Introduction

Please find attached our respresentations in respect of the Core Strategy preferred Options (October 2008) which have been submitted on behalf of our client (Aber Ltd).

In light of the econimic climate this whole policy should be reviewed and numbers downscaled. Which building companies will be left to build the properties and who will have jobs left to buy them. This should all be put on hold untill the economic picture becomes clearer.

HAWKWELL PARISH COUNCIL

RESPONSE TO ROCHFORD DISTRICT COUNCIL ON THE CORE STRATEGY.

GENERAL BACKGROUND:
Members of Hawkwell Parish Council have had some opportunity to consider the Core Strategy Document issued by Rochford District Council. Whilst we are grateful to the District for providing 6 copies, this is a very large document needing considerable time to read and digest. Limitation of our access to 6 copies means that each document has had to be studied by up to 3 Members thus creating time constraints that should not be suffered with such an important document.

We note that the objective of this exercise is, primarily, to allow residents to respond to the options that have been identified as preferred. However we wish to make a number of observations to assertions made in the introductory remarks.

We are concerned that we are being asked to respond before we have had a chance to consider the Allocations Development Plan Document that is to be issued shortly. Whilst many sites have been the subject of speculation we cannot respond specifically until we have had the benefit of the formal statement identifying the actual sites and numbers of property to be built thereon. We therefore require the Planning Authority to provide good opportunity for residents to consider specific sites prior to their approval.

LISTENING TO YOUR VIEWS.

1. Page 3: In response to the comment that there is too much residential development proposed in our village/town. You have said you have reconsidered the matter but have given no indication of your conclusions. Do you accept the assertion or do you reject it, and if so on what basis.
2. Page 4 Intensification: We are concerned that you have inserted the phrase as 'far as is practicable' yet in H1 you state that you will resist intensification on smaller sites. Is this comment also subject to the aforementioned caveat, if not what powers will you rely on to achieve this and why can you not resist intensification currently.
3. Page 8 Priority 5: You state that walking and cycling are to be encouraged. With the greatest of respect, with an ageing population (Core Strategy Document penultimate paragraph page 14) is it realistic to brush aside the opportunity to ease an already almost gridlocked transport system and ignore the additional pressure to be imposed by an additional 3.5K houses by expecting elderly people to walk or cycle everywhere? Though much of the transport congestion experienced in the district is from the district much of it is also traffic travelling from outside Rochford to Southend.
4. Page 8 Priority 6: You say you are committed to improving access to sporting facilities yet we understand you recently rejected a central government initiative to give free swimming to the older people in Rochford. This decision is set against an acknowledgement that the population of over 65's is increasing and is expected to outnumber the under 20s by 2015! This aspiration does not sit well with the insistence on franchising the public sporting facilities out to the private sector that charge high entrance/membership fees thus reducing the ability of fixed income people to make use of these facilities.

CHARACTERISTICS, ISSUES AND OPPORTUNITIES:
Page 20 Settlements: We are incensed by the failure to recognise Hawkwell as a settlement in its own right. As the biggest Parish (based on population) and second only to Rayleigh Town we have, in this report, apparently been subsumed into Hockley. Whilst you may argue that, at the recent Central Area Committee, residents expressions of concern about the number and locations of new houses was premature, we cannot help but feel that, as a settlement that is ignored in the Core Strategy, we are having little say in the allocations of housing to our parish.

HOUSING:
We now wish to make the following observations in response to the chapter on Housing:
General Observation:
It is stated on page 23 (penultimate paragraph) that a balance of 2489 units have to be delivered before 2021 and the total to be delivered by 2025 is 3489, this figure after allowing for the 1301 units identified by the urban capacity study. This represents a 10% in housing and whilst we fully endorse the need to re-use land (brown-field sites) and allow small infill developments where the impact on the local infrastructure can reasonably be accommodated, we cannot agree that finding locations for almost three and a half thousand new homes (or a 10% increase) should be addressed on the basis of cramming them into existing settlements. We suggest that this requires a much more strategic view and the piecemeal approach based on a 'call for sites' is totally inadequate. In our policy document sent to the Planning Authority in December 2007/January 2008, we supported the view that a new settlement should be developed where the infrastructure needs can be properly developed and accommodated and where the additional housing will have the minimum impact of existing overdeveloped settlements. We believe there is strong argument that a new settlement would be far greener and thus, in the longer term, more sustainable that a myriad of smaller in fill sites. This option must not be rejected out of hand as is currently the case

H1 Distribution - Preferred Option
We are concerned that whilst our Planning Authority has adopted a policy against the intensification under this preferred option, this is contrary to what is currently happening with the increase in the number of flats being approved and the number of plots being turned from single dwelling sites to multiple dwelling sites. We are currently told that such intensification cannot be resisted, how then will the new policy be enforced? That said we would support the limitation on intensification and require that new lower levels agreed be adhered to.

In the penultimate paragraph on page 26 (General Locations) it is asserted that you have adopted a balanced strategy in respect of the location of housing development, we cannot see how the emerging proposals for Hawkwell are, in anyway, balanced allocations.

H2 General Locations & Phasing - Preferred Option:
Members hold the view that our policy developed and forwarded to the Head of Planning and Transportation in January 2008 still holds good. A copy of our policy is attached. Our view is that the Core Strategy appears to distribute new housing development on an uneven basis. We hold the view, as clearly stated in our policy, that if additional housing has to be distributed amongst existing towns and villages then it must be done on a sensible and defensible base such as existing population or geographical size and not on the ad hoc base that the call for sites appears to have produced. We strongly object to being subsumed into a settlement called Hockley/Hawkwell and then being expected to take the lions share of new houses that the Core Strategy allocates to this pseudo-settlement. (as indicated by the table in H2)

We do not believe that the argument against Rayleigh taking more of the allocation as given in H2 Alternatives (top of page 29) gives any sensible basis for rejection of this option, if the comment 'best access to services' still holds good then it must be properly considered and not thrown out as a result of clamour from the Rayleigh lobbyists on the District Council.

Transport
The diagram provided on the last page of the document shows a heavy concentration of development within Hawkwell and Rochford. This will inevitably have an impact on Rectory Road, Ashingdon Road, Main Road, Hawkwell and Hall Road ensuring a triangle of congestion on all routes to and from our village.

We cannot help but feel that the options in this section are pious hopes with little real substance. Seeking contributions from developers for public transport provision is laudable but transport companies and developers are ephemeral, housing estates are less so. We have experienced the way the private sector has progressively withdrawn service from our village, what safeguards are offered to sustain this transport when the provider decides it is not profitable and withdraws the service?

T7 Parking Standards:
We are concerned by the decision to apply minimum parking standards in residential developments. The District has insufficient resources to manage the consequential bad parking that occurs with cars parked over pavements causing obstruction to pedestrians and traffic alike. It is not sensible to adopt such a policy without also properly evaluating the consequence and then resourcing the appropriate methods of enforcement.

RTC 4 & 5 - Preferred Options:
We understand from the various consultations that the Hockley and Rochford Town Centre Studies have not yet been completed and we would require that these are completed and properly considered before any decisions are taken.

Economic Development Preferred Options: ED1 to ED 4
Contrary to what is stated in the Core Strategy there is too much reliance on the development of the airport and its environs involving the release of green belt land to provide jobs, it appears to be assumed that the new residents of Hawkwell will work there thus justifying the large proportion of housing in or adjacent to our parish.

We feel the Core Strategy and the JAAP in respect of Southend Airport should be properly integrated so that recommendations are consistent.

Character of Place:
Hawkwell Parish Council welcomes the re-introduction of the local list.

Community Infrastructure, Leisure and Tourism:
CLT 1 Planning Obligations and Standard Charges - Preferred Option
We are concerned that the interpretation of sustainability has been insufficiently addressed and we request that any proposal for a specific site be accompanied by a clear and unequivocal statement of the results of the test of sustainability and that only developments where the assessment shows a clear positive result in respect of sustainability are approved. Furthermore we would request that each site is tested against the sustainability test developed for a 'new' settlement to allow a fair comparison of advantages and disadvantages.

We note that government policy is that 60% of the development should be on brown field sites and the balance on green field, the indications emerging from the Core Strategy document seem to have reversed the policy with the higher percentage on green field sites and the balance on brown field.

Thank you for consulting the Government Office on the Rochford District Council Local Development Framework Core Strategy Preferred Options Report.

As you are aware, we have commented in the past on earlier documents published in relation to the Rochford Core Strategy. In line with our earlier comments we consider that the document is well organised, comprehensive, set out in a systematic fashion and is easy to read and comprehend. The authority is to be commended for achieving this. We do though have some general comments and concerns as well as detailed observations that relate to many of the intended policies. These are set out in the paragraphs below.

