DEVELOPMENT POLICY - LAND at BULL LANE, RAYLEIGH
This representation is with regard to land at Bull Lane which has been put forward for release from Green belt for housing as a suggested and preferred site in answer to the Core Strategy Plan. This is an 11 acre field that is grassed and free of trees and buildings, it has also never had any farmer use for farm grazing or arable use. The land meets the criteria required as follows.

Policies HP8/HP9
As 1800 houses are required in Rayleigh alone; the land North of Bull Lane, Rayleigh which has been offered for building is in an ideal location. The plot of land is some 11 acres in size and will allow for affordable housing for local community needs as well as private residential development. It is very much suitable as it immediately adjoins the existing town in accordance to the criteria defined in Policy HP9. The release of the land would still allow presence of the openness of Green Belt. It would also not encroach on the "Green Buffer'' suggested in the councils preliminary publications.

The land North of Bull Lane is on the edge of town, with good access to:
Shops & Amenities
Local shops - a good range includes Butchers, Greengrocers, Post Office, Newsagents, Café and others, are all in walking distance of 0.4 mile

Town Shopping - Rayleigh Town Centre - itself with its wide range of shops is just 1 mile away.
The Local Park, Library, Community Centre, are also just a mile away.




Schools
Infants and Junior School are serviced by 'The Grove School' is 0.4mile distance from the site.
The Fitzwymark Senior School is local and just 0.5 miles away.

Travel Policy TP1
Roads - Bull Lane has a good road structure for traveling to Rochford - Southend - London- Chelmsford.

Buses - There are a variety of regular buses from Rayleigh which link the county in all directions, see attached routes.
Trains - The good train service carries passengers from Rayleigh to Southend and London directions.

Points raised here are within the East of England Plan, and for these reasons we believe that Bull Lane would be suitable for development.

POLICY TP1 - SUSTAINABLE TRANSPORT .

RAYLEIGH BUS ROUTES
A variety of regular buses from Rayleigh link the county .

NO BUS ROUTES RAYLEIGH PICK UPS
20 Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20C Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20X Southend-eastwood-Ray;leigh-Hullbridge BULL LANE
1 Rayleigh-Thundersley-Leigh-westcliff-Thorpe Bay-Shoebury Rayleigh Station
Rayleigh-Hockley-Ashingdon High Street/Hockley Rd
8 Rayleigh-Rochford-Southend-Thorpe bay-Shoeburyness High Street/Hockley Rd
9 Rayleigh-Eastwood-Southend-Thorpe Bay-Shoeburyness High St,Eastwood Rd
11A Southend-Westcliff-Rayleigh-Chelmsford Eastwood Road/Rayleigh Station

15,15A,15B,15C,16 Southend-Rayleigh-Pitsea-Basildon Eastwood Road/High St
Lower Hockley-Rayleigh-Southend High Street./Rayleigh Station
Southend-Rayleigh-Canvey

Metro 25 Southend,Rayleigh,Wickford,Basildon Rayleigh Station
35/35X Chelmsford-Great Baddow-Rayleigh-Southend Eastwood Rise/Rayleigh Station
Chelmsford-Rayleigh-Southend
200 Bradwell on sea-Maylandsea- Althorne-Sth Woodham-
Rayleigh-Southend Eastwod Rd,High St,Station
222 Southend-Rayleigh-Wickford-Billericay-Brentwood-Warley
825 Basildon-Westcliff High School-St.Thomas More School Eastwood Rise,Rayleigh Station
X30 Southend - Rayleigh- Stanstead Airport Rayleigh Station

Metro 25 BASILDON,BEACHAMPS SCHOOL,Southend Town Centre -Rayleigh Station

TRAINS
Local Railway station - direct to London - Southend
ROAD
It is easy to travel by road to Southend,Chelmsford, London with choices of routes to choose from.

