H3 General Locations Post-2021 - Preferred Option

1170 houses will be built close to Ashingdon Road in Rochford. The Ashingdon Road will not be able to take this extra traffic but no pproposals, or costs, are given for improvements.

CPBC agree that it is necessary to identify general areas for residential development post 2021. In-line with the East of England Plan any review of Green Belt boundaries should identify sufficient land to avoid further review before 2031.

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).

Objection to Canewdon's proposed expansion.

1. The Ashingdon Road is already over capacity & will need to cope with potenially 60+ extra cars during peak times.
2. HGV's are not permitted via Scotts Hall Road and Lark Hill Road, leaving Creeksea Ferry Road as the main route for lorries and other plant required to construct the development. This will mean all HGV's and plant going via Canewdon Town Centre and past the school and throught the very community the document sets out to protect.
3. The infrastructure (drainage/elec/telephone) is already crumbling and inadequte. Additional housing will only strain this further.

insufficient infrastructure/support/emergency services at the moment. where are the plans to support all these houses?

where are all these extra people coming from to live in this 'expansion'?

No further expansion is possible without central goverment funding for infrastructure .Any developement without that funding is unsustainable .

The area of south Hawkwell is too vague.

We welcome the allocation of residential development to the village of Canewdon prior to 2021. The general indication of development is south of the village and we strongly support this proposal.

It is our view that development to the north of the village is prevented by the Coastal Protection Belt designation and topography of the land. The east of the village is constrained by the limited road access available through the village. By developing land south of Anchor Lane direct access to the link roads to Rochford and Hockley can be easily achieved without detriment to existing residents of Canewdon.

We would refer you to the more detailed appraisal of the site submitted in the Allocations Document call for sites made by Richard Stacey. Whilst this submission indicated more land that required for the housing allocation of 60 units pre-2015 and 90 units post 2021 it is clear to see that other community facilities can be provided within walking distance of the village centre.

We would comment that the council should maintain a flexible approach to timing of the release of land to ensure the development progresses in the most cost effective way.

This site is owned by a single landowner who is keen to see the land developed. As a greenfield site with no constraints it is a very deliverable site. The site is also available immediately.

Estimated housing requirement is disputed but if more housing is needed then very little existing settlement enlargment is the possibly preferred option but only if the correct infrastructure is put in place. This is highly unlikely given the current economic climate.

As with Policy H2, further thought should be given to the distribution and extent of the housing allocations with a proportion of the housing allocations in Policies H2 and H3 being available for Tithe Park, perhaps described as: 'land to the south west of Great Wakering, adjoining the boundary with Southend'

The Rochford Core Strategy preferred options document (2008) recognises that:

o Rochford needs to plan for the delivery of 3489 dwellings between 2006-2026.

o The Government's target of providing 60% of new housing development on previously developed land has become unrealistic for Rochford and therefore it is proposed that 70% of this additional housing will need to be provided on green field sites.

o Green belt boundaries will need to be redrawn due to the limited opportunity to accommodate the development requirements outside of the green belt, and it will be inevitable that green belt land will have to be used for new housing development.

Stolkin and Clements (Southend) LLP support this overall approach.

Given that a large proportion of the required housing development will need to be provided on green belt sites, those sites that are to be allocated for new residential development should be in the most sustainable locations, in line with the guidance in PPS1 and PPS3.

The Core Strategy Preferred Options document recognises that the concept of sustainable development is at the heart of any decisions with regard to the location of housing, stating that:

"the primary factors in determining the location of future housing include current infrastructure (along with opportunities to deliver future infrastructure); access to services; facilities; housing demand/need; deliverability; public transport / possibility of reducing car dependency; opportunities to utilise brownfield land; community needs and physical constraints."

The Core Strategy Preferred Options document currently proposes to distribute the required housing throughout the district, based on the following settlement hierarchy:

Tier Settlements
1 Rayleigh; Rochford/ Ashingdon; Hockley / Hawkwell
2 Hullbridge; Great Wakering
3 Canewdon
4 All other settlements

The proposed hierarchy focuses on what are classified as higher tier settlements, whilst allocating a proportion of housing to the lower tier settlements (with the exception of the fourth tier).

Importantly, the document recognises the possibility of development in the eastern part of the district, around the settlement of Great Wakering, which is close to our clients' site, Tithe Park.

However, the document does not consider Rochford District in its wider spatial context, particularly its relationship to Southend. A potential extension to Southend has not been considered in any of the alternative options set out in Policies H2 and H3.

