General Locations

50 houses are proposed for West Hockley but no details given of road improvements. These houses will presumably use Folly Lane with its horse-riders, S bends and poor junction with B1013 and narrow bridge under the railway. No costing are provided but improvements are unlikely to be economically viable

1. You claim that some development is needed in order for a village to "thrive". Hawkwell has a population of 3294 according to the 2001 Census, you are proposing to increase this by approximately 25%, and this will in fact bring Hawkwell to gridlock rather than enable it to thrive. When asked at the meeting what new infrastructure would be put in place, in particular schools, doctors, roads and buses, you could not give any answer this clearly shows a lack of thought on your part. To expect a developer to put these into place is not viable unless they are built into your planning approval. Will they be and if so what will they be?
2. You ruled out West Hockley for extra homes as the Ashingdon Road will not cope with extra traffic. The B1013 from Rayleigh to Rochford is already over capacity so surely the same rules apply? If your argument is that the extra traffic will only come from Cherry Orchard Way then I think you are mistaken. This then leads to access for Rectory Road. This can only be accessed via a mini roundabout at the Hawkwell end, B1013 junction; I believe that Essex County Council has stated that costs to improve this Junction would be prohibitive.
3. You state that Rochford District Council has to build 5500 new homes by law. This does not mean that 330 of them have to be built in Hawkwell. Given the current climate I would expect that the law could successfully be appealed to reduce this number. If not then it would be good sign to the people of Rochford District that you were prepared to fight, this was not the impression I left the meeting with.
4. To bring more jobs to the area. How do you propose to create jobs? Building units does not guarantee jobs; there are still new empty units on Purdy's Way Estate so why build more?

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).

Tier 4 all other settlements should specifically name the parish or town, ie Rawreth, the document is misleading and unclear

The 750 new homes in the Hawkwell/Ashingdon/Hockley/Rochford area are just not sustainable. The Hockley bottleneck, the overstretched B1013, Ashingdon Road and Lower Road are going to be even more jammed, added to the predicted extra traffic from the extended airport and commercial park. It must be much more sensisble to site more housing in the West/North West of the district with access to the new A130 and the A127.

Generally, building a large number of houses in Hockley is unsustainable in the long-term.
Specifically for green belt land in West Hockley, it would be a great pity to destroy or spoil public footpaths and small woodlands. The local residents treasure these natural areas and are precisely why many enjoy living in Hockley. This precious heritage to our children and grandchildren should be preserved.

There is in myr opinion, an unfair allocation of homes throughout the district especially in the Hawkwell area. My concern is that we are being asked to respond to this document in isolation, without considering the impact of the JAAP report regarding Southend Airport and the Site Allocation Document. I am also concerned that comprehensive consultation should take place with ECC, other district councils, local parish / town councils, residents associations and other interested parties in and around our district.

I notice a gradual 'chipping away' of our natural areas all the time; for instance, spraying on farmland (Gusted Hall) recently; litter and dog-fouling in our small copses joined by trails and footpaths, not to mention Hockley Woods. This means that pressure is already being placed on them for recreation.

The fields in and around Hockley West need to be kept for agricultural use (please see my comments at the beginning of the consultation).

The local residents treasure these natural areas, precisely why many enjoy living in Hockley. This precious heritage belongs to our children and grandchildren and should be preserved.

This document does not reflect PPS12 which states "Core strategies may allocate strategic sites for development. These should be those sites considered central to achievement of the strategy." (para 4.6) The larger of these General Locations are of a 'strategic' nature and therefore the Core Strategy should provide sufficient detail to support a planning application, thus negating the need for further consideration through other Development Plan Documents. This document states that it is the Council's intention to produce a Land Allocations DPD to provide the necessary detail, although the policy framework will not be in place until 2012/3 and therefore not likely to result in housing completions until 2013/14 at the earliest.

It is apparent from the inclusion of Appendix 1 that these locations do relate to specific parcels of land and therefore these should be clearly identified.

I agree that sustainable infrastructure is key, and specific attention is needed to areas identified below.

A co-ordinated approach should be evidenced between neighbouring councils and between planning and other decision areas (particularly roads and transport) to address existing problems as well as future development plans.

