Distribution

On behalf of Hockley Parish Plan Group, I would like to register the following comments and objections in response to the RDC Core Strategy Preferred Options (2008) Document:

Comment 1
Hockley must remain as a distinct community with clear boundaries and green spaces between Hockley and its neighbouring parishes. Countryside in and around Hockley, including woods, footpaths, bridleways, play areas, playing fields and nature reserves must be 100% preserved. There should be no loss of greenbelt or open spaces in Hockley or the surrounding areas.

Comment 2
Due to shortage of available building land, housing development in and around Hockley must be minimal, and should include starter homes and affordable housing. Historic and listed buildings in Hockley must be preserved.

Comment 3
Hockley town centre development must maintain the character of Hockley, and include a variety of shops, family restaurants, enhanced parking facilities, and facilities for the youth. It must consider appropriate facilities for people with disabilities.

Comment 4
Increased population in Hockley and its neighbouring parishes must be supported by additional healthcare (dentists and doctors), primary and secondary school places, community services, and leisure facilities.

Comment 5
Improved highways and cycle networks are essential in and around Hockley to support increased traffic volumes, improve road safety, and eliminate congestion.

Comment 6
There must be no additional pollution in Hockley in terms of air quality and noise, particularly related to increased traffic volumes and airport expansion programmes.

Comment 7
Public transport must be improved in and around Hockley in terms of routes and frequencies to support additional population and to alleviate the impact of additional traffic volumes.

Comment 8
Additional controls must be introduced to ensure crime levels, vandalism and anti-social behaviour issues, in and around Hockley, do not increase due to additional population numbers.

Objection 1
The core strategy does not provide an option of placing all 3500 homes in one new location, remote from Hockley, with provision of appropriate self supporting infrastructure (schools, healthcare, community services and leisure facilites), and including public transport and highway networks that do not impact on Hockley.

Objection 2
As the majority of proposed additional housing, population and traffic is located to the east of Hockley, the plan is not sustainable, in and around Hockley, due to insufficient infrastructure proposals (schools, healthcare, community services and leisure facilities), and particularly related to public transport and highway networks. Roads through Hockley already suffer from major congestion issues, and no plans are evident in the strategy to eliminate current and future traffic issues.

Best regards

What keeps Hockley's character are open spaces and footpaths. Housing development should be minimal or Hockley will become overcrowded, not a village as it feels now. We have insufficient health care for the population now, how would newcomers find doctors or schools? The main road from Rayleigh to Hockley has become a traffic jam, and yet Arriva are withdrawing buses from Hockley and Hawkwell so that without a car we cannot get to Southend Hospital. Hockley is at saturation point at the moment. Further housing would bring people into the area who cannot be absorbed.

Cllr Hudson I am testing you!

Testing complete!
Regards
Keith Hudson

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).

I feel that the inferstructure in the Rochford to Rayleigh area i.e. roads, public transport, medical facilities and water supplies will be unable to cope with the large number of houses and extra population.

The distribution of housing set out in the document seems extremely unfair with West Rayleigh/Rawreth taking an extremely large share of the allocations. This area of Rayleigh has already been overdeveloped in recent years, the roads servicing the area, such as Rawreth Lane, Watery Lane, London Road and the A1245 are alreay regularly at a standstill, an accident, heavy rain, snow etc brings long delays, nose to tail jams, with the proposed housing in Rawreth Lane this will only make matters worse.

My principal objection is that the scattering of houses here and there across the district appears to me to dissipate the possibility of substantial planning gain. Spreading the burden simply piles additional pressure on the already creaking infrastructure, with little evidence of how things might be improved.

There is no discussion of the possibility of concentrating the required housing in one location (e.g. in the east of the district). A new settlement like this might not be desirable - but then what the Core Strategy offers is not desirable either. Surely this would at least be worth discussing?

We are in danger of releasing too much green-belt land so that the area is not "crammed"; when in reality as developers put in plans, they appeal the density levels and often win. The consequence is that we release more land and still get "cramming".

There is in my opinion, an unfair allocation of homes throughout the district especially in the Hawkwell area. I believe the required additional homes should be built as a new village with self-contained services in the west of Rochford from a new access road to the A1245 (old A130). This is by far the best location for access to the existing trunk road network and would eliminate the detrimental effect on the rest of the district.

Impacts on Hockley village will include:

Extra traffic on the B1013 and Ashingdon Road and at the Spa bottleneck; also on Lower Road.

Extra traffic to/from further development at the airport and more parking at Hockley shops/station.

Extra demand on our very limited health service. PCT dates show that Hockley has the worst GP/patient and dentist/patient ratios in SE Essex.

Extra demand on schools, particularly Greesward.

Lack of public transport. Most of Hockley, Hawkwell and Ashingdon will soon have just one bus an hour. How will the new and widespread housing (including 'affordable housing') be serviced?

Policy H1/H2/H3 identify potential for 510 new dwellings at Great Wakering within the designated plan period. This should be considered alongside the additional 1400 dwellings proposed in Southend-on-Sea BC's Core Strategy for Shoebury in the period 2001-2021, a significant proportion of which have still to be allocated. The Borough Council propose an AAP or SPD to provide detailed planning guidance for this growth and Renaissance Southend (RSL) support a comprehensive approach to the planning and regeneration of Shoebury. It is suggested there could be merit in a joint approach to the planned growth of Great Wakering and Shoebury.