Going forward under a revised PPS12

You will also be aware that on the 4th June this year CLG published a revised PPS12 along with revised regulations, which are now in place. The revisions are aimed mainly at streamlining the process further to help ensure that production of DPD's is able to happen as quickly as possible, whilst ensuring that public participation is effective and its results taken fully into account. As well as this, a key motivation of the revisions is to provide local planning authorities with greater freedom to determine the most appropriate way to prepare or revise DPD's. There is now more flexibility particularly in terms of consultation, where consultation on the DPD during the preparation phase of the plan is expected to be proportionate to the scale of the issues involved in the plan. On this basis, the regulations have now removed one of the formal stages of consultation - the preferred option stage. As well as this, the regulations now require that consultation and representations are made on a DPD before submission to the Secretary of State.

You should refer to the new PPS in taking forward this DPD, but essentially you will need to comply with the following principles in the PPS on:

• Participation and stakeholders (see section 4.20, 4.25 & 4.27);
• Not repeating national and regional policy (4.30);
• Being subject to a sustainability appraisal (4.39 - 4.42);
• Being justified, effective and consistent with national policy (4.36 & 4.44) and
• Being produced according to the timetable set out in the LDS to ensure that the DPD is produced in a timely and efficient manner (see section 4.53 & 4.54)

Further guidance, including examples of best practice, is provided in the Plan Making Manual, which may be accessed via the Planning Advisory Service's website: www.pas.gov.uk/planmakingmanual. Additional content will become available in further updates of the Manual.

The DPD must be prepared in accordance with the Local Development Scheme and in compliance with the Statement of Community Involvement and the Town and Country Planning (Local Development) (England) Regulations 2004 as amended, be subject to a sustainability appraisal, have regard to national policy and any sustainable community strategy for the area and conform to the RSS. To be sound, the DPD should be justified (founded on a robust and credible evidence base, and be the most appropriate strategy when considered against the reasonable alternatives), effective (the document must be deliverable, flexible and be able to be monitored) and consistent with national policy.

The key consideration before drafting the final DPD, is to be satisfied that the process of testing and refining of the options and consulting with key stakeholders has been undertaken adequately and satisfactorily in an appropriate and proportionate manner in relation to the issues arising in respect of this particular DPD.

Presentation of Options

There will be an expectation when the Core Strategy is submitted for examination, that the Council is able to demonstrate that it's decisions for deciding on certain options and ruling out others has been underpinned and informed by a robust Sustainability Appraisal (SA). I am surprised that there are not many references to the SA in the main text of the Core Strategy preferred options document, especially in the context of the presentation of options. It is not explicitly evident from reading the Core Strategy document, that the findings in the SA report support the Authority's preferred options and how decisions about the spatial strategy have been reached.

At submission, the Authority will need to be able to demonstrate that the DPD's policies represent the most appropriate response in all the circumstances, having considered all the relevant alternatives, and that they are founded on a robust and credible evidence base; and that all reasonable and deliverable options have been equally presented at the Issues and Options stage, all underpinned by relevant sustainability information and other evidence. In order to meet this requirement, we firmly recommend that the subsequent documents make explicit linkages between the SA process and the decisions on chosen options and disregarded options.

Habitats Directive

As a result of the recent European Court of Justice ruling in relation to the Habitats Directive, Local Planning Authorities are now required to assess whether an Appropriate Assessment (AA), the purpose of which is to assess the impacts of a land-use plan against the conservation objectives of a European Site and to ascertain whether it would adversely affect the integrity of that site, is necessary and to carry out the AA in the preparation of a DPD or SPD where it is required.

Replacement of Local Plan Policies

It is a regulatory requirement for the Council to identify which extant saved local plan policies will be replaced/superseded by the Core Strategy upon its adoption. We would suggest that any early consultation documents should give a broad indication of the extant policy areas likely to be replaced and the submission Core Strategy document to include this information in detail, perhaps as an appendix.

Consultation Statement

We remind you that when you submit the relevant DPD, you will be required to provide a statement setting out which bodies were consulted at earlier regulated stages, how they were consulted, and a summary of the main issues raised and how these have been addressed. It is important therefore that you document clearly the consultation that you are undertaking now, and in the future, to inform this requirement.

Specific Comments on the Rochford District Council Local Development Framework Core Strategy Preferred Options Document

• It might be helpful in the introductory paragraphs of your eventual Submission document to explain in slightly more detail, what has preceded the stage you have now reached (i.e. the earlier stages) in terms of the evolution of your Core Strategy, particularly in relation to the chronology and 'frontloading' (statutory consultees/stakeholders) including public engagement.
• You might like to consider whether in your Submission document you should distinguish what is in effect your 'Spatial Portrait' (i.e. term it as such) from the other information that forms the 'Characteristics, Issues and Opportunities' in the introductory section.
• On page 14 under population, I think you are suggesting that the average household size in Rochford is a function of the relatively large number of families which is a feature of the District's population structure. The way you have expressed it appears to be somewhat ambiguous to me and this section of text may therefore benefit from being expressed in a way that is simpler and provides for clarity.
• Under the section entitled 'Vision', the text referring to the latter seems to be based more upon the separate document 'Vision to Reality' that is referred to. In addition, the initial Vision Statement that is then set out as text amounts to little more than a 'Statement of Intent'. The way I feel the Vision should be expressed is in fact much like the way you have expressed it in text boxes at the start of each theme- based section that follows in the document. This is an unconventional way of handling the matter and consequently you will need to be satisfied that it is an appropriate method. Clearly though, I feel that the linkage between the section entitled 'Vision' and what is written subsequently in the initial text and later in the text boxes, is inconsistent and at present confusing (the Vision and the Objectives that follow from it, should set the scene for the Core Strategy policies and proposals, particularly in terms of time scales (which you do outline) local distinctiveness, the scale of development intended and its broad locations).
• The objectives as currently expressed are very general and not distinctive or 'spatially specific' to Rochford.
• Policy H1 - The spatial dimension to this policy is in fact provided by Policy H2 and therefore there should be a cross reference in the text of Policy H1 to provide this linkage.
• Some of the text boxes are clearly making reference in 'plain English/general terms' to the 'Evidence Base' (i.e. when not setting out the Vision) without providing a reference to the appropriate 'Evidence Base' document. Given that the 'Evidence Base' is listed in detail in the first section of the Core Strategy document, it might be helpful to devise a system of Codes, or similar, to provide for cross references from the text box statements to the appropriate 'Evidence Base' document in the earlier list (the same system could be used in respect of 'non-specific references' to the 'Evidence Base' in the main text).
• You should avoid repeating national policy within the Core Strategy. In some instances in the supporting text you actually reproduce sections of PPSs. It may be appropriate in such instances to refer to such policy in general terms (a text box is a good way of doing this) but reproduction of actual PPS text should be avoided. Where references are made in some cases within policy wording to national policy (PPSs etc.) then the policy must be re-written in the Submission document to remove such references. The Core Strategy can only interpret national policy, indicating how it is to be applied to the local area - it must not repeat it.
• Whilst the use of text boxes is to be commended in general, that on P42 contains text which is repeated in some of the main text virtually alongside it. This occurs elsewhere in the document and it should be avoided in the Submission document.
• Several policies (e.g. GB1, ED2) are expressed in terms of: 'we will seek to direct'; 'we will encourage'; 'we will ensure'; we will enhance' etc. Expressed in this way the policies amount to little more than 'statements of intent'. Such expressions beg the questions 'how?', 'when?', 'where?'; and 'what?' etc. The policies in the Core Strategy need to relate to firm actions (albeit 'criteria based' if appropriate) and if there are not clear intentions in relation to delivery, then it is not appropriate to include the policy at all. I accept that as currently written, the policies may be indicating what the 'preferred option' for the policy is, rather than expressing it currently in its final form.
• In policy ED3 other than mention being made of 'Baltic Wharf', the existing employment sites to be reviewed are not identified. In order for the policy to be 'spatially specific' the other sites should be identified.
• Other than mention being made in the supporting text that there is an identified requirement for 2 hectares of office space, there are not any allocations made in terms of quantum of floorspace, or land areas, to meet the jobs requirement for the District. Furthermore, a policy has not been developed in terms of the distinction between locational implications of different uses (i.e. B1, B2 and B8). The submission policy should provide a clearer articulation of the locational implications relative to employment use types B1, B2 and B8 including any relevant split of land requirements relative to the different uses.
• In policy ENV4 'large scale' development is not defined.
• You will need to ensure that the wording in respect of Policy ENV6 wholly accords with the PPS1 Supplement on Climate Change. At present the wording appears to suggest a greater level of restraint than that intended by national policy.
• When/what date will Code Level 3 in Policy ENV8 be introduced? What is your 'Evidence Base' (as required by virtue of the PPS1 Supplement) to justify (in terms of viability) introducing this requirement in Rochford?
• In respect of Policy ENV9, what is your 'Evidence Base' (as required by virtue of the PPS1 Supplement) to justify (in terms of viability) introducing this requirement in Rochford?
• Where is the contaminated land referred to in ENV10 to be found in the District? What are the broad locations?
• In policy RTC1 what is the amount of retail floorspace that is being directed to the stated locations?