POSITIVE COMMENT

LOCAL DEVELOPMENT POLICY - LAND at BULL LANE, RAYLEIGH
This representation is with regard to land at Bull Lane which has been put forward for release from Green belt for housing as a suggested and preferred site in answer to the Core Strategy Plan. This is an 11 acre field that is grassed and free of trees and buildings, it has also never had any farmer use for farm grazing or arable use. The land meets the criteria required as follows.

Policies HP8/HP9
As 1800 houses are required in Rayleigh alone; the land North of Bull Lane, Rayleigh which has been offered for building is in an ideal location. The plot of land is some 11 acres in size and will allow for affordable housing for local community needs as well as private residential development. It is very much suitable as it immediately adjoins the existing town in accordance to the criteria defined in Policy HP9. The release of the land would still allow presence of the openness of Green Belt. It would also not encroach on the "Green Buffer'' suggested in the councils preliminary publications.

The land North of Bull Lane is on the edge of town, with good access to:
Shops & Amenities
Local shops - a good range includes Butchers, Greengrocers, Post Office, Newsagents, Café and others, are all in walking distance of 0.4 mile

Town Shopping - Rayleigh Town Centre - itself with its wide range of shops is just 1 mile away.
The Local Park, Library, Community Centre, are also just a mile away.




Schools
Infants and Junior School are serviced by 'The Grove School' is 0.4mile distance from the site.
The Fitzwymark Senior School is local and just 0.5 miles away.

Travel Policy TP1
Roads - Bull Lane has a good road structure for traveling to Rochford - Southend - London- Chelmsford.

Buses - There are a variety of regular buses from Rayleigh which link the county in all directions, see attached routes.
Trains - The good train service carries passengers from Rayleigh to Southend and London directions.

Points raised here are within the East of England Plan, and for these reasons we believe that Bull Lane would be suitable for development.

POLICY TP1 - SUSTAINABLE TRANSPORT .

RAYLEIGH BUS ROUTES
A variety of regular buses from Rayleigh link the county .

NO BUS ROUTES RAYLEIGH PICK UPS
20 Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20C Hullbridge-Lower Hockley-Rayleigh-Eastwood-Southend BULL LANE
20X Southend-eastwood-Ray;leigh-Hullbridge BULL LANE
1 Rayleigh-Thundersley-Leigh-westcliff-Thorpe Bay-Shoebury Rayleigh Station
Rayleigh-Hockley-Ashingdon High Street/Hockley Rd
8 Rayleigh-Rochford-Southend-Thorpe bay-Shoeburyness High Street/Hockley Rd
9 Rayleigh-Eastwood-Southend-Thorpe Bay-Shoeburyness High St,Eastwood Rd
11A Southend-Westcliff-Rayleigh-Chelmsford Eastwood Road/Rayleigh Station

15,15A,15B,15C,16 Southend-Rayleigh-Pitsea-Basildon Eastwood Road/High St
Lower Hockley-Rayleigh-Southend High Street./Rayleigh Station
Southend-Rayleigh-Canvey

Metro 25 Southend,Rayleigh,Wickford,Basildon Rayleigh Station
35/35X Chelmsford-Great Baddow-Rayleigh-Southend Eastwood Rise/Rayleigh Station
Chelmsford-Rayleigh-Southend
200 Bradwell on sea-Maylandsea- Althorne-Sth Woodham-
Rayleigh-Southend Eastwod Rd,High St,Station
222 Southend-Rayleigh-Wickford-Billericay-Brentwood-Warley
825 Basildon-Westcliff High School-St.Thomas More School Eastwood Rise,Rayleigh Station
X30 Southend - Rayleigh- Stanstead Airport Rayleigh Station

Metro 25 BASILDON,BEACHAMPS SCHOOL,Southend Town Centre -Rayleigh Station

TRAINS
Local Railway station - direct to London - Southend
ROAD
It is easy to travel by road to Southend,Chelmsford, London with choices of routes to choose from.