The Urban Capacity Study (UCS) 2007 estimate of 1301 units is based on conservative assumptions about the potential density of specific previously developed sites. For example, the site at Stambridge Mills, Rochford is described in the UCS as being adjacent to a 'second tier' settlement (i.e Rochford) where densities above 50 dwellings per hectare would generally not be appropriate. By contrast, the Core Strategy Preferred Options Document identifies Rochford as a 'first tier' settlement. Furthermore, whilst applying a 'probable density' of 35 dwellings per hectare to the Stambridge Mills site, the UCS states that 'the specific characteristics of the built development on the site suggest a scheme of some scale might be possible'.

It is also considered that the UCS estimate of the capacity of the Star Lane Brickworks site at Great Wakering is an underestimate given (i) the site's proximity to the Southend urban area, and (ii) the potential for a proportion of flatted development of 3-4 storeys in height in the northern part of the site adjacent to existing industrial development

First para mentions 'key diagram' - where is this?
I support the avoidance of "town cramming" but put additional emphasis on the fact that the "cramming" should be avoided to maintain 'open spaces' and 'wildlife corridors'.
The 70% option on green belt should only be in those areas where there are appropriate and sufficient facilities (sewerage/transport, etc)

CPRE feel that the aim to us only 30% Brown Field sites for further housing developments is too low. Brown Field sites do become available and should be unilised where possible. A 70% use of greenbelt land is unacceptable if we are to preserve the open aspect of the surrounding area.

We support the concern regarding the effect of "town cramming" on the attractiveness and character of parts of the District. Providing 60% of housing on previously developed land as advocated by Government Policy may be unrealistic in Rochford. A 30:70 split between development on previously developed land and suitable Greenfield locations at the edge of sustainable settlements is also supported. A potential site for housing previously put forward, to the south of Ironwell Lane, Hawkwell, would not contribute to town cramming, it is located adjacent to low density residential development in a broad area identified for growth by PolicyH2.

Essex Chambers of Commerce urges that improvements are made to the strategic highway network in Rochford, particularly on the east-west route, as the numbers and locations of proposed housing will only add to the already significant congestion that currently exists.

Essex Chambers of Commerce urges that improvements are made to the strategic highway network in Rochford, particularly on the east-west route, as the proposed numbers and locations of new housing will only add to the already significant congestion that currently exists.

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.

REPRESENTATIONS TO CORE STRATEGY PREFERRED OPTIONS DPD (OCTOBER 2008)

Iceni Projects Ltd (Iceni) has been instructed by Colonnade Land LLP (Colonnade) to submit
representations in respect of the Rochford Local Development Framework Core Strategy Preferred Options Development Plan Document (DPD).

a) Background

Colonnade is a strategic land company with a particular interest in the future development of the District as a consequence of a number of sites that it controls, particularly around Rochford. The representations set out below respond principally to the Housing and Employment chapters of the DPD, but do also take in other issues.

b) East of England Plan Review

You will be aware that representations have been made by Colonnade to the EERA Call for Proposals consultation, which closed in October 2008. The consultation forms an early part of the comprehensive long term review of the East of England Plan, which will address the growth strategy for the East of England Region, to include Rochford District, to 2031. Any associated changes to Rochford's growth strategy triggered by the East of England Plan Review will as a necessity, require a subsequent review to Rochford's Core Strategy, but as a consequence, are not matters that the current Core Strategy needs to directly contemplate.

c) Overview

Iceni consider the Core Strategy Preferred Options DPD to be a balanced, responsible, and legible document. Whilst we inevitably make observations, and in places objections, these are issued with the intention of improving the Core Strategy, and to ensuring that the DPD is both sound and responsive to future changes.

The downside to delivering a succinct document is that much of the material that is presented in the evidence base is left out of the Core Strategy DPD. Iceni believe that further cross referencing must be made in order to ensure the recommendations suggested within the evidence base are carried through.

For example, the employment policy should reflect and cross-reference the Employment Land Study 2008 recommendations.

As a general comment, Colonnade believes that the Core Strategy could place a greater focus on promoting Rochford as the principal settlement within the District. In the longer term, London Southend Airport has the potential to become a key catalyst for employment growth in the town. Such an opportunity warrants
identifying Rochford as the most logical and sustainable location for associated growth, not only in terms of housing, but also retail, community and education facilities. Coupled with the planned delivery of the new London Southend Airport Railway Station and the opportunity to connect with South Essex Rapid Transit (SERT), Rochford has the obvious credentials to function as the principal settlement within the District.

d) Site-Specific Interest

i) Residential

Your Authority will be familiar with Colonnade's interest in Coombes Farm, which it has previously registered through the LDF Call for Sites exercise. In our opinion, Coombes Farm is the most logical location for residential development abutting the urban area of Rochford. Coombes Farm has the ability to
direct pedestrians and cyclists through the town centre, to the benefit of existing retail and service
businesses, which will benefit from through-trade. Our representations accordingly reflect this opinion.