• In policy CLT5 what are the standards that will be applied?

• In policy CLT7 what are the standards that will be applied?

• In policy CLT8 what are the standards that will be applied?

• The Key Diagram should preferably be located much earlier on in the document - it could even be located after the background section and preceding the theme based sections. It appears that some potential designations are missing e.g. AQMA's.

• It is important for a Core Strategy to set out a strategic housing trajectory, expressing the Council's broad expectations for the delivery of housing over the Core Strategy period. It is accepted that it will need to be done at a strategic level, since individual development sites have yet to be identified, but it could set out the general expectations for the broad quantum (in general terms) and sources of completions (existing commitment, unallocated urban capacity/windfall sites, brownfield allocations, Greenfield sites/urban extensions etc) over the plan's lifetime. The trajectory should preferably be in the form of a bar chart, or similar, setting out expected development rates and indications of which main locations in each year that development is likely to be forthcoming.

Conclusions

We commend you for the work carried out so far. Where any soundness issues arise, either through our consideration of the work done to date to comply with Regulation 25, or later, through our consideration of the further documents that you will publish to comply with Regulations 25 and 27, we hope that they can be resolved prior to the DPD's submission and subsequent examination.

The baseline for the housing land supply information should be the most recent, in this case 31st March 2007, as opposed to 2006. It is not clear why 2006/7 supply has to be estimated rather than based on completion records.

It is noted that the minimum balance for 2006-2021 is 2,489 whereas locations for just 2,500 have been identified. This does not allow for any non-delivery or slippage, and represents an over supply of just 11 units which is not in the spirit of minimum allocations as introduced in the East of England Plan.

I suspect the demand for housing in Rochford District has been vastly over-estimated. This view appears to be supported on page 15 of the Core Strategy Preferred Options document where it is stated that the average price for a detached property in Rochford is £300,000 but the average price for a comparable property throughout the whole of Essex is £397,976. Housing prices are governed by supply and demand so the prices achieved in Rochford indicate that there is considerably less demand here than elsewhere.

Full text
The Council is correct in acknowledging the advice in PPS 3, which requires authorities to plan for delivery of housing for at least 15 years from adoption of the Core Strategy. The draft Core Strategy provides for a plan period up until 2025, which suggests adoption being achieved in 2010. In order to allow for slippage in the programme or further revisions, which may become necessary, the plan period should be extended to 2026 to provide additional flexibility and to ensure a continuous fifteen year housing land supply is achievable.

The Council relies upon a 2007 Urban Capacity Study (UCS) as part of its evidence base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply is out of step with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment or SHLAA.

Whilst the Council has attempted to incorporate some of the components that comprise a SHLAA, it has not incorporated all of them and as such, the assessment cannot be regarded as a SHLAA in the correct sense. An important element missing from the "hybrid" assessment carried out by the Council is an assessment of the developability of the broad greenfield allocations identified. This omission is considered particularly relevant in Rochford, where 70% of the housing land supply is to come from greenfield sites. Without an assessment of the developability of the sites identified in the broad locations set out in H2, the CS may not be found sound.

Planning Policy Statement 3 Housing was published in November 2006 and it introduced the Strategic Housing Land Availability Assessments (SHLAA) as the Government's preferred means of assessing future housing land availability. Guidance on the production of a SHLAA was published by Government in July 2007. The Council could have delayed progress on the production of its CS for a short period and produced a SHLAA in accordance with the guidance. This would have removed any doubts with respect to the quality of the evidence base, on what is the central core document.

The Council now has an opportunity to rectify this flaw in its evidence base by carrying out a full SHLAA, between now and the publication of the Submission Core Strategy. By doing so, it will reaffirm the housing land availability data, which is the central pillar of the evidence base underpinning the Core Strategy.

I cannot find anything in the Introduction which sets out the Timetable for the whole LDF - beginning to end - the Timetable in the Statement of Community Involvement is out of date.

I also think that it would be helpful for the public to have been informed in this document when, how and where the outcome of this Consultation will be published and if they will be able see how their objections and comments will definitely change the proposals.

Are the public to be consulted again in the process? And are there any limitations on the basis of future consultations in terms of public representations and the ability of the public as a whole to see their comments carried through to an amended Policy?

Response to Core Strategy - Local Government Framework Oct 2008-12-24

Thank you for opportunity to comment on the above and I make the following objections.

HOUSING

I object to proposals in Preferred Options under this heading in following 10 paras.

Numbers. I object to ordained housing numbers. Up to 2025, East of England Plan requires 5,600 minimum, of which, after actual and projected completions, gives remainder of 4,700, based on current need - adult children wanting to leave home, break-up of relationships, population projected increase from 78,489 to 87,000 by 2020s. This is largely supposition. Even the original remainder of 3,500 to 2021 after projected completions is too many. Notional redistribution of numbers around District centres following last Core Strategy consultation is fruitless when one studies the map showing areas excluded from development due to: flood plain, SSIs, conservation etc which comprise the bulk of the District. The built area plus projected green belt release won't sustain it. Don't forget, based on history, post 2025 Government will require ever more notional numbers accommodated.

Population. Planning Services express fear of continued out-migration due to housing shortage. In fact much known such migration is caused precisely by over-development, families looking to move to roomier, less claustrophobic environments. It will be necessary to discourage inward migration by persuading other Local Authorities to make improvements to education etc.

Much is made of the old causing a housing problem. This is skewed logic. The under 20 age group will not fall. The Office of National Statistics has reported a further baby boom commenced 2001 - an increase. The over 65 population will increase solely because the ageing earlier baby boom generation mostly under that age now will join them, but that doesn't increase population. The 24 to 64 age group will lose at the top and gain at the bottom.

In this connection complaint is made of the old hanging onto houses instead of down-sizing to so-called sheltered housing and allied ghettoes. If over-65s are found a problem, Third Reich had a solution that should appeal to EEDA: they could set up termination camps, with double benefit: get rid of them and clear their homes for redevelopment.

It should be pointed out much over-large new build market housing is for upwardly mobile, but middle and old aged persons from elsewhere, whose children have left home. An estate of 5 such units houses 10 persons. Some mansions are built or bought purposely for one person.

Distribution/General locations. I appreciate new concern with 'town cramming' and note view that Government target of 60% on 'brownfield' land is unrealistic (that damage already done) and that you propose much less. If this can be done with one Government target, why not cut down others?

I regret, however, that the newly restrictive approach against town cramming does not apply to 'windfall' development - very much of that has been done - over-dense, out of scale with existing dwellings, particularly in Hockley.

In this respect I'm sceptical of your new good intentions, as revised Urban Capacity Study 2007 notes 'intensification of existing residential land has made significantly larger contribution to housing figures than other forms of development..'.

Presumably the proposals listed under H2 and H3 are based on the 'call for sites' letter 2007 and have been offered by developers. The total for south Hawkwell of 350 to 2025 is over the top in relation to impact and land availability. It is bounded by over-busy B1013, former country lane. New roads required for it will mean compulsory purchase and some green belt residents will have to go.

Hockley seems unusually favoured with 50 units, but only as officials know well that windfall development will continue without restriction, as in the past, so no need to overdo target.

Core Strategy Preferred Options is a blank cheque, exact locations to be given in later allocations document.

AFFORDABLE HOUSING

I object to outlined proposals as follows. The noted dire shortage, with waiting list of young looking to leave home, etc, has resulted from shed loads of council housing having been sold off under the Thatcher Government in 1980s, or you would not need this genre. Council housing was meant for two sections: first those who would never be able to afford a mortgage and should not be pressured to do so; secondly, first-timers who could not initially afford ownership, but with aid of cheap rent could save over time for a deposit on their own place.

CHARACTER OF PLACE AND DWELLING TYPES

I object to proposals for reasons in following 7 paras.

Traditional. It is noted that the District 'has character, appearance, much of which stems from traditional buildings that still dominate towns and villages'. Unfortunately, as I noted under housing, much of that has been eliminated, many remaining dwellings now threatened with same, as Locally Listed buildings and their environs have gone, especially in Hockley, though Rochford, Rayleigh, small settlements have been reasonably well spared in this respect.

Intensification. Rochford District recognises defects of intensification of residential areas and proposes limiting redevelopment not in keeping with density and character of the area. But failure to clarify that those terms both mean not only destruction of heritage, but replacement with edifices out of scale in bulk, area, height, will lead to jeopardy of existing homes. Some new build may be out of character, but might be acceptable if not out of scale. Planning Services have been known to decide planned over-large buildings comply with density - they might do numerically, but are over-dense proportionally.