The importance of considering the wider spatial context is recognised in PPS 12 (paragraph 4.17) concerning Core Strategies, which sets out that many issues critical to spatial planning do not respect local planning authority boundaries, and noting housing markets and commuting catchments as examples which often cover larger areas. PPS 12 therefore advises that local authorities should explore and exploit opportunities for joint working with neighbouring authorities.

Southend comprises a large urban area, and has an extensive boundary with Rochford. The importance of Southend within the region is recognised in Policy SS3 of the East of England Plan, SS3 which seeks to focus development in Southend and other major settlements within the region.

An extension to Southend on land currently within Rochford District's administrative area provides numerous benefits.It will assist Rochford in meeting the relevant housing targets, whilst providing a sustainable form of development with the new residential development benefiting from access to the amenities and infrastructure that the location adjacent to Southend affords.

A masterplan of the Tithe Park site is provided with these representations and shows how residential development, community uses and open space can be provided. This is an illustrative plan and can be modified to incorporate different permutations/number of dwellings and other uses, in line with the views of Rochford District if so identified for residential development in the Core Strategy.

The development of Tithe Park as an urban extension to Southend is a more sustainable solution than are the proposed locations currently put forward in the Core Strategy Preferred Options document. For example, with reference to the primary factors determining the location of future housing as stated in the document and quoted above:

• Current infrastructure (along with opportunities to deliver future infrastructure) - the site is served with existing pedestrian and vehicular access as outlined in the masterplan.
• Access to services and facilities - the site is within an 800 metre walking distance of the Asda superstore, the wide range of community amenities within Great Wakering and Friars Park.
• Housing demand/need - N/A - A demand/need has clearly been identified by the East of England Plan.
• Deliverability - the site is owned by one landowner, Stolkin and Clements (Southend) LLP, who are committed to bringing the site forward for development within the next 15 years.
• Public transport / possibility of reducing car dependency - Currently bus routes run along Poynters Lane and it is intended to ensure a bus route passes through the site to increase patronage and sustainability. A green travel plan will promote these issues
• Opportunities to utilise brownfield land - N/A as the Core Strategy has identified the need to develop green field land.
• Community needs and physical constraints - Community uses can be provided on site. There are no physical constraints, the site is relatively flat and only a very small part of the site falls within an area of flood risk.

More information on the site in relation to these sustainability factors is detailed in the accompanying masterplan.

Furthermore, the community infrastructure which is required to be accommodated with the new residential development at Great Wakering, as set out in appendix 1 of the Core Strategy Preferred Options, can also, or alternatively, be accommodated within the proposed development at Tithe Park: public open space, play space and community space.

The proposed public open space and community facilities could be made accessible to the existing residents of Rochford District, and, in particular, Great Wakering by extending the existing public footpath, as indicated within the proposed masterplan, and public transport can be upgraded to connect Great Wakering with the proposed new facilities.

Providing a sustainable urban extension to Southend, will have the benefit of directing a significant amount of development away from the existing villages within Rochford District, in particular the settlements identified in the document as Tier 2 and Tier 3 settlements i.e. Hullbridge; Great Wakering and Canewdon, and where new residential development may be more sensitive.

Currently, a significant amount of development is proposed in the document as extensions to these lower tiered settlements, and this could change the character of the villages and put a strain on infrastructure, and social and community resources. By reducing the amount apportioned to these villages, the character of these settlements can be maintained.

The development of Tithe Park will not result in coalescence.

In conclusion, further thought should be given to the distribution and extent of the housing allocations with a proportion of the housing allocations in Policies H2 and H3 being available for Tithe Park, perhaps described as: 'land to the south west of Great Wakering, adjoining the boundary with Southend'.

The same comments as H2 apply, albeit reference to 'availability' of sites within 5 years is not a relevant test.
The comment that the release of land needs to be flexible is welcomed. The policy should allow for sites to be brought forward prior to 2021 should non-delivery of the Policy H2 sites become apparent.

No further development should take place unless Government provides money for the proper roads to take traffic

Full text
This policy is unnecessary; there is no obvious justification for holding back these units to the latter years of the plan. The Council will be left with no flexibility, if the delivery identified in the first two phases does not materialise or if it exceeds current expectations. It is commonplace in other Core Strategies that have been adopted to allow a 10% contingency. Rochford has allocated its RSS minimum requirement and allows no flexibility to adjust if the need arose.

The housing numbers can be placed in one policy and in a single table. The Council may prefer to see some locations developed ahead of others and if so, there can be policies and reasoned justification set out in the Strategy to explain why this is necessary. There does not appear to be any identified infrastructure requirements, which will affect the release of numerous sites and as such no reason to set 5 yearly tranches for the release of land.