The site warrants recognition through the Core Strategy as a general location for residential development. At a more local scale, Colonnade is also pursuing the allocation of land adjacent to Little Wakering Road, which abuts the existing urban area and an existing playspace, and presents an excellent opportunity for a
focussed residential development in the rural area, which in particular, can deliver affordable housing. It is anticipated that the Site Allocations DPD will provide a more appropriate forum to advance these proposals, as well as reaffirming the support for Coombes Farm.

ii) Employment

In addition to the above, Colonnade will look to pursue the allocation of Three Ashes Farm for employment purposes, which abuts the western boundary of the Purdeys Industrial Estate. The Employment Land Study 2008, recommended that Purdeys Industrial Estate is a 'fit for purpose industrial estate which should be maintained and, if possible, expanded'. Colonnade consider Three Ashes to be an excellent location for
localised employment growth in Rochford, in view of its proximity to existing businesses and residential properties, which will be further enhanced by the development of the planned London Southend Airport Railway Station. Colonnade note with interest the Core Strategy's aspirations for an Eco-Enterprise Centre, which could be incorporated within the site, and underpins Colonnade's aspirations to provide a high quality buffer between existing residential properties and the boundaries of Purdeys Industrial Estate.

e) Plan Representations

For the sake of clarity, the representations made are presented in the same order as the Core Strategy Preferred Options DPD.

i) Page 24: Distribution

We concur that it is not realistic to expect Rochford's housing allocation to be met mainly on Brownfield sites, and support the aim of delivering 30% of development on previously developed sites.

ii) Policy H1- Housing Distribution

The policy objective of resisting intensification of smaller sites in residential areas is supported, both in terms of the stated intention of protecting the special character of existing settlements, and ensuring that the District's housing programme is not dominated by the development of flatted developments, which
typically provide an oversupply of one and two bedroom properties. Furthermore, this approach accords with the general thrust of the guidance within PPS3 which confirms that allowance for windfall sites should not be included in the calculation of the first 10 years of housing land supply.

Whilst the general principle of directing housing development towards previously developed land is accepted, deliverability of identified sites must be carefully monitored. This is particularly important in the current market as many of the sites identified as previously developed land will not be viable for development and will therefore not come forward within the first five years of the Core Strategy. The policy should be sufficiently flexible to allow for additional sites to be brought forward in order to demonstrate the
continuous delivery of a five year housing land supply.

iii) Page 26: General Locations

Colonnade concur with the general principle of the settlement hierarchy, albeit would reaffirm its view that Rochford has the potential to stand above all other settlements due to its proximity to London Southend Airport. The Airport, along with London Gateway, is one of the two most significant employment opportunities within the Essex Thames Gateway. The Core Strategy should more specifically acknolwdge this opportunity, and reflect this in its approach to all policies and objectives.

iv) Policy H2: General Locations and Phasing - Preferred Option

Policy H2 provides for the development of 1,450 dwellings by 2015. The concluding paragraph on page 27 implies a start date of 2006, with reference to an annual delivery rate of 261.7 units over the period 2006-2015 (which in turn, represents a notional target of 2,617 for the ten year period). Allowing for the sites identified in Policy H2, this would imply a continuing requirement for 1,167 units to be brought forward from previously developed land. In contrast, the second paragraph under Distribution (on page 24) indicates an anticipated delivery of 805 units by 2015. Iceni would suggest that this issue deserves clarification. Subtracting the anticipated urban capacity and the identified H2 sites from the ten year delivery target suggests a shortfall of 362 units. In view of the guidance provided by PPS3 it is important that the Core Strategy is not perceived as placing a continuing reliance on windfall sites. Should this be the case, the
Core Strategy should look to identify additional land to meet its housing target under Policy H2.

In respect of the general areas identified for the delivery of housing, it is recognised that the detailed location and quantum of development will be articulated within the Allocations DPD. However, without providing any notional site areas, development density, or land take of associated facilities (such as those listed within H Appendix 1) it is difficult to quantify how likely it is that these site will be capable of meeting
the District's housing target. Iceni would suggest that this information needs to be incorporated within further iterations of the Core Strategy.

Regarding the relative strengths of the housing areas, at this juncture, Colonnade is content to focus on the merits of promoting Coombes Farm (or East Rochford) as a suitable location for residential development rather than criticising those areas identifed, for two principal reasons: firstly, areas rather than sites are listed, and consequently, it would be inappropriate to pass judgement until greater information is known of
actual sites, their size, potential constraints, and so on. Secondly, in advance of clarification on the above issue (in respect of windfall sites) it is possible that there will be a requirement to incorporate additional areas for residential development in any event.

The above notwithstanding, in Iceni's opinion, it is evident that there are compelling grounds for identifying Coombes Farm (within an East Rochford area designation) under Policy H2, and that in particular, it should be recorded as a priority location for helping to meet the District's five year housing land supply. The site is
located adjacent to the existing urban area, the River Roach acts as a defensible boundary to avoid coalescence with Southend, and it provides an opportunity to promote a sustainable residential development in close proximity to both Rochford Town Centre and Rochford Railway Station. Colonnade has conducted a detailed site analysis and is in the process of preparing an evidence base to a sufficiently detailed standard to underpin a planning application. Colonnade's emerging development proposals avoid the use for residential purposes of any land at risk of flooding, land within the existing (or future) public safety zone of London Southend Airport, or any other constrained land. A highly qualified consultant team have been appointed, including John Thompson Architects and Buro Happold engineers, who have deduced that the site is capable of accommodating circa 300 houses, the majority of which would be provided as family accommodation, as well as satisfying the District Council's affordable housing objectives.
Moreover, and despite the criticism provided within H2-Alternative Options, the proposals can be progressed without detrimental impact on congestion levels through Rochford Town Centre. Indeed, the site's proximity to Rochford Town centre is a virtue, as all other potential areas for development in Rochford/Ashingdon would bypass the town centre entirely. As a final point, it remains to be seen whether other landowners and developers will be prepared to proceed with a planning application and commit to implementation of any planning permission in the present economic climate. Colonnade in contrast is fully committed to Coombes Farm.