Full text
Whilst the respondent supports the general locations identified in the CS, the means by which the land is identified is considered too vague. The respondent does not agree with the Council's opening statement in this section of the Strategy, which states:

"It is not the purpose of the Core Strategy to set out precise locations for new development - this is done through the Allocations Development Plan Document".

Whilst it may not be necessary in Rochford to identify the exact boundaries of strategic sites, the information that is given is too vague. The advice in Planning Policy Statement 12, Local Spatial Strategy (PPS 17, 2008) is that:

"Core Strategies may allocate strategic sites for development". The Core Strategy looks to the long term. It may be beneficial to delivery of its objectives for details of key sites to be included in it, where these sites are central to the achievement of the strategy and where investment requires a long lead-in"

Further, at paragraph 4.3, it states:

"it is essential that the core strategy makes clear spatial choices about where developments should go in broad terms. This strong direction will mean that the work involved in the preparation of any subsequent DPDs is reduced. It also means that decisions on planning applications can be given a clear steer immediately."

There can be little dispute, that the greenfield locations identified in the Core Strategy are essential to the delivery of the spatial strategy. At present, the district cannot demonstrate a 5 year supply of housing land, as required by PPS3. The lack of a 5 year supply may result in a rash of early planning applications coming forward on greenfield, which could undermine the Council's spatial strategy and the preparation of the Allocations DPD. To guard against this and to channel development towards the most appropriate locations, the Council has the option of being more site specific in its Core Strategy. This option would in principle be supported by PPS12 and could apply to the delivery of one or more of the Ashingdon locations identified in Policy H2 and thus assist the Council's in demonstrating a five year supply of housing land.

It is acknowledged in Policy H2 that the Council will be flexible with regard to the timing of the release of land to ensure a five year supply of land. Therefore, there is no reason not to be site specific on sufficient land that will bring forward development to meet the Council's current 5 year shortfall. The respondent feels that the land north and south of Brays Lane would be one such location, which could be specifically allocated in the Core Strategy. The land has been broadly identified by the Core Strategy Preferred Options and its early release would ensure a continuous five year supply, assist in the delivery of public open space, a long held aspiration of the Local Plan and more importantly, resolve a long standing and the pressing need to improve access to King Edmund Secondary School.

Indicative Master Plan Option
The respondent has prepared an indicative master plan illustrating an option for the broad locations in Ashingdon. The master plan is designed to be illustrative of what could be achieved and is by no means the only layout option.

The purpose of providing this indicative option is to demonstrate that there is sufficient land available within the locations to accommodate the growth; in fact, the area could take more. In addition, the master plan illustrates a workable and tested improvement to the access to King Edmund School and shows a possible location for the 3.0 hectare expansion of the school, required by policy CLT 3. It is understood that it may be more viable to build a new school either on the existing site or on adjacent land. The master plan option caters for such an eventuality as well as providing options for the layout of housing and public open space. The respondent has commissioned a Highway Access Strategy, which considers the optimum location of access points to serve the land parcels. A copy of the strategy is attached to these representations.

The land parcels in the broad locations identified in the Core Strategy as East and Southeast Ashingdon are largely free of constraint and are developable and deliverable in the first five years of the plan period. Sufficient housing land is available to exceed the allocations set out in Policies H2 and H3 and there are many advantages to the location, which would allow for additional growth. The respondent owns approximately 28 hectares of land in the general vicinity of the broad locations of East and Southeast Ashingdon abutting the urban area, which would accommodate up to 1000 residential units at 40 dwellings per hectare, as well as providing an additional 3.0 hectares for expansion of the school. The land is available and developable in the short term. It has the following advantages in terms of developability.

• un-contaminated land in arable use;
• falls within flood zone 1;
• abuts the urban area;
• is accessible and within walking distance of a secondary and three primary schools, shops, services and public transport;
• accessible to main drainage facilities and utilities;
• within agricultural land classification 3;
• located in an area free of special or important landscape or biodiversity designations;
• does not contain any important ecological or sensitive habitat areas.

In relation to the Green Belt and the five purposes of including land within the Green Belt:
• the land parcels would round off or infill the urban edge;
• there is no possibility of coalescence, the nearest settlement is several miles to the east;
• the urban extensions will not encroach into the countryside, much beyond the existing urban edge;
• the location does not interfere or impact on the setting or special character of a historic town or settlement.