There is an absence of explanation in the Strategy or in the evidence base that points to the reasons why specific locations have been held back to post 2021. If the Council is to maintain a three tiered release of land then it must explain in its evidence base, why certain sites appear in certain phases. It is surprising that the phasing does not closely align itself with the settlement hierarchy explained on pages 26 and 27. For example, the allocations for South East Ashingdon, which lies in the first tier, receives 120 units up to 2015, nothing 2015 to 2021 and then 380 units post 2021. There is no explanation for this or any obvious logic as to why the allocation is phased in this way. Development in this stop-start fashion is uneconomical and causes prolonged upheaval, which may present developers with delivery difficulties and delay the provision of community infrastructure.

The Core Strategy only needs to have a single table, which identifies the broad locations and provides an estimate of the amount of units that are likely to be delivered in each of those locations.

The emphasis in the Core Strategy should be shifted towards the flexible delivery of the maximum amount of housing in the most sustainable locations. It should not be about prescriptive delivery of the minimum amount of housing required in what appear to be arbitrary phases.

The District Council has adopted a balanced approach to the distribution of additional housing locations, which is based on identification of tiers of settlements defined by reference to their accessibility to jobs, services and facilities (some of which lie outside the District) and the need to protect the valued environments within the District. This approach is generally supported, although further thought should be given to how to secure sustainable functional relationships between proposed development locations and established settlements and features.

The proposed development at South East Ashingdon should be further examined to ensure that the scale of development at the location would not place too much pressure on the highway network passing through Rochford town centre.

Provision of County Council services at all of the proposed development locations would require adequate funding to be forthcoming through planning obligations and standard charges. The District Council is encouraged to engage in further discussions with County Council services during the remaining stages in preparation of the Core Strategy to ensure effective implementation and delivery of necessary County Council services and facilities to support the proposed development locations.

It is considered that there should be minimal new development at the smaller settlements of Hullbridge and Canewdon given their remoteness and the likelihood of harm to the character and appearance of the countryside in these rural locations.

We support the broad locations for development detailed in H2 that are in accordance with the settlement hierarchy. We particularly support the indicative level of growth directed towards south Hawkwell. Paragraph 10 and 36 of PPS3, state that to support the Government's objective of creating mixed and sustainable communities, housing should be developed in suitable locations, offering a range of community facilities and good access to jobs, key services and infrastructure. Paragraph 38 states that LDDs should specifically take account of the accessibility of proposed development to existing local facilities, infrastructure and services including public transport.

This continuing release of Green Belt land is unsustainable. Intensification of Town Centre and urban areas should be maiximised prior to release of Green Belt.

Re: Call for Sites - Site at Junction of Napier Road and Albert Road - Rayleigh

Design Associates act on behalf of the owner of the above land at the junction of Napier Road and Albert Road, Rayleigh and have previously offered on behalf of our client, in our letter dated 21st March 2007, the above land be included in the council list of sites for possible future housing. The site is referred to as a Number 94 on you "Call for Sites list" and we hope will be selected for release from the green belt for future housing, when the Site Allocations Document is produced next year.
We make the following comments, on behalf of our client, in response to the public consultation on the Core Strategy Preferred Options Document:
1) Our client ids heartened to note that some green belt land is deemed to be required to be released for new housing, by the Council, and that the council are in support of new residential development occurring mainly to the edge of existing main settlements. It is considered that Rayleigh is the only urban area with a principle town centre and it has the best to services in the district.
2) Taking into account the Council's vision for sustainable new dwellings which integrate into existing communities, together with the stated intension of the Council that 70% of new housing will be on Greenfield sites, as sustainable extensions to existing settlements within the plan period 2001-2021, we believe the locations shown on the key diagram for the allocation of new housing development does not give adequate recognition of the valuable contribution potential sites situated at the eastern edge of the settlement area of Rayleigh will give.
3) It is considered that some modest growth to the east of Rayleigh could be accommodated without detriment to the upper Roach Valley or the separation between Rayleigh and Hockley.
4) Taking into account the above we ask the council to give further consideration to the H2 options so as to provide for a greater number of dwellings around Rayleigh with some additional housing to the east of Rayleigh not only for the 2001-2021 period but also the post 2021 period. In this respect we ask you to also consider a variation to the preferred option set out in H3, consistent with the above mentioned suggested variation to H2.
5)We are not suggesting eastern Rayleigh should represent a potential major residential growth area but consider the area should not be totally excluded from the possibility of some modest residential growth which if felt would have sustainability advantages over some of the more outlying locations indicated on the Key Diagram.
6) Please take the above comments into account when considering the final version of the Core Strategy and in connection with the ongoing consideration of our client's land as a possible future housing site.