v) Policy H3 - General Locations Post 2021

Colonnade welcomes the fact that the Core Stratey correctly responds to the requirements of PPS3 in identifying broad locations for the delivery of a fifteen year housing land supply. In keeping with representations on H2, it remains to be seen whether the areas identified are sufficiently robust to meet the District's longer term housing requirements, because at this stage, there is insufficient information to
comment. In so far as Colonnade would anticipate Coombes Farm being fully delivered well in advance of 2021, the Company has no significant observations to make at this stage on the proposed policy.

vi) H4- Affordable Housing

Colonnade supports the proposed affordable housing target of 35%, albeit the actual percentage and tenure split is more appropriately determined at a planning application stage. It is likely that only Greenfield housing sites will be capable of meeting this target, as Rochford historically, and Brownfield sites generally, have consistently failed to meet affordable housing targets, as reflected in the critical under supply of affordable housing identified by the Thames Gateway South Essex Strategic Housing Market Assessment. Between
2001 and 2007, Rochford have only delivered 8% of their total housing stock for affordable dwellings, presenting a shortfall of 1,338 affordable units over the Plan Period to the end of 2007. The inability of sites to typically deliver more than 35% affordable justifies an over provision of housing sites to deliver a greater
quantum of affordable housing and housing as a whole.

Colonnade would also recommend that the Core Strategy specifically enables 100% affordable housing schemes to be brought forward on unallocated sites, potentially as rural exception proposals.

vii) H5- Dwelling Types

Colonnade welcomes the emphasis placed in the Core Strategy on delivering a mix of dwelling types, whilst making specific reference to the provision of family and affordable housing. Colonnade supports the promotion of Rochford District as a location for housing rather than flatted developments.

viii) H Appendix 1

There is concern that the table in H Appendix 1 fails to provide the necessary justification for the proposed improvements in infrastructure. Whilst the preamble seeks to clarify why the infrastructure is sought, the inclusion of this list should be fully justified, otherwise it is of little value. Furthermore, it would be of benefit to provide further details of the existing community infrastructure provision and capacity within the evidence base.

For the avoidance of doubt, Colonnade would welcome similar information being provided as a caveat for the allocation of Coombes Farm. Colonnade is fully committed to delivering infrastructure and community improvements, and for Coombes Farm to properly address the needs of future and existing residents.

ix) Proposed Policy GB3

Colonnade would promote the inclusion of an affordable housing exception policy within the Core Strategy, which will particularly aid the delivery of community housing within rural areas. Passing land values will typically preclude such developments on Brownfield sites. However, the limited and justified release of small
parcels of Green Belt land would fundameltally enhance the viability of 100% affordable schemes without setting a precedent for open market housing developments.

x) ED1- London Southend Airport

Colonnade supports the identification of London Southend Airport in providing a significant role for the economic development of the District, not only within the confines of the development location and Airport uses only, but also through the expansion of other employment uses in nearby locations. The policy does not provide any indication of the number of jobs it will provide within the Plan period through the
redevelopment/extension of the Airport. The supporting text explains that there is pportunity for economic development around the Airport that is not necessarily linked, but it does not commit to the amount of employment land that might be appropriate and where this should be ideally located.

Three Ashes is located adjacent to the existing Purdeys Industrial Estate and is located close to Southend Airport. As discussed above, the site is an opportunity to provide employment land in the short-term which can cater for 'spin off' Airport uses, or for more general employment purposes adjacent to the existing Industrial Estate. The Three Ashes site would be further justified by its close proximity to the planned
London Southend Airport Railway Station.

xi) ED2- Employment Growth

Colonnade agrees that Rochford's economy must diversify and modernise through the growth of existing businesses and through the creation of new enterprises. Whilst the general principle of encouraging growth of existing businesses is accepted, further employment growth is likely to be necessary, as identified within the Employment Study 2008.

The policies of the Green Belt chapter should reflect the requirement for Green Belt releases and in accordance with policy 2.12 of PPG2, consideration should be given to the identification of additional safeguarded land to meet employment and job targets to allow flexibility and ensure Green Belt policies do
not put employment delivery at risk.

xii) ED4- Future Employment Allocations

The policy indicates that only one new location for employment should be carried forward, located on land to the South of London Road, Rayleigh, and otherwise relies solely on the Airport to deliver the required employment land within the District. The level of employment to come forward from the Airport is likely to be
delivered towards the end of the Plan period and beyond, and therefore presents further employment land to be identified.

Three Ashes Farm provides an excellent opportunity to deliver employment growth in the short term. The Employment Land Study 2008 stated that Purdeys Industrial Estate is fit for purpose, and recommended that if possible, the Industrial Estate is expanded. Three Ashes could deliver this outcome, providing a natural extension to Purdeys Industrial Estate and being strategically located close to the Airport. Three
Ashes would address the negative impacts that the nearby residential area experiences from the existing Industrial Estate by providing a buffer between established uses and the residential area with less intensive employment activities. The highways analysis that has been carried out has suggested that it would not have an adverse impact on roads and congestion. Furthermore, there are very few opportunities for businesses to expand and Three Ashes could provide this opportunity.