Strategic Housing Market Assessment is happy for market housing to be out of scale with existing: '...recommends Local Authorities don't set rigid requirements for size of dwellings, particularly...market housing, market is adept at matching dwelling size to market demand at local level'. Precisely. The upwardly mobile private sector have no regard for others and want multi-bedroomed dwellings massively out of scale with neighbours (who are often unfortunate to be north of them) plus all sorts of intrusive security systems to match. This should be resisted.

Planning Policy Statement 3 states: 'Design which is inappropriate in its context and which fails to take opportunity for character and quality of area should not be accepted. Development which is not inclusive and does not fit with surroundings..'. This is just what the typical 'executive' house, in gated site, 'town' house (also 3 storey where locale is 2 storey), flats etc, encouraged for Hockley has done. So clearly Government dictate has not been followed in this regard.

Character of place. Much has been made of the idea that, unlike Rochford, Rayleigh, the small settlements, Hockley village is not where once sited - around Hockley Church a 12C Listed building, but is a construct arising with the railway in 1887, all growth haphazard and dated subsequently, having no heritage value. This is inaccurate.

The road from Rayleigh to Rochford, via Hockley was a country lane. What is now B1013 was made a toll road in 18C for coaches, which is why it by-passed the church. To my certain recollection a dozen period houses, as good or better than Rochford's, from Marigold Corner (Hawkwell end of Hockley hill) to the Spa Hotel, dating 17C to 19C, have been destroyed since c.1975 for redevelopment.

4 Tiers. Core Strategy proposes dividing District settlements into 4 tiers of graded sustainability for more housing, those in the 4th tier being thought unsuitable. No wonder such places as Paglesham, Foulness, Stambridge have closed schools, churches, for lack of people.

MATERIALS

My objections here should be included in those under Character of Place. Core Strategy notes 'modern standardised building materials and design have begun to erode character of the District'. That is very true: there is a new element of hard sell by contractors, who want to replace traditional work, materials, with eg. Plastics, spray paint, steel. Personally, to avoid this I have had to engage a contractor specializing in heritage work to do standard painting, repair of external cast iron, timber work. Formerly, any general building would have done the work required as asked without argument.

It is a joke that design is expected to be sympathetic to locale and in-house building styles to fit local setting, not other way round. It is too late. Developers have strived to spoil local setting precisely to jeopardise existing housing, so it can be acquired for redevelopment.

LOCAL LIST

I list my objections to proposals for preferred options under this heading in following 6 paras.

I note Rochford District Council dropped Local List just prior to enabling demolition of Black's Farm (1 Southend Road), which was on that list, a house and garden that certainly conformed to 'local distinctiveness and [central to] a cherished and local scene' in Hockley.

The List was ostensibly dropped as, so a former Planning policy Manager said, 'Government frowns on such Lists'. Other councils, unaware of that, retained theirs. His comment to an Inspector on objection to proposed flats redevelopment of 1 Southend Road 'Just politics, lot of local interest, nothing of character in that area', presumably presaging his plans for the area. He also remarked on intended replacement 'flats sell well' - not a planning consideration. Surprise, surprise! As soon as the item was successfully demolished, we learned more recent Government guidance encouraged Local Lists! 'There is now positive encouragement from Government in recent White Paper for such Lists and we propose to reintroduce one for the District'. How disingenuous can you get.?. Were they holding it back, then?

It seems to me where Hockley is concerned notional land values for developers are more important than anything standing on it. In fact a former councillor once said exactly that.

An adviser proposed an Article 4 Direction be served for 1 Southend Road (an embargo on demolition while listing is considered. If it fails, compensation may be payable to the developer by council). The council refused because of that risk. English Heritage, well documented, as also Dept. of Culture, didn't visit, but left the matter to Essex County Council heritage department, who were inevitably not interested from scratch. After all was too late, English Heritage even advised another time one should get a period building under threat put on the Local List! Meanwhile in the time when 3 Hockley period houses were demolished for redevelopment, including No1, there was sickening sight of several Rochford buildings under repair 'sponsored by English Heritage' and other funded organisations. In Rayleigh large sums of public money, including from Thames Gateway, Lottery, were spent on schemes such as the Mill. And to think the council begrudged an unlikely financial risk in respect of Article 4 on 1 Southend Road Hockley.

I insist that a draft Local List be issued for consultation for ALL residents, which right to propose or refuse what goes on it. If, as suggested in earlier Strategy document, new development is to be included, then all adjacent properties are to be included as a conservation area.

Heritage, etc, Award by RDC. In view of all the above, there is hypocrisy in this scheme for heritage style redevelopment. Period houses now demolished, are replaced with out of scale pseudo-period redevelopment, particularly, as a planner said, on 'important, significant hill top, hillside sites' (money) such as Etheldore Avenue and Southend Road. These are of doubtful marketability, but this award is a pretence of concern with heritage to hide the real facts.

INFRASTRUCTURE AND TRANSPORT

I list objections to proposals under this heading in following 5 paras.

Standard Charges. Though I welcome proposals at CLT 1 for developers to pay towards the problems caused by their plans, it is a pity these are not to be set at a realistically punitive level to discourage them from excessive schemes. It has been suggested if a developer won't provide required infrastructure, opportunity will be given to another who will. But what if first developer already owns the site council is keen to see developed? Also, there is still a risk that retention of S.106 Planning Agreements will cause developers to buy Consents they might not otherwise get.

South Hawkwell building proposal. Re H2 alternative options, namely N E Hockley thought unviable for development due to impact on highway network of traffic heading through/out of Hockley to Ashingdon, but development south of Hawkwell found better placed in relation to highway network and employment growth at Southend Airport - this is grossly illogical.

I certainly don't support further development for N E Hockley. It is already burdened by Etheldore/Wood Avenue, Broadlands estate and much new else, and appreciate Greensward traffic, though less than main roads, does meet extra traffic traversing Lower Road. But to suggest that B1013 through Hockley and Hawkwell, busiest B road in UK, carrying 2000/hour quiet times, gridlock at peak times, now threatened by vast economic expansion proposal at the airport, is a suitable venue for 330 extra dwellings in south Hawkwell is ludicrous. Since opening of Cherry Orchard Bypass, all area traffic has been directed through Hockley and Hawkwell to Southend on B1013. B1013 (like the above roads) is a winding country lane. It has been hinted there will be new roads - where, and will this also involve compulsory purchase?

Highway improvements. I note these are under consideration to serve new developments, particularly to cast-west routes. Please do not subject home owners along B1013 winding lane to compulsory purchase of frontages to effect highway efficiency. This was done to owners on both sides of that road along Southend Road on Hockley hill in the 1960s. Apart from loss, speeds increased, accidents occurred and owners have had on-going problems. Any more and owners would lose homes as well.

Public transport improvements. Presumably as Standard Charges, are envisaged for new development at H Appendix 1 and CLT1. You need to watch crafty manoeuvres by services to get more money this way. For example, it is not coincidence that, since the revised Core Strategy consultation, with proposed large developments for Hawkwell, Ashingdon, Rochford was issued, Arriva bus company propose cutting back further their already abysmally poor Nos 7 and 8 services, presumably as ploy to get more money to reinstate them. Don't forget also that, unlike eg a community centre, classroom etc once provided a bus service is on-going. What happens to bus service when the builder has made his profit and moved on?

RETAIL AND TOWN CENTRES

I list my objections to proposals in Core Strategy under this heading in following 5 paras.

'2008 Retail/Leisure Study shows significant leakage out of the District...[should] direct retail development to town centres: Rayleigh/Rochford/Hockley'. You should understand Hockley has always been a village, traditionally having staple day-to-day shopping needs, eg grocers, butchers, bakers, fishmongers, greengrocers, haberdashers, hardware, newsagents, pharmacy, shoemenders, post office, building society or bank. Hawkwell also has a small shop parade with similar basics. At most, a modest extra supermarket might be set in the industrial estate in Eldon Way.

Regrettably, several prime Hockley units have become occupied by numerous estate agents. These should be reduced to two. An instructive example follows: in late 1980s, with already 6 agents, owner of one unit wanted change of use to estate agent. Planning Services refused on grounds it would be one too many. He appealed and won. In 1990 recession he closed, as did all the rest bar two, proving for once planners were right. A number of trivia shops have also arisen, which last a short time.

Residents have always expected to travel to Southend for furniture, clothing, large DIY stores other than hardware, bathrooms etc. This is NOT going to change. Any attempts have failed.

You need to understand there won't be any 'national multiples' in Hockley. Presumably Eldon Way industrial estate was considered a possible venue. The crowds and traffic would build up further in Spa Road, already a bottleneck. Remember your point that further housing for NE Hockley would increase traffic impact passing through Hockley. Also how would this fit with possible plans for extra housing in Eldon Way?