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

1.0 Instructions and Introduction

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

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

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

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

Peter Kneen BSc (Hons) MSc MRTPI
Planner

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

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

2.0 Housing:

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

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

Policy H1 - Distribution

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

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

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

Policy H2 - General Locations and Phasing

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

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

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

Policy H3 - General Locations Post 2021

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

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

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

Policy H4 - Affordable Housing

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

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

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

Policy H5 - Dwelling Types

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

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

Policy H6 - Lifetime Homes

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

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

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

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

Policy GB2 - Rural Diversification and Recreational Uses

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

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

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

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

Policy ENV4 - Sustainable Drainage System (SUDS)

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

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

Policy ENV8 - Code for Sustainable Homes

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

5.0 Transport:

Policy T1 - Highways

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

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

Policy T2 - Public Transport

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

Policy T4 - Travel Plans

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

Policy T5 - Cycling and Walking

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

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

Policy T7 - Parking Standards

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

6.0 Character of Place:

Policy CP1 - Design

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

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

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

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

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

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

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

Policy CLT6 - Community Facilities

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

8.0 Summary:

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

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

RE: CORE STRATEGY PREFERRED OPTION - COMMENTS

Please find set out below my comments in respect of the Core Strategy Preferred Options dated October 2008. I would be grateful if you could register these comments and confirm receipt in due course.

Policy H2 General Locations and Phasing - Objection

I welcome the allocation of residential development to the village of Canewdon prior to 2015. I do however object to the identification of land South of Canewdon and feel strongly that it should be allocated to the North and North West of the village at Canewdon Hall Farm.

Land south of Canewdon has no defensible boundary. Currently Anchor Lane defines the southern boundary of the village. To move beyond this line takes development into open agricultural land where there is no defined boundary which could limit development in the future.

The development at Canewdon Hall Farm would wrap around existing residential development creating a contained village settlement. The central village services would be easily accessible from development in this location.

I would refer you to the more detailed appraisal of the site submitted in the Allocations Submission. I have for ease of reference attached a plan of this 9 acre site. I believe it can provide supporting community facilities such as play space and recreational facilities on the west side of the village making them more accessible.

The site has a natural defensible boundary provided by the topography of the adjacent farm land. The site is level but adjacent farm land slopes down to the River Crouch. Development cannot extend beyond the area indicated.

Part of the site is developed with farm buildings and farm yard and as such there would be minimal loss of productive agricultural land in this location.

This site is owned by my family and I am happy to see the land come forward for development. The site is available immediately.

Policy H3 General Locations Post 2021 - Objection

I welcome the allocation of residential development to the village of Canewdon prior to 2015. I do however object to the identification of land South of Canewdon and feel strongly that it should be allocated to the North and North West of the village at Canewdon Hall Farm.

Land south of Canewdon has no defensible boundary. Currently Anchor Lane defines the southern boundary of the village. To move beyond this line takes development into open agricultural land where there is no defined boundary which could limit development in the future.

The development at Canewdon Hall Farm would wrap around existing residential development creating a contained village settlement. The central village services would be easily accessible from development in this location.

I would refer you to the more detailed appraisal of the site submitted in the Allocations Submission. I have attached a plan of this 9 acre site. I believe it can provide supporting community facilities such as play space and recreational facilities on the west side of the village making them more accessible.

The site is has a natural defensible boundary provided by the topography of the adjacent farm land. The site is level but adjacent farm land slopes down to the River Crouch. Development cannot extend beyond the area indicated.

Part of the site is developed with farm buildings and farm yard and as such there would be minimal loss of productive agricultural land in this location.

This site is owned by my family and I would be pleased to see it come forward for development. The site is available immediately.

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.

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.

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.

Comments on behalf of Mr & Mrs T Harold 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.

It is noted 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.

Our clients support the Council's preferred option for the distribution of land for new housing, broadly in accordance with the key diagram, so as to avoid the over intensification of existing residential areas, in accordance with H1.

The approach of focusing new housing development on the higher tier settlements, including Rayleigh, Rochford/Ashingdon, and Hockley/Hawkwell is supported, as part of the proposed balanced strategy. Our clients consider preference should be given to brownfield sites already developed.

Our clients support the Council's Preferred Option for the General Location of future housing development, as set out in H1, on the understanding this does not exclude their own site (see call for sites ref number 114) and they feel the West Hockley area has the potential for a greater number of dwellings both during the pre 2015 period and between 2015 and 2021.

Accordingly our clients ask for the tables in H2 and H3 to be amended so as to include a higher allocation for the West Hockley area. This can be achieved without encroachment into the open countryside and will not prejudice the separation between Hockley and the neighbouring settlements of Rayleigh and Hullbridge.