The evidence base presented within the Urban Capacity Report 2007, suggests that it is likely that a significant amount of employment land will be taken up for residential development. This puts further pressure on the demand for employment opportunities within the District. The potential loss of employment sites would trigger the need for a further allocation of employment land. The policy should be flexible
enough to allow for other areas to be considered to meet the minimum job target set by the EEP.

Cross-referencing to the Employment Land Study should be provided within this chapter in order to demonstrate that more information has been issued on the consideration of general locations for employment land.

xiii) ENV5- Eco-Enterprise Centre

Colonnade support Rochford's aim of securing an Eco-Enterprise Centre within the District and consider Three Ashes to be an excellent location. This would provide a high-quality employment development that may also incorporate uses associated with the Airport. The site would further justify its sustainability benefits
by being located within close proximity to the London Southend Airport Railway Station and Rochford Town Centre.

xiv) ENV8- Code for Sustainable Homes

In seeking to go above and beyond the policy targets set out by Central Government, which propose zero carbon (i.e. Code 6) by 2019, the proposed policy does not set achievable targets for developers. The proposed imposition of stricter targets will have a potentially negative impact on housing delivery after 2010.

This is exemplified by the findings of the recent Communities and Local Government report entitled 'The Cost Analysis of the Code for Sustainable Homes' (July 2008) which confirms that costs for achieving the Code 6 would increase between 41% and 52% of the cost for meeting 2006 Building Regulations per unit
(detached). These additional costs would further impact upon the viability of housing schemes and thereby reducing housing delivery.

Accordingly, Iceni would suggest that rather than identifying specific targets, a generic policy should be incorporated confirming that housing development should accord with Central Government targets for the Code for Sustainable Homes.

xv) T1/T2 Highways and Public Transport

Colonnade supports the principle of improving public transport provision and reducing reliance on the private car. However, it is to be noted that the Core Strategy provides no information on how surface access improvements are to be delivered to London Southend Airport, which is a fundamental caveat for the growth of the Airport, and therefore the District's employment strategy. Equally, the policy provides no information on the planned development of a London Southend Airport Railway Station. Notwithstanding the planned programme off a Joint Area Action Plan with Southend-on-Sea Borough Council, the transport and
infrastructure implications of the Airport deserve further scrutiny within the Core Strategy.

xvi) T7- Parking Standards

The guidance in PPG13 is clear regarding the imposition of parking standards. Paragraphs 52-56 of PPG13 confirm that the Local Planning Authorities should apply maximum not minimum parking standards. Such a clear dismissal of adopted Central Government policy guidance is undermining the Strategy. Policy must reflect PPG13 to promote sustainable transport choices and further provide incentives for developers to
locate further residential land closer to local service centres by requiring maximum parking standards for residential developments.

xvii) CP1- Design

The Council should not seek to impose further demands on developers where existing regulations provide sufficient requirements regarding design. In this instance, Design and Access Statements provide sufficient design guidelines for developments.

xviii) Planning Obligations and Standard Charges

The principle of providing for planning gain associated with new development proposals is widely accepted. However, there needs to be a careful balance struck to ensure planning gain does not place undue burdens on developers, particularly in difficult market conditions. There is considerable risk that the imposition of high tariffs will mean that development will not come forward, further reducing affordable housing delivery and planning gain as a whole. The policy should refer to guidance contained within a Supplementary Planning Document (SPD) and should allow for flexibility to acknowledge reasonable negotiation on s106 agreements to ensure development proposals continue to come forward thereby contributing to
deliverability, whilst allowing realistic reductions for marginal schemes.

The supporting text to Policy CLT4 refers to the potential requirement to undertake a Health Impact Assessment. However, it fails to confirm what information should be contained within Health Impact Assessments and as such, further clarification of what is involved in the assessment and the expected outputs should be provided as it is not made available in the Core Strategy Preferred Options consultation document.

Colonnade Land LLP welcomes the opportunity to be an active stakeholder in the consultation process for developing the standard formula for Planning Obligations and formally requests that an invitation is extended by Rochford District Council.

Conclusion

Iceni Projects, on behalf of Colonnade Land LLP trust that the Council will find these representations to be constructive and helpful in taking forward the Core Strategy. Should you wish to discuss any aspect of these representations further, please do not hesitate to contact me.

INTRODUCTION

We act on behalf of Crowstone Properties Ltd and are instructed to submit Representations on their behalf as part of the Consultation on the emerging Core Strategy.

Whilst we fully appreciate that the current stage is principally concerned with strategic and district-wide issues rather than site-specific aspects, we note that Policy H2 General Locations and Phasing Preferred Option contains a schedule of areas which are indicated on the Key Diagram. We also note that two of the areas, namely West Hockley and West Great Wakering, have capacities of only 50 units. Our clients Representations submitted at an earlier consultation stage on the Core Strategy Preferred Options, (ie July 2007) included a Land Bid relating to developable land on the western side of Ashingdon which extends to approximately 2.5 hectares and would therefore provide an estimated minimum capacity in excess of 50 units. It is therefore of sufficient size to be regarded as "strategic" in terms of the Core Strategy and Policy H2.

Our Representations are in three parts:-

Part A: General Representations
Part B: Strategic Site Representations
Part C: Schedule of Amendments

At various points, however, we will cross-reference to our proposed strategic site, a plan of which can be found at the end of Part B. As noted, the area edged red extends to 2.5 hectares of which 0.5 hectares would be used to provide peripheral landscaping, and if required, a car park to serve the open space to the west and south. Immediately to the north, edged in blue, a woodland area extending to approximately 1.5 hectares would be dedicated for public open space. The strategic 4.0 hectare site would therefore constitute a mixed use comprising housing, a public car park and public open space and amenity land.