I have heard central Hockley central area might be regenerated. That will be resisted; there must be no demolition or compulsory purchase here, where there are listed and period buildings, too many of latter have been destroyed in Hockley already, intentionally to change its character.

There is also no space for large multiple stores in either Rayleigh or Rochford, which would be damaged. Southend High Street and Hamlet Court Road are ideal for large scale shopping.

ECONOMIC DEVELOPMENT AND EMPLOYMENT GROWTH

I object to proposals in Core Strategy preferred options as follows. 'East of England Plan specifies the number of jobs any sub-region must provide'. Apart from the airport, Rochford District is not within Thames Gateway and EEDA are not qualified to dictate 3000 jobs must be found. EEDA's idea the airport will generate large employment is unrealistic - jobs from this will be temporary.

Many attempts have been made to 'reduce reliance on out-commuting' without success. Vide the empty office blocks in Southend once occupied by eg Willis Faber, C E Heath & Co., Prudential, CU - all now elsewhere. You cannot replicate London employment in Rochford.

EDUCATION

I understood 'new residential development' was for extension of existing population, not meant to 'result in more people living in the District' already overcrowded. I'm surprised Hockley isn't expected to generate additional educational needs. I conclude the new upwardly mobile moving to executive mansions from elsewhere get their young tutored at private prep schools in Southend to pass the 11+ and get into Southend grammar schools. It should be noted parents have for years had a problem getting their children into any of the 3 overcrowded primary schools.

HEALTHCARE

It seems appropriate to propose under CLT4 that 'new developments be accompanied by a Health Impact Assessment... and developers be required to address negative effects prior to development implementation'.

Having, with other existing neighbours, experienced deafening noise 7am to 7pm 7 days per week for several years, polluting and furnace heating fires, daylight denying and night dark removing huge edifices in course of adjacent development, there is a definite impact on health by development.

PLAY SPACE

I object to preferred options proposals under this heading for following reasons. I thought Strategy said RDC would be abolishing practice of removing homes and gardens to get greater density. Gardens for children are essential. Even if out of sight, they are within earshot of adults. I note couples with small children are usually keen to have a place with garden. Communal play space advocated under CLT7 means children must be escorted. There is one on Hawkwell green, adults not permitted to enter.

AGEING POPULATION

I object to preferred options comments here. Core Strategy is obsessed with this. It is nonsense that ageing population leads to a smaller workforce with higher dependency ratio. Many persons of retirement age forced out of jobs by the baby boom continue to earn a living if allowed to do so, well beyond retirement.

Final insult under Youth Facilities '...ageing population (which could lead to increased demand for health and social care, rather than services for youth) it is important....needs of young people...catered for..'. The old, as well as striving to keep economically sound, also take steps to remain healthy and so are no more a burden to NHS and social services than younger groups.

As I said under Housing, if you feel the old are in the way in various ways, EEDA could clear them with termination camps.

PROTECTION, ENHANCEMENT OF LANDSCAPE AND HABITATS

I object that landscape and gardens in built area gardens have been excluded.

This is laudable, but it should be noted that landscape and habitat are also found in local gardens. Any wild life if found in same would need protection - definitely not translocation as at Etheldore Avenue etc, with unfortunate results. Developers have been known to drive protected wildlife out ahead of building and Rochford Woodland office to designate flourishing hedgerows 'dying, diseased'. So I object to landscape and habitats in gardens, built area being omitted from preferred options here.

CONCLUSION

I appreciate all this sounds negative, but development and inward migration ideas are out of hand.

Greenbelt. The perceived need to release some and recognition that existing settlements have increasingly limited space for further development clarifies that further government/developer demands must now be resisted. S E Essex is overcrowded and too small for further incursion.

Flood risk. Practically all Thames Gateway is a flood basin. From RDC map, most of the District is either at flood risk from N. Sea, rivers Crouch, Roach or else enjoys special protection. Permeable pavement is a good idea to stop surface flooding from paved residential frontages (now needing planning permission), but another problem is the many drainage ditches that have been filled in in residential and other areas.

Car dependency and congestion will continue with any population growth.

Energy consumption. Small wind turbines don't produce relevant energy. Most homes don't have cavity walls (doubtless an excuse for demolition as not sustainable).

In sum, I object to Core Strategy preferred options as further extensive development in Rochford District cannot be contained.

I apologise for responding so late to your Core Strategy Local Development Framework document. It is obvious that considerable effort has gone into preparing it.

I noted from one of the other reports that people are attracted to the Rochford area because of the rural nature, relative quietness and cleanliness. Basically the quality of life. A sentiment shared by many in the District.

Although I am focusing on the overall strategy I support wholeheartedly the efforts Hockley Residents' Association are making for that region.

HOUSING AND EDUCATION.

I do not understand the Housing assumptions. I have been advised by RDC that the driver for the additional houses is the population growth and that is centred on the over 65 years. There is no mention as to whether this change requires a strategic response in terms of the number of retirement and care homes. The under 20 population is projected to fall, and the over 20 to 64 to remain stable. Looking at the period beyond 2021 it is stated that 251 homes a year will need to be built. These homes will obviously be constructed on Greenfield sites if the current proposed strategy is continued. Yet given the under 65's falling or stable numbers the population overall should be reducing as people die.
The population is to increase by 5300. The house build is approximately 3500 of which around one third will be for affordable housing. It is assumed that this housing will be flats or terraced properties used at least in part to address the issue of 'concealed housing'. Depending on how much of the 5300 includes people not needing a property e.g. births, and how much the growth needs to be adjusted for the 'concealed housing' factor a ratio of between 1+ and under 2 people per new house is computed.
The strategy sets out a plan for a growth in the number of Primary Schools. I found this proposal surprising. Until three years ago I was a School Governor. The Essex CC projection at that time showed an ongoing trend for falling numbers of primary school children. In addition most schools had capacity. As an example Doggetts in Rochford had 100 children when a few years before they had well over 300.

Questions

I) Given the ageing population why is there no consideration to their housing needs?
II) Why are 251 homes needed each year after 2021?
III) What percentage of the existing Greenfield site available in 2021 will the 251 houses utilise if the current strategy is extended?
IV) The average occupancy of the planned homes could be as low as 1. Why are houses to be built on the assumption of a lower occupancy rate than currently actually exists in the District?
V) The Strategy declares that 'there is a question mark over the long-term viability over many of the smaller schools in the District'. Has any consideration been given to a 'change of use' of the land to housing?

EMPLOYMENT

The strategy states that 70% of working residents work outside the District. Rochford is in a commuter belt surrounded by three towns and a major hospital. The job density ratio is unsurprising given the location. No mention is made in the report of an estimate of the split of the 3000 additional jobs between those filled by people in the District, those filled by those moving into the District and those filled by people commuting into the District. This data would be useful in assessing the impact on infrastructure needs.
It would appear from the Strategy assumption and comments in the local paper that the Authorities accept the Airport expansion with attention focusing on mitigating the impact of night noise etc. Airport growth supports the aims of increased employment (much of which may be satisfied from outside the District) and local regeneration. Against it is set environmental issues, increased carbon footprint, and infrastructure issues like increased traffic. It is felt that there is a majority of residents against a major development of the Airport.
Within the Plan the comment is made of 'care in the home', and emphasis put on Lifetime Homes. There appears to be no strategy for developing a labour force to provide the increasing in house support to the growing elderly population.

Questions

i) Of the 3000 created jobs what percentage is anticipated to be filled by new people moving into the District, and what percentage by people commuting from outside the District?
ii) Will the wishes of the residents regarding the three options for the Airport be adopted even if the minimum growth route is preferred?
iii) There will be a growing market to provide support to the elderly at home. Why is there no strategy to develop a labour pool to satisfy this need?

INFRASTRUCTURE.

The aspect of infrastructure support to the various projects is vague. Perhaps this is understandable given the extent of the developments across the District and the difficulty of appreciating the overall impact that the sum of these could have. There is also the challenge of getting the enhancements done and determining who pays?
Rather than considering the whole spectrum of services an examination of the issues surrounding Transport indicates the obstacles that have to be overcome. More houses, jobs, leisure facilities, airport expansion etc. will increase traffic on the roads. The laudable ideas of improving public transport could have some affect, but the convenience, comfort, time, and load carrying capacity of a car will be a major barrier. One has to question the achievability of the aspirations in the strategy. It is stated that 'there will be no new major highway developments, the District is not included in the current SERT proposals, limited public transport results in congested routes, but improvements to public transport cannot provide the solution to the District's transport issues'. The ideas of car pools, walking trains, cycling etc. have all been considered before.
The focus is on the car and there are no proposals to deal with lorry transportation. Any regeneration will increase this mode of transport that is more damaging to roads.
The infrastructure support for new developments is imprecise. Statements that these are 'to be accompanied by the requisite highway improvements' and 'achieved by planning obligations, developers, and a partnership with Essex CC' are arguable.