The land parcels are capable of exceeding the allocations set out in the Core Strategy whilst enhancing the access and size of King Edmund Secondary School, a vital component in the District's infrastructure. The development will result in only limited harm to the character and appearance of the countryside and as such, the Council should give greater consideration to the production of more detailed assessment through the Allocations DPD and an early planning application.

So that the local position is clear, the comment in the margin on Page 28 (alongside Preferred Option H2) regarding the viability of small schools should note that the County Council has a presumption against the closure of rural schools.

It is agreed that the concept of sustainable development lies at the heart of any decisions with regard to the location of new housing. Factors such as the re-use of previously developed land, accessibility to services, infrastructure capacity, deliverability, the re-use of on-site materials, the removal of contamination, and the protection of the local environment are key considerations.

Development at Hullbridge and Canewdon would not accord with the objectives of sustainable development. New housing should be directed towards those areas with a close relationship with Southend, namely the first and second tier settlements of Rayleigh, Rochford, Hockley and Great Wakering.

Second para: Not sure whether I would agree that one of the criteria of sustainable development re housing includes 'opportunities to utilise brownfield land' as their development can cause cramming and the loss of open space for people/fauna/flora, etc.
Para 4: Is there a factual relationship between the 'closer ralationship'to the two more major local urban areas of Southend and Chelmsford/Basildon?
Para 5: I welcome the balanced strategy.
para 11: Creating alternative land for employment use and displaced by residential potentially only increases intensification of development and encroachment, etc

We support the balanced strategy adopted for the settlement hierarchy resulting in Hockley/Hawkwell being positioned at the top tier. This follows Government guidance on location of development set out in PPS3, paragraph 38 stating that the relationships between settlements should be considered in deciding suitable locations for development. Hawkwell is considered to be a sustainable settlement, capable of accommodating development to the south. A potential site for housing put forward during previous consultations, to the south of Ironwell Lane, Hawkwell, it is well located in terms of services, facilities and employment opportunities and has good links with Hockley.

The overall number of dwellings to be build is high, especially 60 in the small settlement of Canewdon. All the houses will necessitate release of Greenbelt land. Additionally, such a proposal in this village will stretch all available facilities. Few buses, no jobs, already difficult road conditions. No footpaths on the already busy roads leading out of the Village. No facilities for teenagers, such as Youth Centres. CPRE feel that numbers should certainly be reduced considerable.

Character of Place
Whilst agreeing it is desirable to keep the traditional buildings, where possible the public would wish to see any new build in keeping and fitting in with the character of the surrounding areas.

Infrastructure, Leisure and Tourism
Without a comprehensive assurance that the Infrastructure i.e. Sewers, Roads, Bus Routes, Schools, Recreational and Medical Facilities are dealt with at the OUTSET of ANY new scheme would occur, then without this assurance, a ghetto type scheme would occur, with building being done for the sake of putting up bricks and mortar. At this moment in time there is great concern at the reduction of bus services and bus routes. This council feels it is rather a short sighted view and needs to be dealt with in the very near future.

Green Areas
It is vital our Green areas, some under Green Belt and some under recreational land is retained where possible. If this is reduced too much then the question will be that the health of the new and existing population will start to suffer. The idea of the Upper Roach Valley and Wallasea Island schemes is good - for those who are able to travel to and take advantage of these areas. They will of course aid the conservation of the wildlife habitats for all to benefit by.

Economic Development
Under this heading comes London Southend Airport. Now that the lease has been purchased we will all wait with some trepidation for the "preferred options" to come to light. There are very few people who do not want the Airport to succeed but the overwhelming concern is regarding the likelihood of the 24 hour operational action at the Airport, and with the proposed obvious increase in flights, quite a large proportion of the residents of both Rochford and Southend would have very little sleep. This would cause enormous health and economic problems - watch this space very carefully.