Our clients' above mentioned site has been put forward as a mixed site for both residential and public open space. As such they suggest this represents an opportunity to make a significant contribution in accordance with preferred option CLT5 and to link into the Green Grid Greenway and the recreational potential of the land to the south-west of Hockley, within the Upper Roach Valley.


Comments submitted on behalf of Mr & Mrs T Harold
by Graham Jolley Ltd

Comments on behalf of Mr A C E Kingston 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.

It is noted with interest the Council's acceptance that some Green Belt land will need to be released and 70% of new housing is to be on green field sites, as sustainable extensions to existing settlements within the plan period 2001 - 2021. Our client notes also that the Council accept there are insufficient brownfield sites within the District to meet projecting housing needs and, therefore, Green Belt land will need to be released.

Our client supports the Council's preferred option for the distribution of land for new housing broadly in accordance with the key diagram, so as to avoid the over intensification of existing residential areas, in accordance with H1.

The approach of focusing new housing development on the higher tier settlements, including Rayleigh, Rochford/Ashingdon, and Hockley/Hawkwell is supported, as part of the proposed balanced strategy. In this respect our client notes Rayleigh is the only first tier settlement which is classed as a principal town centre and has the best services within the District.

Our client is in broad support of the Council's Preferred Option for the General Location and Phasing of future housing development, as set out in H2, which is to include a significant element of new housing within the south west Rayleigh area. However, it is suggested that, in view of the above mentioned sustainable advantages of Rayleigh, together with the uncertainties of longer term housing demand, it is appropriate to consider a provision for some additional housing within the south west Rayleigh area for the post 2021 period.

This area is felt to have more potential than currently indicated in the table forming part of H2 and our client therefore asks for the Preferred Options table of H2 & Option H3 relating to the general location for housing post 2021, to be modified accordingly. This would provide a more balanced growth for Rayleigh in the long term, particularly taking into account accessibility to the town centre.

The Council's intention to satisfy future housing demand mainly by developing green field sites situated on the fringe of the main urban areas within the western part of the District will inevitably require the release of some of the existing Green Belt. Our client therefore suggests GB1 needs to be amended, since the stated intention of this option, to seek to direct development away from the Green Belt, is considered to be in conflict with the controlled balanced release of some Green Belt land, which is clearly unavoidable as an integral part of the Councils stated future Core Strategy.

Our client notes the Council intend to give priority to the release of Green Belt land which contributes least towards the purposes of the Green Belt over other Green Belt locations. In this respect our client's land within the south west Rayleigh area represents an infill between established urban areas which would not visually encroach into the open countryside or result in the merging of neighbouring settlements.

RE: Ivanhoe Nursery, Ironwell Lane, Hawkwell, Hockley, Essex SS5 4JY

We act as planning agent for Stuart Ross, who is the owner of the above property. At a recent meeting with Judith Adams, to discuss the residential development potential of this site, it was suggested it would be appropriate for our client to formally submit this site to the council for release from the green belt, as part of the Council's ongoing call for sites and to make submissions in response to the current consultation on the Council's published Core Stratergy Preferred option.

Having subsequently spoken to you on this matter, you have kindly agreed for us to make submissions in the form of this letter which, as agreed, we are submitting to you electronically (and will also deliver to you by hand.) You will appreciate our client's comments on the Core Strategy Preferred Options are therefore being made prior to the 17th December 2008 deadline.
Accordingly, on behalf of our client, we first ask you to kindly consider the above site of development, as part of your preparations of the Council's Allocations Development Plan Document.
As requested, we are pleased to submit the following relevant information-
a) CONTACT DETAILS- Our name, address and contact address are set out in our letterhead. our client's address is Emberzone Ltd, St Nicholas House, Church Road, Rawreth, Essex SS11 8SH.
b) LOCATION PLAN- A map showing the location of the above site which we ask you to consider for possible future residential development is enclosed. As, requested the area of land for your consideration is outlined in red.
c)STATEMENT OF OWNERSHIP - our Client's above mentioned Company has the freehold ownership of the land edged red, referred in the previous paragraph.
d)SIZE OF SIGHT- The land in question outlined in red is approximately 1.4 hectares.
e)SITE CONSTRAINTS- Our initial thoughts on the planning constraints affecting the site include the need to have regard to improving the quality of vehicular access along ironwell Lane and the removal of the Site form the Green Belt
f)STATEMENT OF SITE SUITABILITY - We consider the land edged red is suitable for residential development because the sight is at the fringe of an urban area situated within a sustainable location, near to the facilities, services and public transport connections available to the Hawkwell area. The development of this sight would round off the existing development without any significant encroachment into the open countryside, taking into account the pattern of existing development and the topography of the area.
There is already a substantial amount of built form on this site comprising a detached bungalow, three large greenhouses and substantial outbuildings which result in approximately 50% so site coverage with buildings. As a result, the redevelopment of this site is likely to significantly improve the openness of the area and form a much better visual transition between the urban area to the north west, of which this site could form part and the open countryside to the south and east.
g)TYPE OF DEVELOPEMENT PROPOSED-On behalf of our clients we ask for the above mentioned land edged red to be allocated for residential development. It is considered the site would be appropriate for mixed housing which could include a significant element of much needed affordable housing. Furthermore, if required, part of the site could be retained as new public open space.
h) OTHER RELEVANT CONSIDERATIONS-Other material considerations which we ask you to take into account include the potential highways improvements which could result in conjunction with the residential development of this site. Furthermore, the site provides potential for funding to enhance the cycle network envisaged as part of the comprehensive linkage between Rochford and Hullbridge.
Significantly, it is felt that development of this sight would be consistent with the councils current Preferred Core Strategy, which includes the possibility of a signficant amount of growth within the south Hawkwell area.
Further comments on behalf of our client, in response to the Council's consultation on the core Strategy Preferred Options are set out in the documents attached to this letter, which we ask you to kindly accept as our client's response to the current public consultation.