Questions.

I) Why are lorries not considered in the Strategy?
II) In granting planning permission for any development will the Council require the infrastructure agreed to be completed first e.g. before building a house?
III) Where is the money to come from to support the infrastructure needs?

RISKS

No mention of risks or priorities is mentioned in the Strategy. The current economic climate will restrict funding, and the lack of a cogent infrastructure plan threatens the quality of life in the District.

Questions.

i) What are the risks associated with achieving the Strategy?
ii) What is the plan to deal with these risks?
iii) If the Strategy cannot proceed in its entirety which items will be given priority?

SUMMARY

It seems strange that the elderly sector, which is causing the population growth, sees little consideration in the strategy for housing, or in generating support from the labour market for their future needs. Presumably 'concealed housing' and 'affordable housing' are the reasons for the lower than average new build occupancy rate. Shortly with the direction of the Plan all new houses will be built on Greenfield sites.

Any major expansion of the Airport will add to the infrastructure problems of the area, and dilute those features of the District that are so attractive to residents. More emphasis in the Strategy should be given to employment diversification through 'the expansion of uses around the Airport not directly related to aviation'. It is expected that people outside the District will fill the majority of the new jobs created.

It is the infrastructure strategy that seems the least viable. The proposals are 'woolly' and lack substance. Transport policy which has it's own section in the report is focused primarily on stopping people using their cars. The other major road users of lorries and vans seem to have been totally ignored. Any Airport expansion without major infrastructure addition e.g. A127 will be seriously detrimental to the 'quality of life'.

The future economic climate for the Country looks quite horrible. Lack of funding could be the biggest threat to the Strategy. Lack of infrastructure the biggest impact on residents' lifestyles.

Representations on behalf of
Swan Hill Homes Limited
RESPONDENT NUMBER: 5040

1.0 Instructions and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Preferred Options (October 2008) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations in the Preferred Options document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the preparation process and we look forward to the opportunity to comment further at the Submission Version stage. Prior to the assessment of the Core Strategy Preferred Options (October 2008), Swan Hill had serious concerns regarding the way the document had been prepared. The lack of clearly defined policies meant that any policies would have only appeared in the Submission Version of the document, giving the Council no opportunity to make amendments, and limited opportunity for Consultees to see the exact policy position of the Council. It is considered that this Revised Preferred Options document has addressed this position, and enables Consultees to examine further the proposed position of the District Council, and the direction with which they are seeking to take their Core Strategy.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

Charles Planning Associates Limited
1644-1645 Parkway
Solent Business Park
Whiteley, Fareham
Hampshire
PO15 7AH

Tel: 01489 580853
Fax: 01489 580913
E-mail: peter.kneen@charlesplanning.co.uk

2.0 Housing:

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements on greenfield sites, particularly in the most sustainable locations. Swan Hill supports the approach that green field land on the edge of settlements that are released for development should not have a significant impact on the characteristics of the Green Belt, and that densities are in line with the objectives of PPS3 and reflect the local character of the settlement to which the extension is proposed.

Policy H1 - Distribution

2.3 Swan Hill generally supports the approach taken by the Council in this preferred option. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advise in PPS3.

2.4 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that 70% of new residential properties will need to be on sustainable greenfield urban extensions to the existing settlements of the District.

2.5 As such, it is essential within the Core Strategy to establish general locations suitable for the expansion of settlements into the Green Belt. This should not be as site specific as determining the exact parameters of settlement expansions, but should include a general assessment around settlements where development could be accommodated without conflicting with the objectives of the Green Belt. Swan Hill considers that the Council has had regard to these implications in this version of the Core Strategy, and supports the overall distribution policy set out by the District Council.

Policy H2 - General Locations and Phasing

2.6 As set out above, Swan Hill supports the overall approach the Council has taken in this revised version of the Core Strategy, which has both recognised the need for sustainable green field urban extensions in addition to the recognition of the most suitable 'general' locations for such extensions.

2.7 Swan Hill considers that the level of provision for the Tier 1 and 2 settlements (Tier 1: Rochford/Ashingdon, Hockley/Hawkwell and Rayleigh; Tier 2: Great Wakering and Hullbridge), which represents almost 98% of the proposed urban extensions, is appropriate, particularly given that these settlements either benefit from established services and facilities or are located within good proximity to the important service centres surrounding the District, principally Shoeburyness and Southend. This approach, as also set out in the supporting text to Policy H2 would help ensure that the second and third tier settlements remain viable rural settlements, supporting their local communities.

2.8 Additionally, Swan Hill welcomes the recognition that the provision of development on larger sites, in these first and second tier settlements can positively contribute to infrastructure provision, particularly in areas where there is an identified need for improvements.

Policy H3 - General Locations Post 2021

2.9 Swan Hill supports the general principles of this policy, and that the Council has sought to make provision for a 15-year supply of housing land supply, from the date of adoption of the document, as set out in PPS3.

2.10 Policy H1 of the Adopted RSS, East of England Plan sets out a requirement for the remaining 5-year supply, beyond 2021 to be based on the higher amount of the annual average for the period 2001 to 2021 or 2006 to 2021, whichever is higher. Based on this assessment, the 5-year period beyond 2021 would make a minimum requirement for 1,000 dwellings. However, Swan Hill considers it is important that the Policy provision sets out that this is a minimum level, and is likely to change over the course of the Core Strategy period.

2.11 Whilst Policy H3 sets out a degree of flexibility towards the deliverability of these 'general locations', it is important that Policy H3 sets out that the potential number of units proposed on those 'general locations' are a minimum, based on the current Adopted East of England Plan. Further, the East of England Plan is currently under review, and it is likely that the strategic annual housing figure for the period beyond 2021 is likely to increase. This should be reflected in Policy H3.

Policy H4 - Affordable Housing

2.12 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. Additionally, the threshold is considered the most appropriate, given that most developments below 15 dwellings or 0.5ha may not be viable to support an element of affordable housing, unless being provided solely for affordable housing.

2.13 The proposed Policy sets out a degree of flexibility for those sites which, if demonstrated by the developer that a provision of 35% affordable housing would make a scheme unviable, has been included. However, it is considered that a greater degree of flexibility should be set out in the policy, in order to ensure the level of affordable homes is considered through negotiation with the Council, and that each application is assessed on a site-by-site basis.

2.14 Additionally, it is considered that many Registered Social Landlords (RSLs) may consider the 'pepper potting' of affordable dwellings throughout larger sites can have significant logistical and cost implications which could discourage RSLs from wanting to take up those units. Whilst Swan Hill acknowledges the benefits of pepper potting affordable housing units around a large development, as this would ensure less disparity between those units and the open market units, clustering affordable housing units together, whether that is in one area or in groups can significantly reduce costs and logistical management issues for many RSLs, making them more attractive to manage and rent.

Policy H5 - Dwelling Types

2.15 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. With the exception of providing a suitable proportion of the provision of affordable units with three-bedrooms, the policy appears to represent to best option for ensuring flexibility for new housing developments, enabling developers to ensure the most up-to-date market assessments play a pivotal role in determining the appropriate level of mix, at any given time.

2.16 In respect of the reference to the Strategic Housing Market Assessment for Thames Gateway South Essex, it is important that if the Council chooses to rely on such assessments as a key factor in determining the appropriate level of mix, it is important that such an assessment is up-to date, and represent the most appropriate model for assessment the level of housing requirements.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's preferred options where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers the Alternative Option set out in the Core Strategy represents the most suitable option for this type of policy provision. Seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a degree of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

3.1 Swan Hill generally supports the policy approach taken towards the protection of the Green Belt, where the key objectives of PPG2 can be met and maintained. It is important that Policy GB1 has regard to the need for a review of the Green Belt boundaries around the key settlements of the District, in order to achieve the required level of residential development required by the East of England Plan.

3.2 As such, and whilst a review of the Green Belt is set out in the supporting text, Swan Hill considers that Policy GB1 of the Core Strategy should be amended to address the need to review the Green Belt boundaries as a means to ensure that minor greenfield sustainable extensions to the settlements can occur without offending the overarching policy objectives of the Metropolitan Green Belt.

Policy GB2 - Rural Diversification and Recreational Uses

3.3 Swan Hill generally supports the Council's policy approach towards rural diversification and provision of recreational uses within the Green Belt.

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

4.1 Swan Hill supports the preferred option approach towards dealing with settlements at risk of flooding. Whilst Great Wakering is identified as a particular area at risk of flooding, this is predominantly associated with the eastern part of the settlement, and as such should not be considered as an overriding constraint to development at other parts of the settlement. Swan Hill concurs with the Council that restricting all new development away from Great Wakering could have a significant adverse impact on the long term viability of the settlement.