Housing
Unfortunately, no actual maps are yet available, the location on the given maps being somewhat vague. There is a genuine concern that the infrastructure for a further 2489 dwellings will be unable to cope BUT we realise, with an ever increasing population they are necessary.
Yes, they can be added on to already existing areas but perhaps a new village could be created towards the Rawreth Lane - London Road are of Rayleigh, bearing in mind a large new build has already been completed on the Park School Site. This would include shopping areas, schools, medical and recreational areas including village halls and of course the very necessary public transport facilities.

Green Belt
There must be a limited and tightly controlled release of Green Belt, but only if absolutely necessary. Once a start is made, without very tight control, they you might as well say bye-bye to it. It is a very necessary Green Lung.
Again no actual proposed plans are available.


Overall Views
Overall, whilst we do agree it is very necessary to look at sites for new housing and employment facilities etc., to be built and encouraged, without the infrastructure that is already in existence being vastly improved i.e. farmers making sure all ditches are cleared and lined where necessary to stop flooding, adequate sewage pipes and drains are attended to, roads and pavements brought up to date, then if the relevant Councils do not address these problems, what chance is there for any new proposals being dealt with properly.

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.

Please find enclosed herewith, representations on behalf of Barratts Eastern Counties. We trust these are in order and look forward to the acknowledgement in due course.

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.

Comments on behalf of Mr J Hart in response to the Council's public consultation on the Core Strategy Preferred Options document, dated October 2008, to form part of the Local Development Framework of Rochford District Council.

The Council's acceptance that some Green Belt land will need to be released and 70% of new housing is to be on greenfield sites, as sustainable extensions to existing settlements within the plan period 2001 - 2021 is supported.

Our client is also in favour of focusing new housing development on the higher tier settlements (H2), which includes Rochford/Ashingdon, as part of the proposed balanced strategy.

However, our client does not support the Council's Preferred Options for the General Location and Phasing of future housing development, as set out in H1 &H2, which is to totally exclude North Ashingdon from any future housing development within the period up to 2025, now being considered.

Although our client accepts the possible concentration of growth in East Ashingdon may have merit, some growth within the North Ashingdon area is felt to be appropriate given the pattern of the existing settlement, the established infrastructure and accessibility enjoyed by this more established area.

Furthermore, our client suggests the topography and impact on the surrounding countryside is more in favour of some growth taking place within North Ashingdon than to the West of Rochford, in which substantial growth is anticipated on a scale likely to far more significantly encroach into the open countryside and reduce the separation between the settlements of Rochford /Hockley and between Rochford / Southend.

Our client therefore respectfully suggests some development within North Ashingdon should form part of the Core Strategy in its final form.

Comments submitted on behalf of Julian Hart
by Graham Jolley Ltd

Re: Rochford Core Strategy

On behalf of Rawreth Parish Council I write with reference to the preparation and agreement of the Rochford Core Strategy and express extreme disappointment at the lack of integrity by the members of the Local Development Framework Sub Committee and Rochford District Council Officers regarding the allocation figures for housing in the District.

Throughout all the previous and present paperwork Rawreth has not appeared and, therefore, should be included in Tier 4 - All other settlements. We are not part of Rayleigh and should not be considered so. We are a separate Parish and intend to remain so.

At various stages of the consultation process, and at West Area Committee meetings the direct question has been asked on many occasions, what is meant by "Rayleigh West", was this a reference to Rawreth? An answer to this question was often avoided, but on the 24th of June 2007 after releasing a list of sites that landowners and developers had suggested could be used for development the District Council stated that "so far no housing is suggested for Rawreth" and at a meeting of the West Area Committee on the 4th of September 2007, when pressed, Mr Shaun Scrutton eventually stated that "the Council's original proposal was for extensions to be made to existing urban settlements and, there are NO actual urban settlements in Rawreth" therefore the area referred to was not Rawreth. He clearly stated that "no substantial housing development was planned for Rawreth". Council would now like to know why months later the truth has been revealed and the reference to "Rayleigh West", does in fact mean Rawreth. This area is still being referred to as Rayleigh but now identified as North of London Road. This is NOT Rayleigh, but Rawreth.

