H4 Affordable Housing - Preferred Option

I attended the CAC Meeting in Hawkwell.

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

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

Hockley Town Centre development must maintain the character of Hockley, and include a variety of shops, family restaurants,enhanced parking facilitiers, and facilities for the youth. It must consder appropriate facilities for people with disabilities.

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

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

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

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

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

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

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

Surely it is not unreasonable to expect there to be a planned infrastructure
put in place before all these houses are built. Where are all these new
roads going to go, stating the obvious that we do have the sea one side.

Also what about our farm land we need this protected for food supply.

One further comment, most people live in Hockley or come back to Hockley because of what it is now, when this wonderful vision for John Prescott eventually happens, no body will want to come back!

It is important to find the right balance between affordable housing and larger house developments. Future development needs to cater for key stage worker accommodation and smaller households without altering the present characteristic of Rochford District, which is dominated by larger properties at the middle to higher end of the housing market.

I am writing with Shelter's comments on the section in your council's Core Strategy Preferred Options relating to Affordable Housing, and in particular to Preferred Options H4 and H5.

Shelter notes that in the preamble to the preferred policy there is a recognition that there is "an acute need for affordable housing within Rochford District, equating to 131 net additional affordable dwellings per year." Shelter also notes from your Council's Annual Monitoring Report that since 2001 affordable housing has accounted for only 9% of new housing in the District.

Against this background, Shelter believes that the Council needs to set robust targets. Shelter also does not consider that previous thresholds have hindered the delivery of affordable housing.

Turning to Preferred Options H4 and H5, Shelter has the following comments:

1. The affordable housing requirement for developments of 15 or more units should be increased to 40%, this figure being more consistent with other parts of the region where the need is particularly great.

2. Affordable housing requirements should be set for developments of less than 15 dwellings; specifically for developments of 3 or more dwellings. In order to recognise the comments in the Alternative Options the precentage of affordable housing for smaller developments could be lower at either 30% or 35%.

3. The Government's target is that approximately 65% of affordable housing should be social rented. There is no provision for this in H4, and Shelter considers that this omission should be rectified by the inclusion of a requirement that at least 65% of all affordable housing units must be social rented.

4. Shelter welcomes the proposal in both H4 and H5 that developments should provide a mix of both market and affordable housing. However, with regard to H5 Shelter considers that a proportion of affordable housing provision within development should be required in the form of four-bedroom dwellings as well as three-bedroom dwellings.

We thank you for your letter of notification dated 5th November 2008 giving us the opportunity as an interested party to comment on the above and we respond as follows.

Provision for future housing in the Rochford District.

On the basis of past study of the Local Development Framework and previous, associated support documents which reject various alternative options such as a new town wholly constructed in the greenbelt, we consider the Council and the Planning Directorate have basically got it right for the following reasons, subject to certain comments herewith.

It is understood that the Council has a legal liability to make provision for a certain quota of future housing in the district the numbers being dictated by representative agencies of the Government. If adequate provision is not made by the Council, these outside agencies will have the power to dictate where and when such provision will be made. Something no one who lives in the Rochford District would really like to see.

We also understand that the total housing target for the period 2001 to 2021 is 4600 and from this year (2008) 3790 remain to be completed by 2021.

We believe that the Council's Policy H1 Distribution - Preferred Option of allocating sites a selective but more general spread in areas adjoining the existing settlement envelopes within the district, is the fairest and best case scenario. Also Policy H2 General Locations and Phasing - Preferred Option we feel is the best way forward under the circumstances. All settlements have previously evolved in this way and objectors should be mindful not to deny the district's young and relocating families the same choice, means and opportunity to live and work in the Rochford District.

Accepting that a singular equivalent development sited wholly in the greenbelt would destroy the existing character of the Rochford District, it is apparent that prospective sites within the existing town planning envelopes of the various settlements are inadequate to accommodate all of the required future development. Therefore, some areas of land currently designated greenbelt, albeit a minimum, will have to be released to supplement the deliverable land supply needed for the district's future development.

It is important that great care should be taken (although general quotas have to be met) that proposed gypsy/traveller sites and social rented housing should not be too concentrated in singular locations in the Allocations Development Plan Document. If the Council should fail to take such care we feel that this would change the character as well as the standards of the Rochford District, and place a greater burden on certain community resources. We therefore consider that social housing should be dispersed within mixed new housing projects as outlined in Policies H4 Affordable Housing - Preferred Option and H5 Dwelling Types - Preferred Option, in a sympathetic way together with intermediate, key worker and market housing to create a more sustainable development.

It makes sense that allocated sites will have to be within reasonable reach of existing services which may in some cases have to be extended or upgraded. Where specific sites are eventually allocated, landowners/developers should be encouraged to contribute to appropriate Section 106 Agreements to help facilitate any necessary upgrading of infra-structure (including local road improvement) but with due regard to viability.

Finally, in relation to the foregoing and with regard to requirements set out in H Appendix 1, as long standing landowners and residents of Rochford District, we feel it may be helpful in recommending to the Council and Planning Directorate, our joint deliverable proposal with Swan Housing Association, submitted under the Council's Call for Sites (Ref No 17) within the context of the release of greenbelt land in south west Hullbridge that the Council and Planning Directorate may decide to make.

CPBC support the 35% affordable housing target, in line with the East of England Plan. A flexible approach in exceptional circumstances is important to ensure developments remain viable and sites are deliverable. The possibility of contributing towards off-site affordable housing offers flexibility potentially enhancing the deliverability of a site. However in line with PPS 3: Housing, off-site provision should only be accepted were it is robustly justified.