Executive summary

RW Land & Planning Ltd welcome the opportunity to submit representations on
behalf of J F Spencer & Son Ltd in response to the Core Strategy Preferred Options, published by Rochford District Council in October 2008.
This submission is split into two parts:

1. Core Strategy Representations
It is felt that the "Core Strategy Preferred Options" does not provide a balanced or
justified distribution of the housing numbers throughout the district and that key
sustainability principles have been disregarded when identifying the preferred housing allocations.

Accordingly, it is considered that Hockley, as a first tier settlement within the district should be allocated a larger proportion of the housing numbers in the area already identified on the Key Diagram as being suitable for housing growth (West Hockley).

2. Site Suitability Appraisal - Land and property at Folly Chase, Hockley

A suitability appraisal of land off Folly Chase, Hockley including the residential plot
known as Thistledown, demonstrates its suitability as a deliverable location for housing in line with the Core Strategy principles. The sites location, within walking distance of Hockley town centre and the available facilities, services and public transport links locally and regionally identify this site as being able to meet sustainability principles and should be considered
appropriate for development.

A Masterplan illustrates one of the many ways this site can be developed for housing and provide a deliverable opportunity to provide social housing within a sustainable location, reducing the reliance on the private car.
Appendix 1 - Site Suitability Matrix
Appendix 2 - Site Photographs

1. Core Strategy Representations
Sustainable Community Strategy - Page 6
We welcome the importance the Council place on the close links between the Sustainable Community Strategy and the Core Strategy including ensuring accessibility to services.
Housing Issues and Options - Page 16
We welcome the acceptance by the Council that infilling alone will not be able to provide the housing numbers necessary and that this would have an adverse effect on the character of the towns.

Whilst we acknowledge that the release of greenfield sites for development present
an opportunity to provide new infrastructure, it is surely more sustainable to concentrate additional housing on greenfield sites which benefit from existing infrastructure and nearby services. This would then enable Planning Obligations to improve services and facilities rather than having to focus on providing basic
infrastructure.

Transport Issues and Options - Page 18
It is acknowledged within the Core Strategy that car dependency within the district
is higher away from the main three settlements of Rayleigh, Hockley/Hawkwell and
Rochford/Ashingdon, primarily due to the rail links within these three towns.

This principle of sustainable development therefore dictates, unless there is a justifiable reason, that the majority of the housing proposed should be within or adjacent to the main three settlements.

Settlements Issues and Options - Page 20
We welcome the four tiers of settlements and the Council's acknowledgment that Hockley is classed as a Tier One settlement containing a "local town centre catering for local need".
We also agree that the Second tier Settlements of Hullbridge and Great Wakering have a "more limited range of services access to public transport is relatively poor".

H1 Distribution - Preferred Option
We acknowledge that brownfield sites should take priority over the development of
Greenfield sites. However, with a rising housing market over recent years, many of the sites identified in the Urban Capacity Study still remain undeveloped it could be argued that if the sites were suitable for development they would have come forward by now. The Council must therefore demonstrate that there is evidence to
suggest that the remaining sites are genuinely available and deliverable within the specified phased timescale.

If they are not deemed to be available, the housing must be allocated on greenfield sites associated with a Tier One settlement.

H2 General Locations and Phasing - Preferred Option

It is welcomed that the Core Strategy accepts that greenfield development will be necessary in order to achieve the required housing numbers.
As set out in the H2 chart and Key diagram, the reliance of Tier Two and Three settlements (Hullbridge, Great Wakering and Canewdon) to provide 860 houses pre 2021 is unsustainable, unjustified and contrary to sustainable planning
guidance at national, regional and local level.