Rawreth is the gateway to the District of Rochford and this allocation of 650 houses has been put forward for an area of the highest quality farmland, coupled with a further 200 houses on an area of land currently used as an industrial site, no confirmation or indeed indication has been made as to where the current industrial site will move to, but again it is highly probable that it will be within the Parish of Rawreth south of the London Road, therefore. in addition to the unjust housing proposals more land will be lost to a new industrial site, the location of which has never been discussed with residents, the Parish Council or the businesses who are directly affected and who rely on the units, location and facilities. There is nothing beneficial to the Parish by building a development of this magnitude, nothing of any quality would be added to the Parish and nothing of any benefit would be added for the residents, however this development would take away the character of the Parish, and valuable farmland and greenbelt would be lost. The Parish currently has an electoral role of 793, with a total of 373 dwellings, how can an extra quota of houses, 228% higher than those already in the Parish be justifiable, how can building on the open greenbelt be justifiable? This is not considered to be development of Rawreth; it is a vast unwanted expansion.

The Parish of Rawreth simply does not have the infrastructure to cope with any more development. Rawreth and the western side of Rayleigh has already seen vast expansion in recent years which has placed a huge strain on the existing roads, schools, doctors and amenities, Rawreth Lane is regularly at a standstill, yet this would provide one of the main routes into both the proposed developments.

Rawreth Parish Council strongly oppose development of this magnitude in the Parish, and state that any development should be proportionate with the number of existing properties, a figure in the region of 10%, equating to 40 new houses would be a fairer figure for consideration and on this basis the Council strongly urge the committee to reconsider the allocations that they have set for Rawreth, "Rayleigh West", and the sites they have chosen.

The Members of Rawreth Parish Council and the residents of the Parish look forward to receiving direct answers to the questions raised in this letter.

LDF - Core Strategy - Preferred Options.

On behalf of Rawreth Parish Council I confirm that this letter is a formal response of Objection to the Core Strategy Preferred Options with particular reference to the allocation of 1050 houses to be sited within the Parish of Rawreth - 650 initially "North of London Road", with a further 200 on the Rawreth Industrial Estate and 200 more at the edge of Hullbridge.

We believe that no development should take place until local infrastructure is in place and the roads are able to take the increased traffic that would result.

1. We believe that Rawreth should be included in Tier 4 - all other settlements, where additional development is considered unsustainable. Rawreth presently has 373 dwellings and to put in developments of 1050 houses which equates to a 228% increase is totally unjustifiable, unsustainable and would completely destroy the
character of Rawreth.

2 The huge development of 650 houses "North of London Road" Rawreth is totally
unacceptable. This land is good quality agricultural land which is protected by the
Green Belt -GB1 - fulfils all purposes under PPG2 and should be retained as such.
Once used for development this land can never be returned to agricultural use, and if
you continue to erode into our Green Belt and farmland it will be lost forever.


3. This particular area is part of the "Gateway to Rochford " and is the "strategic buffer"
between Rayleigh and Wickford. Reference is made in the document to "avoiding coalescence" of villages/towns - a development of this size immediately erodes this buffer, starts coalescence and destroys the rural character of Rawreth.


4. The document clearly states that "Brownfield" sites would be considered before Green Belt land is used. This is not the case with the land ""North of London Road" and there are several sites within the area in the "Call for Sites" document that should be looked at first, these sites as we understand have not even been visited by the Local Development Framework Sub Committee and do not form part of the preferred options. These sites need to be visited, considered and the views of all the residents considered before any development areas become "site specific". A complete consideration has to be given to all the sites put forward in the "call for sites" and not just those that appear an easy option for development.

5. The roads and infrastructure in the Rawreth area are completely full to capacity. The A127, A1245, A129 London Road, Rawreth Lane and Watery Lane just cannot take any more traffic and this proposed development will increase traffic to a completely unsustainable level. On three occasions in the last month alone, incidents within and on the outskirts of this area have brought traffic to a standstill for hours along London Road, Rawreth Lane, Watery Lane/Beeches Road and the Hullbridge Road. It took some residents 1 ¼ hours to proceed along Rawreth Lane and into Hullbridge - a distance of 1 ½ miles.