It would be of great assistance if future documents have their various sections numbered and each paragraph given a discreet paragraph number. The absence of any form of numbering system poses difficulty in identifying particular quotes from the document which makes the task of the reader and writer more laborious.

PART A: GENERAL REPRESENTATIONS

Listening to your views:

We found the summary of public opinion set out in "Listening To Your Views" to be both interesting and valuable as a basis for formulating the Core Strategy.

Clearly, one of the key points of public concern relates to the question of whether some Green Belt land should be used for future development. Much depends on how the question is put; if one asks: should Green Belt land be developed? - it is to be expected that most people's first reaction is that it should not. It is widely recognised and appreciated that undeveloped land in Rochford District performs many functions - it provides the setting for the settlements, gaps which prevent the coalescence of settlements, areas for informal and formal recreation, and pleasant countryside. Any encroachment of the Green Belt must be at a cost and should be avoided if humanly possible. If, however, the question is put another way, namely - should we safeguard the Green Belt rather than make provision for the various types of housing to meet the needs of our existing and future residents? - then a different response might be forthcoming. The prospect of housing shortages, with house shortages, with house prices driven up by scarcity value, and younger sections of the population finding it even more difficult to reach the first rung on the housing ladder, might be sufficiently unattractive a proposition to lead people to support a justified and carefully controlled release of parts of the Green Belt. We therefore welcome the fact that after many years of assiduous protection of Green Belt land, the Council has "grasped the nettle" and has clearly identified sound reasons why it is a Preferred Option to identify some Green Belt land for development.

Characteristics, Issue and Opportunities

We also found the section headed "Characteristics, Issues and Opportunities" to be a useful summary which painted an accurate picture of the current character and contemporary issues in Rochford District.

Economy

We do not consider the document sufficiently recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable. We note the paragraph which states "A high proportion of the Rochford workforce commutes out of the District. 30% travel to work in Southend, 14% to London, 9% to Basildon and about 15% travel elsewhere outside the District." In other words, 68% of the working population commute out of the District and only 32% work within the District. Even allowing for the high proportion that commute the relatively short distance to Southend, this represents a very heavy reliance on employment beyond the District's boundaries. The District is therefore highly unsustainable in this particular respect.

We note the references to Thames Gateway South Essex and to initiatives at Southend Airport, but consider that such employment growth will needs to be supplemented by a myriad of smaller and localized initiatives which are more likely to reduce the lengths of journey to work. At the same time, if well located, small business parks and enterprise areas would help counterbalance the lack of local employment which makes the District so heavily reliant on other areas. It would also reinforce the District's track record for thriving small businesses.

Settlements

We broadly support the four tiers of settlement with the first tier comprising Rayleigh, Rochford and Hockley as set out on page 20. We note, however, in "General Locations" on page 26, the first tier settlements are listed as Rayleigh; Rochford/Ashingdon; Hockley/Hawkwell. We have no difficulty with this but consider there should be consistency as to how settlements are addressed. For the avoidance of doubt, we prefer the approach adopted on page 26.

Vision

Again we register our support for the overarching vision and the key planning objectives. Without detracting from the high ideals expressed here, we would perhaps hope to see a much fuller explanation of how the vision is to be realised. Some reference to the types of measures or policy and proposals that will be introduced to implement the key planning objectives might be appropriate at this stage.

Housing

We consider the remaining balance of 2,489 units for the period 2001-2021 together with the further 1,000 units for the period 2021-2025 represents a substantial commitment requiring careful decisions in relation to its future distribution. We fully acknowledge the concern that can arise from town cramming and the difficulty posed by the rapidly dwindling supply of other brownfield land. We consider the Council can be justifiably proud of its record in directing a high proportion of recent growth to brownfield sites. However, this is a finite resource and it was inevitable that at some point it would be necessary to increase the Greenfield contribution. In the Council's view, that point has now been reached, and we agree with that. We note that the 30% of development that will still be targeted to brownfield sites is only half that advised in the East of England Plan, but that this lower level is probably realistic and hence deliverable. In any event, it is also important not to rely on regular reviews of the Green Belt boundary and this points to the need for long term land reserves needed for development being taken out of the Green Belt as part of the Core Strategy.

In moving towards the Preferred Distribution, we note the following on page 26.

"The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District."

We believe that is exactly the right approach but at this stage we have not seen the evidence to support this important claim. Indeed, the Preferred Options move rapidly into the topic of "Housing" without any clear demonstration of a comprehensive and holistic approach in terms of the distribution of the wider development needs of the District. In other words, we would expect to see a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles. We do not believe that general locations for new housing, for example, can be selected in isolation but that such decisions must reflect a pre-agreed framework of sustainability principles taking account of existing and all forms of new development requirements.