4.2 Swan Hill supports the Council's collaboration with the Environment Agency in seeking to ensure Great Wakering is protected from flooding for the existing and future residents.

Policy ENV4 - Sustainable Drainage System (SUDS)

4.3 In respect of Policy ENV4, Swan Hill supports the general principle of sustainable drainage systems. However, given the difficulties in transferring the future management and operation of SUDS to water companies and local authorities, it is not considered appropriate to require the provision of SUDS as a pre-requisite to development in all cases.

4.4 As such, it is considered that the provision of SUDS should be considered on a site-by-site basis, and the level of provision should form part of the negotiations at the planning application stage of the larger developments in the District.

Policy ENV8 - Code for Sustainable Homes

4.5 The need to provide all new dwellings to the Code level 3 of the 'Code for Sustainable Homes' by 2010 is a key objective of the Government. This policy approach is supported by Swan Hill. However, Swan Hill consider the requirement to achieve Code level 6 by 2013 is unrealistic and whilst Swan Hill recognises the importance of this issue, and the desire for carbon neutral homes, producing this on all new dwellings by 2013 could have significant implications on the cost of developments, viability and deliverability. The Government target for achieving Code Level 6 for new dwellings is 2016, and as such, Swan Hill considers the Council should not seek to supersede Government policy on this matter.

5.0 Transport:

Policy T1 - Highways

5.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

5.2 Swan Hill recognises the importance between providing sufficient infrastructure provision to meet the requirements of development, and that where developments have no consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T2 - Public Transport

5.3 Swan Hill supports the policy approach taken by the Council on Policy T2.

Policy T4 - Travel Plans

5.4 Swan Hill supports the policy approach taken by the Council on Policy T4.

Policy T5 - Cycling and Walking

5.5 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. However, it is important that any policy on the provision of additional off site facilities is based on a site-by-site assessment, and should be related to the impact generated by the development proposed.

5.6 As such, Swan Hill considers this policy should allow for a greater degree of flexibility on the provision and justification of off-site improvements to the cycle and pedestrian network of the District.

Policy T7 - Parking Standards

5.7 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill supports the policy approach chosen by the Council. However, Swan Hill consider it relevant that the Council set out within the wording of the policy that they have adopted supplementary guidance, which should be applied by developers in the preparation of proposals.

6.0 Character of Place:

Policy CP1 - Design

6.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

6.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

7.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

7.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

7.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

Policy CLT6 - Community Facilities

7.4 Swan Hill supports the approach set out by the Council in policy CLT6, and in particular, that the Council has identified a need for new community facilities within Great Wakering.

8.0 Summary:

8.1 In Summary, Swan Hill considers that overall the 2008 version of the Core Strategy presents a significant improvement on the earlier document, and seeks to address the strategic housing requirements for the District up to and beyond 2021 with clarity. However, it is considered that in general terms the Core Strategy is overly prescriptive and detailed, dealing with too many issues and providing too many policies that could be and should be dealt with in other Development Plan Documents, such as the Development Control Policies DPD. Whilst some of the policies provide flexibility and allow for the individual assessment of development proposals through negotiations with the Council, Swan Hill considers that many of these can removed from the Core Strategy, to be considered later in other DPDs.

8.2 Swan Hill considers the Core Strategy could be significantly reduced in size, in order to provide a more concise, directed document, which deals with the key, overarching strategic policy requirements of the District, as required by PPS12.

Dear Sir / Madam,

Rochford District Council Local Development Framework, Core Strategy Preferred Options Consultation Document

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

Vision

The Council's key planning objectives include the following:

o To work towards sustainable development by making the most effective and efficient use of land.
o To improve the quality of life of the inhabitants of the District by providing the best possible environment, and satisfying social needs by making accessible provision for the necessary health, housing, educational, community and leisure facilities in the interests of the total well being of all groups within the population.
o To ensure the availability of land in appropriate locations for housing, commercial and industrial uses.
o To retain, conserve and enhance the built and natural environments, including the architectural and historical heritage, flora, fauna and their habitats throughout the District.
o To make provisions for transportation improvements to effect the most environmentally sustainable, efficient, convenient movement of goods and people.
o To define and protect the Metropolitan Green Belt, the undeveloped coast and area of ecological interest by directing development towards the District's established settlements.
o To enable the existing business community to function as efficiently as possible and to support economic and regeneration development throughout the Borough.

Whilst our client would like to provide support for the Council's key planning objectives, at present there are a number of aspects which are currently inconsistent or do not accurately reflect the sentiments of the Preferred Policies set out in the remainder of the draft Core Strategy.

Firstly, there is currently no recognition within the Council's key objectives of the most appropriate direction for development. Whilst it is understood that these are overarching aims, it is considered particularly important that locating future development within and adjacent to the Borough's existing larger settlements is essential in order to uphold national, regional and local sustainability aims. This requirement is in line with our further comments on this particular subject below.

Further, it should be made clear as part of objective six that the Green Belt boundary is to be re-defined. This provision will ensure that the objective is consistent with the allowances made in preferred Policy GB1 and the associated supporting text to release some Green Belt land where deemed appropriate and necessary.

Housing

In response the Council's method regarding the location, type and timing of housing development, as set out on page 24 of the draft Core Strategy Document, care should be taken to ensure that the requirements stipulated at Paragraph 54 of PPS3 are adhered to. In particular, the deliverability of sites should be carefully considered when taking decisions on the timing of housing development, in that the site should be available, suitable and achievable, in order that the five year housing supply is realistic in its aims.

Distribution

The Council's Preferred Option for housing distribution is set out as follows:

Policy H1 - Distribution - Preferred Option

We will prioritise the reuse of previously developed land identified as being appropriate as part of our Urban Capacity Study, having regard to the need to protect sites of ecological importance. Areas coming forward for residential development identified within the Urban Capacity Study will be required to conform to all policies within the Core Strategy, particularly in relation to infrastructure, and larger sites will be required to be comprehensively planned.
In order to protect the character of existing settlements, we will resist the intensification of smaller sites within residential areas. Limited infilling will be acceptable if it corresponds to the existing street pattern and density of the locality. We will encourage an appropriate level of residential intensification within town centre areas, where higher density schemes (60+ dwellings per hectare) may be appropriate. The remaining housing requirement will be met through the allocation of land on the edge of existing settlements as outlined in H2.
Our client would like to provide support to the realistic approach taken by the Council in respect of brownfield development within existing settlement boundaries. However, in order that the character of existing settlements can be maintained and Policy H1 can be adequately implemented, Policy GB1 relating to Green Belt protection will need to incorporate a sufficient level of flexibility to allow the release of Green Belt land where it is considered appropriate.

General Locations

At present, support cannot be provided to the Settlement hierarchy as set out on Page 26 of the draft Core Strategy Document. Whilst it is considered appropriate for Rayleigh to be designated as a Tier 1 settlement, the draft Core Strategy is currently not consistent throughout in this respect. It is noted on Page 20 of the Strategy that Rayleigh is the only first tier settlement which could be classed as a 'principle town centre'. Rayleigh is also considered to have the best access to services in the District. However, when considering the general locations for housing development there is no consideration of the higher order level of the settlement of Rayleigh. Rayleigh should be considered the priority direction for housing development given the greater level of services available and public transport connections, in line with the designation set out on Page 20. The greater concentration of services available within Rayleigh results in adequate capacity being available to support a higher level of resident development. In addition, directing development in this manner will act to support the Council's environmental and sustainability aims, particularly, Preferred Policies ENV1,2 and 3.

We, therefore, recommend on behalf of Fairview New Homes that the settlement hierarchy set out on Page 26 be amended in order to reflect the higher level order of Rayleigh.

The Council's preferred option for the general location and phasing of housing development is as follows:

Policy H2 - General Locations and Phasing - Preferred Option

We will extend the residential envelope of existing settlements for the purposes of residential development in the following areas to deliver the following approximate number of units by 2015 or between 2015 and 2021, as stipulated below and indicated on the Key Diagram.