It is acknowledged by the Core Strategy that the Tier Two and Three Settlements only having limited services and poor public transport links and despite this, over 34% of the greenfield housing allocations have been located here without justification.

We acknowledge that development in Tier Two and Three Settlements is necessary to ensure that village communities continue to grow. However, there has been no justification provided that warrants such a large percentage of the overall housing numbers being allocated to these lower tier settlements.

The distribution of the greenfield housing allocations as it stands is contrary to PPS3 which provides clear local level guidance for Core Strategies when deciding on housing locations:
"...at the local level, Local Development Documents should set out a strategy for
the planned location of new housing which contributes to the achievement of
sustainable development." Part of which is "...the contribution to be made to cutting carbon emissions from focusing new development in locations with good public transport accessibility and/or by means other than the private car..."
Even with significant public transport improvements, residents will have to travel a
substantial distance to Rayleigh, Hockley/Hawkwell or Rochford/Ashingdon in order to catch a train and go beyond the local area. This level of development in the lower tier locations are promoting a significant increase in carbon emissions, contrary to PPS3, even if the residents travel by public transport, which the Core Strategy accepts is not the current situation, with high car dependency.

Despite being a Tier One Settlement with an active and diverse town centre and good public transport including a train station, Hockley has only been allocated 50 houses (2% of the total greenfield allocation within the district). This goes against the Core Strategy vision of concentrating development on Upper Tier settlements which have the services and facilities to accommodate additional development.
In light of this unsustainable and unsound approach to housing distribution, Policy H2 General Locations and Phasing - Preferred Option and the Key diagram should be amended to reduce the proposed housing numbers associated with Tier Two and Three settlements and redistribute the surplus to Tier One Settlements and Hockley in particular which has received an unnecessarily low number of houses
despite existing services and facilities to accommodate additional development.

It is proposed in the analysis set out in Appendix 1 that Land at Folly Chase, West Hockley is suitable and capable of accommodating circa 200 houses. Policy H2 should be amended to reflect this.

We welcome a flexible approach to the release of land in order to maintain a five year land supply is supported and necessary. It is imperative, however that in assessing the release of land, the landowners willingness to sell or develop the site is taken into account.

We welcome the identification of West Hockley as being a suitable location for development pre-2015.

H2 Alternative Options
We welcome the comments regarding North East Hockley and agree that the location would place undue pressure on the highway network and that it is unviable for development.

H3 General Locations - Post 2021
The continued reliance on lower tier settlements post 2021 is again unjustified and
unsustainable with 340 homes proposed. These locations, even following improvements to the infrastructure will not provide genuine alternatives to the private car due to the length of journeys required to get to services, facilities and employment.

H4 Affordable Housing
The 35% level proposed must be based on sound qualitative evidence with the flexibility to be reduced if there are site specific circumstances that warrant it.

We do not accept the desire by the Core Strategy to "pepper pot" social housing
throughout developments, it causes difficulty for Housing Associations to manage their properties effectively and efficiently. This should be amended to allow for clusters of social housing units in say, groups of 15-20.

H5 Dwelling Types
Whilst we acknowledge that PPS3 suggests that local level planning documents should assist in developing a suitable mix of houses on sites, PPS3 para 23 also states that developers should "...bring forward proposals that reflect demand and the profile of households requiring market housing...". It is therefore imperative
that H5 makes reference to the influence of market demands and does not solely
rely on the advice of the Strategic Housing Team as the policy currently intimates.

H6 Lifetime Homes
We welcome the fact that the pursuit of 100% Lifetime Homes from 2010 will be viability tested.
H Appendix 1

We welcome the associated infrastructure required in relation to development at
West Hockley.

As part of the development of Land off Folly Chase, Hockley, further community benefits beyond those listed could be included, such as a new community woodland and play space.
Proposed development at the lower tier settlements (Hullbridge, Great Wakering
and Canewdon) are reliant on significant public transport improvements which sequentially is contrary to sustainability principles of focusing development in areas of good public transport, with the ability to improve further.

ENV3 Flood Risk
We welcome the proposal to pursue development in areas which fall into Flood
Zone 1 and the use of the sequential test in PPS25.

ENV4 Sustainable Urban Drainage
SUDS is not always the best environmental option for dealing with drainage. We welcome the viability test intended to identify those sites where SUDS is not appropriate.