In turning to H2 General Locations and Phasing - Preferred Option, it is unclear what process of selection was undertaken to alight on this particular choice of area. No doubt each of the areas identified have their own particular merits and advantages, and some may be highly sustainable and other less so. It is difficult to pass judgement without any pre-stated basis for the inclusion of these particular areas. By the same token, the reasoning behind the split before and after 2015 is equally unclear. We do not oppose the principle of staging development - indeed we support it if this assists in ensuring land allocations are more evenly spread and hence available throughout the plan period. Again, however, we expect to see the reasoning for this split and this does not seem to be apparent. We raise these points because they are fundamental and there needs to be a clearly understood basis for the choice of general locations and for phasing. We have given careful consideration to the general locations set out in H2 and the alternative options set out giving reasons why these further locations were not preferred. Having regard to the earlier representations submitted on behalf of Crowstone Development Ltd relating to an area on the western side of Ashingdon, we can find no reference to this as a possible option.

Turning to H3 General Location Post-2021 Preferred Option, we consider there is a similar duty to justify the general locations and capacity for the areas identified. Whilst we note that: "The detailed location and development will be articulated within the Allocations Development Plan document and, where appropriate, Area Action Plans," this in no way reduces the need to ensure that the location itself is sustainable and can be justified as a Preferred Option. The information and analysis to support the general locations both pre and post 2015 and post 2021 is lacking and we consider this must go to the soundness of the Plan.

Affordable Housing

We take the view that much greater emphasis must be given in future to the delivery of affordable units, especially having regard to the high house values which preclude so many entering the housing market. We recognise that Exceptions Policies are necessary but deliver very little in terms of numbers. We also recognise that it is the larger sites that have the viability which enables a significant proportion of affordable units to be provided or cross-subsidised by free market housing. A judgement is needed as to the level of affordable provision that should be required from new sites. On balance we consider the suggestion that at least 35% of dwellings on all developments of 15 or more units, or on sites greater than 0.5 ha, should be affordable - gets the balance about right. We therefore support the wording of H4 Affordable Housing - Preferred Option in this respect and favour this to the Alternative Options in H4.

With regard, however, to the requirement to spread (pepper-pot) affordable dwellings throughout larger developments, we express certain concerns. We agree that large blocs of affordable housing should be avoided if possible but pepper-potting can give rise to design and management problems. As usual, these matters can normally be overcome through compromise having regard to the circumstances relating to each particular site. We would therefore prefer to see a more general reference to the need to avoid large blocs of affordable housing and the need to integrate affordable and free market housing in a harmonious way.

The Green Belt

As indicated above, we support the conclusion that the time has now come when the current boundaries of the Green Belt need to be reviewed to enable development required to be provided in Rochford District by the East of England Plan can be met in an environmentally acceptable way. Given the long-term nature of the plan period, the opportunity arises to adjust the Green Belt boundaries to facilitate growth over a long period and this should avoid the need for repetitive short term reviews which could undermine the confidence in the Green Belt. We note the wording of GB1 Green Belt Protection - Preferred Option and in particular the commitment to prioritise the protection of Green Belt land based on how well the land helps achieve the purposes of the Green Belt. Whilst this seems entirely clear and logical, we would expect this exercise to be conducted to inform the general locations identified in H2 and H3. Further uncertainty arises from the reference to "strategic buffers that are particularly worthy of mention" which appear not to be mentioned or featured on the Key Diagram. We consider any reference to "strategic buffers" should be deleted from the text as this function will continue to be achieved by means of the Green Belt.

The approach being adopted towards the release of Green Belt land for development may be sound as a general principle but we would expect to see clear evidence to support the general locations for growth in terms of their relative impact on the purposes of the Green Belt. There would appear to be a lack of joined up thinking between the Preferred Options in H1 and H2 and that in GB1.

Dwelling Types

Whilst we support the wish to ensure a mix of dwelling types to reflect a wide spectrum of housing needs and budgets, much will depend of the size of the particular development, the character of the area, and any other local constraints or factors. We therefore have certain reservations about a blanket policy requiring a housing mix. Such a mix may in any event be triggered by the requirement to provide affordable housing over and above the thresholds in H4. Our reservations might be overcome quite simply by inserting the words "Where appropriate," at the beginning of the text H5.

Rural Diversification, Green Tourism and Recreational Uses

We support the Council's aims to promote and secure a vibrant and prosperous countryside and one that encourages recreational uses. In fringe urban areas and particularly where development abuts the Green Belt boundary, opportunities should be explored to supplement formal and informal recreational provision as part and parcel of mixed use development sites. The opportunities for such provision should be one of the determining factors in the selection of locations for growth and subsequently at the Site Allocations DPD stage.

Future Employment Allocations

We generally welcome the initiatives set out to deliver increased employment provision to meet the needs of the District and its growing population over the plan period. We nevertheless have similar reservations to those expressed in relation to housing in terms of the proposals put forward. It is vital that housing and employment are considered jointly to ensure the best possible "fit" which would encourage new and more accessible employment opportunities. We would like to see evidence of the co-ordinated provision for housing and employment promoted through the growth locations put forward as Preferred Options. Again, this potentially calls into question the soundness of the plan.

Environmental Issues

We support the continuing protection of the District's natural landscape and habitats and hence we endorse the Preferred Options in ENV1 and ENV2. We consider some of the protective notations are sufficiently important to be denoted on the Key Diagram.

Flood Risk

Clearly the avoidance of areas prone to or at risk of flooding will be a key consideration in the choice of growth locations and later individual sites at the Site Allocations DPD stage. We mention in passing that the inclusion of the western side of Ashingdon as a General Location would not pose any problems associated with flood risk as it lies entirely outside any area so defined by the Environment Agency (see Part C).

Transport

We fully endorse the Preferred Options in T1 Highways and T2 Public Transport. With regard to the Preferred Option T5 Cycling and Walking, we draw attention to the particular opportunities in this respect associated with the inclusion of the western side of Ashingdon (see Part C).