The proposed development at the western edge of Hullbridge, which is, in fact, largely in Rawreth would also greatly increase the traffic problems in the area. We understand there would be a proposal to "widen/straighten" Watery Lane/Beeches Road, with a roundabout at the junction with the Hullbridge Road. This is an extremely dangerous junction even at the present time and would become increasingly so. There is also the question of where the traffic would go when it reaches Battlesbridge at the Western end, it cannot possibly cross the Bridge as this is "restricted" and in a Conservation Area, therefore, it would have to turn left and proceed to the A1245 -
a very dangerous junction.

6. The Services in the area would be unable to cope with this increase in housing - drains and sewers are already working to capacity. Recent heavy rain resulted in flooding in Watery Lane and the Rawreth Brook system has been very close to flooding twice already this year. During a meeting between the Parish Council and the Environment Agency we were advised that this situation will worsen with increased housing.

7. We believe that the appropriate amount of additional housing should be built on smaller existing sites thus enhancing the lives and environment of existing residents.
We believe RDC should consider the use of smaller sites that have been put forward, particularly in the Rawreth area and that the large development proposed "North of London Road" should be refused. We are at present in the process of developing our Community Garden in the centre of Rawreth Village with the help of a Community Initiatives Fund and believe that a reasonably sized development of houses in that area could be of benefit to our village. It may be that any development of this nature could include a village shop which would be of enormous value to local residents.

8. Large numbers of housing in one area, as stated in the infrastructure requirements, will necessitate a new primary school. County figures suggest that there will be surplus places in Rayleigh schools even with new housing. Obviously these will be in the wrong parts of the town so increasing the risk that an existing school could close .It makes sense to spread the development in smaller sites around the town, avoiding closure and preventing unnecessary provision of a new school.

9. Relocation of Rawreth Industrial site to a vague area south of the London Road near
Carpenters Arms would take further green belt, admittedly of moderate attraction, from the Parish. It is therefore suggested that an area bounded by the A127, A130, A1245 and the railway to the north gives the chance to provide high quality well designed industrial site with potential to use alternative forms of transport in the future.

10. Further use could be made of the land opposite Michelin farm. This land has been despoiled in recent years and landowners could and should be made to forfeit the full value of their land by way of compulsory purchase powers for use as a travellers site to provide some of the required pitches necessary for the Rochford District and to remove the illegal site on the A1245 at Bedloes Corner.

On behalf of Rawreth Parish Council I look forward to receiving an acknowledgement of this letter.

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.

INTRODUCTION

We act on behalf of Mr Dudley Ball - a resident of Church Road, Hockley and are instructed to submit Representations on their behalf as part of the Consultation on the emerging Core Strategy.

Our Representations are in two parts:-

Part A: General Representations
Part B: Schedule of Requested Amendments

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.

In particular, we note the inclusion in H2 of a location at West Hockley with a projected capacity of 50 units in the period to 2015. It would appear possible that this relates to potential capacity that might become available on land known as Pond Chase Nurseries. We have no specific objection to the inclusion of this site - but this would strengthen the case for a careful review of the Green Belt boundary in the general vicinity of Pond Chase Nurseries and Church Road, Hockley. The existing Green Belt boundary in this part of the settlement is highly arbitrary and has been blurred by development that has taken place on the edge of the town over a number of years. We refer to this matter again shortly in relation to the Green Belt.

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.

In addition to the need to amend the Green Belt boundary to facilitate the selected General Locations, it is considered that a wider review of Green Belt boundaries should also be undertaken. There are many small scale opportunities to adjust and rationalise the Green Belt boundary which would enable various small sites to come forward without material conflict with the purposes of the Green Belt. We have already referred to one such general area, namely Church Road, Hockley, where a more appropriate urban edge could be defined. We believe it is important that both larger and smaller adjustments should be agreed to avoid regular nibbling at the Green Belt boundary which would undermine confidence in Green Belt policy.

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. Any changes to the Green Belt boundary on the western side of Hockley, and particularly in the vicinity of Church Road, will not raise any flood risk issues.

Transport

We fully endorse the Preferred Options in T1 Highways and T2 Public Transport.

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.

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: SCHEDULE OF REQUESTED 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. Commit to undertake a comprehensive review of the Green Belt boundary to enable small sites to come forward for development at the Site Allocations DPD stage where this would not harm the purposes of the Green Belt, sepecially where a rationalisation of the boundary is justified.

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

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

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

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

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