4.12.11 Energy & Water Conservation & Renewable Energy Preferred Option

Why not construct all new dwellings to incorporate solar panels which would go some way to making the housing less of a burden on our national grid and environment? whilst this would increase initial costs for each unit sure the long term benefits cannot be ignored?

Whilst broadly supportive we think that reducing the need to travel, is too vague and in fact almost impossible. What is needed is reducing the distances that people travel.
The policy needs to be clear on transport, including transport within carbon neutral and ensuring that new developments encourage cycling and walking ahead of car travel.

The district needs a more integrated, cheaper and more frequent bus service to cut down on use of cars. Tickets need to be interchangeable between operators, bus stops should have timetables on display and indicators to show expected buses.

I agree.

The RSPB would recommend that the Council commit to ensuring all new homes meet a 3 star rating under the requirements of the Code for Sustainable Homes.

These issues are very important. In 60 years time this area could have a climate similar to Bordeaux, or even Lisbon. We could be facing a problem of permanent water scarcity long before that.

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.

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.

Policy Content

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

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

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

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

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

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

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

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

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

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

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

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


Future Process

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

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

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

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


2. MORE DETAILED COMMENTS

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

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

Spatial Vision

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

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

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

Green Belt

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

General development locations

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

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

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

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

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

Employment

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

Good design & design statements

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

Character of place & the historic environment

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

Energy & water conservation & renewable energy

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

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

- Use of renewable resources from sustainable sources.

- Impact of development on the environment and local amenity.

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

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

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

Compulsory purchase & planning obligations

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