ENV8 Renewable Energy
We recognise the Core Strategies desire to adhere to the Code for Sustainable Homes star rating, however, there remains a doubt as to whether Code Level 6 is realistically achievable within the current timescales. There will always be the potential for National Policies to alter the rating system and timescales. There is a
requirement for the Core Strategy to remain flexible and be in parity with The Code for Sustainable Homes, or its successor. Moving away from the Code should it alter, would alienate the Districts development sites from developers and reduce the likelihood of them being built within the Core Strategy phasing timescales.

We welcome the decision to not pursue the 10% renewable "Merton Rule" as piecemeal renewable energy production is not an efficient approach to its production.

T1 Highways
We welcome the objective to locate and design housing developments that reduce the reliance on the private car.

T2 Public Transport
We welcome the objective developments must be well related to public transport, or accessible by means other than the private car.

RTC1 Retail
We welcome the designation of Hockley as a district centre and that retail developments will be focussed towards it along with Rayleigh and Rochford.

RTC5 Hockley Town Centre
We welcome the proposals contained within this policy for the improvement of facilities, services and town centre living within Hockley Town centre.

CLT1 Planning Obligations and Standard Charges
We welcome the continued use of Planning Obligations to secure reasonable on and off site improvements as set out in Circular 05/2005.
Standard charges must take into account the level of impact the future residents are likely to have on the strategic infrastructure and be negotiated on a site by site basis.

[more details including photographs regarding the site put forward can be found our ref allocations no. 69]

Summary of Representations on behalf of MD Smith & Son

Land at the former Hambro Nursery, Rawreth (see attached location plan) should be utilised as part of the Core Strategy (CS) policies to help contribute towards delivering sustainable housing and employment opportunities, as part of a mixed use development on previously developed land. Notwithstanding the green belt designation which affects the whole district, the CS is not currently flexible enough to facilitate previously developed land within the District coming forward for appropriate uses. These opportunities should take a higher priority over future green field, green belt allocations.

Details of Representations

The CS recognises the need to provide a minimum of 4600 additional homes within the District. This should be stated within the CS as being a lower and not an upper limit for development in accordance with Policy H1 of the Regional Spatial Strategy (RSS), The East of England Plan. Setting a minimum target will help deliver the required and identified housing.

In addition, there is a need for the District to help contribute towards the delivery of 55,000 additional jobs within the Essex Thames Gateway area by reference to Policy E1. These two Policy references (H1 and E1) would help the conformity of the CS with the RSS and establish the need for additional growth.

Green Belt Study

Recognition of the relative constraints of the District are acknowledged and correct in contextual terms, as set out within the draft CS Key diagram. This clearly shows the constrained nature of the district. It is, however, difficult to determine the quality and contribution of the Green Belt designation in the absence of any detailed study to determine the relative quality, value and performance of the site against those criteria identifying the purposes of Green Belt designation as set out in PPG2 (Para 1.5). Whilst this appears not to have been undertaken within the main body of the CS or the Evidence Base, such a study would justify and support the Council's choice of options. Such a study would not necessarily identify some other site sustainability credentials which may make development in broad locations acceptable, but would enable the Council to identify and map out those areas which are most important in green belt terms to protect.

Development to the west of Rayleigh may not perform against all of the Green Belt functions which are to:

check the unrestricted sprawl of large built-up areas;
prevent neighbouring towns from merging into one another;
assist in safeguarding the countryside from encroachment;
preserve the setting and special character of historic towns; and
assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

All previously developed land, including the Hambro Nursery site, should be considered in a hierarchical manner with preference above green field allocations. The CS does not allow suitable flexibility within its policies for such sites to be considered either as part of mixed use or stand alone, residential or employment sites. In terms of PPS3 (Housing) the site performs well by making use of previously developed land where options for appropriate community facilities including open space and affordable housing could help sustain the existing local community. Options to make use of proposed cycle links could also be explored with adjoining landowners and the Hambro Nursery site could form the location of a sustainable business park or mixed community. The site also benefits from close proximity to existing community facilities at Battlesbridge including a doctor's, museum and public houses.

Strategic Housing Land Availability Assessment

It is noted that the Council relies upon a 2007 Urban Capacity Study (UCS) as part of its Evidence Base and the data it provides underpins the Council's housing land supply figures as set out in Policies H2 and H3. Using urban capacity as a means of assessing housing land supply does not accord with Government advice set out in PPS3, which advises that housing land supply should be assessed via a Strategic Housing Land Availability Assessment (SHLAA).

In light of the above we therefore object to the following policies:

H1, H2, H3, GB1, GB2, ED2, ED4 and T7.

Changes are proposed which may overcome our objections and incorporate suitable flexibility within the CS to deliver suitable development on previously developed sites in preference to greenfield housing allocations to the west of Rayleigh, north of London Road. Amendments as suggested.