Area - North of London Road, Rayleigh
No. of units by 2015 - 450
No. of units 2015 - 2021 - 200

Area - South West Rayleigh
No. of units by 2015 - 100
No. of units 2015 - 2021 - 0

Area - West Rochford
No. of units by 2015 - 300
No. of units 2015 - 2021 - 100

Area - West Hockley
No. of units by 2015 - 50
No. of units 2015 - 2021 - 0

Area - South Hawkwell
No. of units by 2015 - 100
No. of units 2015 - 2021 - 100

Area - East Ashingdon
No. of units by 2015 - 120
No. of units 2015 - 2021 - 0

Area - South East Ashingdon
No. of units by 2015 - 20
No. of units 2015 - 2021 - 0

Area - South West Hullbridge
No. of units by 2015 - 0
No. of units 2015 - 2021 - 450

Area - South West Great Wakering
No. of units by 2015 - 100
No. of units 2015 - 2021 - 100

Area - West Great Wakering
No. of units by 2015 - 50
No. of units 2015 - 2021 - 100

Area - South Canewdon
No. of units by 2015 - 60
No. of units 2015 - 2021 - 0

Total no. of units by 2015 - 1450
Total no. of units 2015-2021 - 1050

The detailed location and quantum of development will be articulated within the Allocations Development Plan Document.
Development with the above areas will be required to be comprehensively planned. A range of other uses and infrastructure (including off-site infrastructure), having regard to the requirements of the Core Strategy, will be required to be developed and implemented in a timely manner alongside housing. H Appendix 1 outlines the infrastructure that will be required for each residential area, and should be read in conjunction with Preferred Option CLT1.

We will maintain a flexible approach with regards to the timing of the release of land for residential development to ensure a constant five year supply of land.

Fairview New Homes would like to offer strong support in response to Preferred Policy H2 as well as to the general housing locations as shown on the accompanying Key Diagram. In particular, it is requested that the intention to extend the existing settlement boundary in the south west area of Rayleigh is retained when formulating the Core Strategy Submission document. Our client has an interest in a large parcel of land in this location of Rayleigh which is available for redevelopment in the immediate future, therefore, reflecting the phasing option set out in Preferred Policy H2.

In addition, the retention of a flexible approach to the timing of the release of the areas of land set out in Policy H2 is particularly important in order that sites can come forward when available and required.

Affordable Housing

The Council's preferred option for affordable housing is set out as follows:

Policy H4 - Affordable Housing - Preferred Option

At least 35% of dwellings on all developments of 15 or more units, or on sites greater than 0.5 hectares, shall be affordable. These affordable dwellings shall be spread (pepper potted) throughout larger developments. Affordable dwellings shall be required to remain affordable in perpetuity - this will be secured through legal agreements.

This requirement will only be relaxed in highly exceptional circumstances, for example where constraints make on-site provision impossible or where the developer is able to definitely demonstrate that 35% provision will be economically unviable, rendering the site undeliverable. In such cases we will negotiate the proportion of affordable dwellings based on the economic viability calculations. It is expected that affordable housing will be provided on each development site; in rare cases, taking account of particular site characteristics, the affordable housing contribution may be provided by way of a commuted sum towards off-site affordable housing.

The Council's realistic approach to securing affordable housing throughout the Borough is supported by Fairview New Homes. In particular, the flexibility and recognition that it may not be possible to provide the full requirement of affordable housing on all sites is offered strong support by our client. In this respect full consideration should be had towards individual locations and specific sites depending on the findings of the Strategic Housing Needs Assessment (PPS3 Paragraph 29 Part 3).

It is requested that the Council seek to retain an element of negotiation within Policy H4 when developing the Core Strategy to submission stage in order to allow a sensitive approach to local housing need as it fluctuates throughout the Council's administrative area rather than a blanket approached.

Further, the first part of the preferred policy requires that affordable housing be spread "(pepper potted)" throughout new development. Whilst my client is sure you are aware, management is a real issue for social landlords, and often it is not practical to adopt a 'pepper pot' approach, and further consideration should be had of the 'user' / 'management' requirements when developing the Core Strategy to Submission Stage.

Lifetime Homes

The Council's preferred policy for Lifetime Homes is as follows:

Policy H6 - Lifetime Homes - Preferred Option

We will normally require all new housing developments to comply with the Lifetime Homes Standard from 2010. Exceptions will be made where such a requirement threatens the viability of developments, in which case we will seek a proportion of units to comply with the standard.

In line with our comments in respect of Preferred Policy H4 Fairview New Homes would like to provide support to the recognition that in some instances the Lifetime Homes Standard will not be able to be met. It is requested that this level of flexibility is retained when developing the Core Strategy Submission Document.

The Green Belt

Protection of the Green Belt

Whilst it is recognised that there is a need to protect Green Belt land throughout the Borough, on behalf of our client, we would like to provide full support to the acknowledgement on Page 41 that a proportion of the currently allocated Green Belt land will need to be released for redevelopment. When considering areas of land for release, those adjacent to the existing settlement boundary should be prioritised in order that settlements within the Borough are coherently extended.

In particular, the area of land to the South West of Rayleigh, designated as a general location for housing in Preferred Policy H2, should be a key priority for reallocation. This land is available for development and is sited in a particularly sustainable location, therefore, meeting with the wider aims of the draft Core Strategy, as well as contributing towards the Council's housing requirements for the Borough. Release of small areas of Green Belt surrounding larger settlements will allow a concentration of development in key areas. In addition, there is no risk of coalescence of settlements should Green Belt land be release to the south west of Rayleigh.

Further, our client would also like to support the provision set out on Page 42 of the Draft Core Strategy document for high density development on the areas of Green Belt land released for development in order that remaining Green Belt land is sufficiently protected.

The Council's preferred policy for Green Belt Protection is stated as follows:

Policy GB1 - Green Belt Protection - Preferred Option

We will seek to direct development away from the Green Belt, minimise the reallocation of Green Belt land and will prioritise the protection of Green Belt land based on how well the land helps to achieve the purposes of the Green Belt.

The need to prevent the coalescence of individual settlements, in order to help preserve their identities, will be given particular consideration.

In line with our comments above, our client would like to endorse Policy GB1 in that some allowance remains within the policy to permit the release of Green Belt land where appropriate and necessary. This flexibility is essential in order that the Council are able to meet the housing provision requirements set out in the adopted East of England Plan in the plan period until 2021.

Transport

Parking Standards

Rochford Borough Council's preferred policy on parking standards is set out as follows:

Policy T7 - Parking Standards - Preferred Option

We will apply minimum parking standards, including visitor parking, to residential development. We will be prepared to relax such standards for residential development within town centre locations and sites in close proximity to any of the District's train stations.

Whilst applying maximum parking standards for trip destinations, we will still require such development to include adequate parking provision. Developers will be required to demonstrate that adequate provision for the parking, turning and unloading of service vehicles has been provided.

At present our client is unable to support Preferred Policy T7 in its current form, due to the lack of coherence with national planning policy set out in PPG13. The first part of the preferred policy specifies the Council's intention to apply minimum parking standards to residential development. Paragraph 17 of PPG13 clearly states that parking policies should not be expressed as minimum standards. Considering this against advice set out in PPS12 at Paragraph 4.52, Local Planning Authorities should ensure that Core Strategies are consistent with National Policy in order that the document can be considered to be sound. As this is the case we are unable to endorse Preferred Policy T7 in this respect. Instead, it is requested that the Council seek to enforce a maximum parking standard to ensure that the sustainable aims of PPG13 are upheld.

Open Space

The Council's preferred policy relating to the provision of open space is set out as follows:

Policy CLT5 - Open Space - Preferred Option

New public open space will be required to accompany additional residential development, having regard to local current and projected future need. Standard Charges may be applied to developments as necessary.

In particular we will seek the incorporation of a significant amount of public open space to accompany new, and be integrated with existing residential development in the west of Rayleigh.

Furthermore, the following existing uses will be protected, whether in public or private ownership:

• Parks
• Amenity areas
• Allotments
• Playing pitches
• Any other form of open space that has a high townscape value or is intrinsic to the character of the area.

New forms of the above will be promoted.

Fairview New Homes strongly object to the requirements set out in preferred Policy CLT5.
Whilst the sentiments of the policy are well founded and it is recognised that there is a need to provide public open space throughout the Borough, there is no justification as to why a significant amount of public space will be required in the west of Rayleigh. No information or evidence is provided to rationalise this requirement either as part of preferred Policy CLT5 or within the accompanying supporting text. Further, there is no explanation as to why this particular area of the Borough is specified for a higher than average provision of public open space, as an exception.

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

There is a need for housing in general, however, there is a limit on numbers. You will no doubt include in this to bolster the number of house units, maisonettes and flats to increase numbers of units, you must consider all other aspects of this document. I do not believe it is possible to build all that is required, houses that is, as more land will be needed for industry, play areas, schools, traveller sites etc.

House numbers you state Government are insisting are build in our locations are far to many. Therefore you the Council elected by the residents must stand up to this old labour in sheeps clothing REFUSE to accept the 4600 by 2021. Look at Castle Point residents protests indeed the Tory Council are strongly objecting to complying with the Governments blue print.

Listen to the residents. We will be on the side of a caring Tory Council.

It has been stated by those that provide our food ie farmers that to provide sufficient food stuffs they must have 3 crops per year to maintain our living standards.

My view yes some new housing but limited numbers. Also await for locations of housing and work places.