Community Infrastructure, Leisure and Tourism

With regard to CLT5 Open Space - Preferred Option, we have already indicated we see opportunities for providing Open Space for both formal and informal recreation in association with General Locations especially on the edge or within the Green Belt. There are particular opportunities on the western side of Ashingdon which we refer to in Part C.

CONCLUSION

Whilst it will be seen that we have identified much to support within the text of the consultation document, we have expressed concerns in relation to the justification of many of the Preferred Options - particularly where these have Lane Use implications. Whilst not necessarily opposing any particular proposal, we have been unable to establish a paper trail which would convince us that such proposals are indeed justified in themselves or sufficiently tested. In some respects, the danger is that unless there is a clear testing of options against agreed criteria leading through a sieving process to establish the most appropriate locations for growth, then the process is not very different from the old style Local Plan system. It is this introduction of "better assessment" which is critical in terms of determining 'soundness'. An example of this crucial defect is the identification of General Locations requiring the loss of Green Belt land without any reference to the evaluation of the relative effects of that encroachment in relation to the purposes of the Green Belt. We believe these fundamental concerns need to be addressed in order to achieve reasonable confidence in the Core Strategy.

PART B: STRATEGIC SITE REPRESENTATIONS

In the above submission, we indicated that we considered the Land Bid put forward at an earlier stage in relation to Land on the Western Side of Ashingdon qualifies as a General Location because of its capacity to deliver more than 50 units - the lowest capacity threshold in H2. A plan identifying theland in question is found at the end of this section. As noted in the introduction, the site extends to 4.0 hectares of which 1.5 hectares is existing woodland. The remaining 2.5 hectares re envisaged to provide 2.0 hectares of housing and 0.5 hectares for landscaping and a public car park serving the Open Space to the west. Based on minimum densities required in PPS3: Housing, it is therefore envisaged that the location would provide a minimum of 60 units.

The main justification for the inclusion of the western side of Ashingdon as a General Location is as follows.

The location directly abuts established development off Rectory Avenue with estate road access up to its boundary along Hogarth Way. It therefore forms a natural adjunct to the existing built up area.
The location has very clearly demarcated and defensible boundaries in the form of a boundary with a flood park to the south, a footpath/cycleway to the west, and mature woodland and bridleway to the north.
There are important opportunities to contribute to the recreational use and potential of the land to the west as well as to upgrade the woodland for public access.
There are additional opportunities to provide a landscaped recreational car park for use by ramblers and dog walkers on the western side of the development served via Hogarth Way.
The interface between the development and open land to the west can be provided with a landscape buffer to help integrate the General Location into its landscape setting.
The site lies outside any Flood Risk zone identified by the Environment Agency (see plan at end of this section).

It is considered that a General Location identified on the western side of Ashingdon compares well with other locations on the edge of Rochford/Ashingdon in terms of its sustainability, its effect on the Green Belt, and on the setting of the settlement. As noted in Part A, this general location is not included in the list of General Locations or in the alternatives that have been considered and rejected.

We have advanced the view in Part A that particular regard should be had to the contribution General Locations might make to recreational facilities and amenities. We attach sufficient importance to this by suggesting that it could be a determining factor in the choice of General Locations. The associated Open Space and woodland management that would be achieved as part of the development of this proposed General Location would be very substantial indeed and would reinforce the existing neighbouring Open Space provision which is heavily used by both the local resident population and by visitors. There are no Rights of Way across this General Location at present. However, we envisage that there would be new footpath and cycleway routes through the development area to link with the existing Rights of Way.

Having regard to the above, we put forward land on the western side of Ashingdon as a General Location that should be included in H2 as a Preferred Option.

PART C: SCHEDULE OF AMENDMENTS

We set out below the main amendments we are seeking and suggesting to the Core Strategy Preferred Options some of which we believe to be necessary in order to make the document 'sound'.

1. Insert text which recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable.

2. Supplement the main employment growth proposals with complementary proposals relating to smaller and localised employment initiatives likely to reduce the lengths of journey to work.

3. Refer consistently to Rochford/Ashingdon and Hockley/Hawkwell rather than just Rochford and Hockley.

4. Provide a fuller explanation of how the 'Vision' is to be realised through the implementation of the key planning objectives.

5. Provide evidence to support the claim that "The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District".

6. Set out a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles.

7. Demonstrate how the coherent strategy referred to in (6) above has informed the General Locations for new housing and other forms of development.

8. Provide supporting evidence to justify the locations and capacity for the release of land pre- and post-2015 and post 2021.

9. Amend text to delete reference to pepper-potting affordable housing and refer instead to the need to avoid large blocks of affordable housing and the need to integrate affordable and free-market housing in a harmonious way.

10. Explain the relative effects of the General Locations identified in H2 and H3 on the Green Belt.

11. Delete reference to "strategic buffers" as their purpose will continue to be achieved by the Green Belt.

12. Insert the words "Where appropriate," at the beginning of H5.

13. Make explicit that opportunities should be explored for the provision of recreational and amenity land within or adjoining General Locations.

14. Provide clearer evidence to show a coordinated approach to the provision for housing and employment in order to meet the tests of soundness.

15. Consider including the more important rural and natural resource notations on the Key Diagram.

16. Include Land on the western side of Ashingdon (Part B of this submission) as a General Location in H2.