Dear Committee

I could not believe the amount of comments or ideas that came from the floor that the members on the top table had not seemed to have even thought about. To me I got the impression that of "let them have their say then we will do as we have already agreed".

The three main areas under threat are all surounded by development, making small areas combine into one so in the end Rayleigh, Hockley, Hawkwell and Rochford will become one instead of spreading outwards leaving these small green areas as parks or leisure zones.

Once these small areas are gone they have gone forever and you won't be around in years to come when residents have to travel miles in a car to have a walk in the greenery.

That is what the "Green Belt" was started for.

Look at our area on Google Earth at the amount of "outside" areas that are there instead of building in everyones back garden.

"Affordable housing"? Even with terraced streets they will be still dear with the cost of ground as it is today. When builders are prepaired to pay about £300,000 for a house just to pull it down and build two on it you can see at least £150,000 plus before you start. I have lived in Hawkwell/Hockley since 1962 but my own son, born here had to go to Southend to live.

We moved from the High Road to here in 2006 because of the traffic on that road was at a standstill at least two times a day. We asked the Rochford Council offices about the areas around our proposed property and was told, don't worry, its all green belt, it will never be built on.

I read that you aim to "Make Rochford District the place of choice in the county to live, work and visit". Well the price of property in Hockley/Hawkwell is higher than most areas about. There is not much work unless your a builder, and without taking residents gront gardens to build new roads people won't be able to get here to visit.

Think again.

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).

1.Affordable housing requirements should be set for developments of less than 15 dwellings and there should be public scrutiny when this is deemed to be unviable economically. If an exception is made on these grounds, the decision should not be made behind closed doors.
2. There is no provision for the government's target figure of 65% socially rented housing.

South West Rayleigh

I have grave reservations of the impact of "Affordable Housing " on the character, amenity, and possibly even safety of the area.
Rayleigh and the wider Rochford district are charecterised by a generally high standard of housing, in keeping with the attractive rural environment. This permeates the whole community and should not be impaired.

The threshold and general approach to the provision of affordable housing is accepted, however, the requirement must be also balanced against economic viability, if a project is going to be unlocked. It is likely that the Council will need to be more realistic in their affordable housing expectations, as developers and landowners prepare for the recovery of the economy.

Stolkin and Clements (Southend) LLP support this policy which seeks at least 35% of affordable housing on all developments of 10 or more units or on sites greater than 0.5ha unless there are site constraints which make the provision impossible.

It is considered that the 'pepper potting' of affordable housing throughout larger developments is not always appropriate in management and maintenance terms, and is not always sought by RSLs. This issue needs to be addressed in pragmatic rather than prescriptive way reflecting the circumstances of individual schemes.

The policy should also stress in a more balanced way that the precise level of affordable housing to be sought on individual sites, against the background of a policy target, will need to reflect the costs and constraints of such provision in order to ensure the viability of the development.

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.

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.

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]

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.

Re The Future Development of Rochford District: the Core Strategy Preferred Options Consultation

Within this letter I set out the representations of Countryside Properties (Special Projects) Ltd to the recently published Core Strategy Preferred Options.

We have also submitted comments directly via the online system and these are repeated here.

As you are aware, we are promoting land to the west of Rayleigh (north of London Road and south of Rawreth Lane). The area of land under option is identified in our "call for sites" submission, made on 14 August 2008. In our comments on the Core Strategy (set out in this letter), in some cases we refer you to our "call for sites" submission.

Before setting out our comments, it should be noted that the full Sustainability Appraisal/Strategic Environmental Assessment to accompany the Core Strategy does not appear to be published, only the Non Technical Summar. Without this, we cannot be sure whether the decisions on growth etc within the Core Strategy bring forward the most sustainable options.

Furthermore, there appears to be no transport related evidence base to inform the Core Strategy. In an area where traffic congestion and accessibility issues, again it is hard to know whether the correct/appropriate decisions have been reached in terms of identifying growth locations/strategies. We think that a transport/highway network assessment is a key piece of work which must be developed to inform the Core Strategy growth decisions.

We of course support the allocation of land west of Rayleigh (north of London Road) for residential development within the Core Strategy Preferred Options. Although it is not clear from the key diagram exactly where this development will take place (see comments attached), and therefore whether it falls totally or partially within land under option, it is clear to us that land west of Rayleigh is the most appropriate and sustainable location for housing growth in Rayleigh. I would refer you again to our "call for sites" submission which identifies the benefits of allocating land west of Rayleigh for development as opposed to other urban edge/green belt sites around Rayleigh which have been considered by the Council (see comparative analysis, appendix 3, and the Scott Wilson report).

It is appreciated that Rawreth Parish Council and some Rawreth Lane residents are not supportive of such an allocation, but this does not detract from the fact that the area is the most accessible and sustainable option for growth in Rayleigh, and in terms of accessibility for vehicles, probably the most accessible within the whole of the district. West of Rayleigh benefits from being in very close proximity to the two principal roads serviing the district (A130 and A127). The existing highway network has adequate capacity to serve a development of the size identified in the Core Strategy (no new roads required to the site).

Without repeating too much of what has already been stated in our previous "call of sites" submission, it is clear that there are few on-site constraints to development:

- The land is used for arable purposes, of Grade 3 classification (all agricultural land around Rayleigh is Grade 3).
- There are no ecologically significant designations or sites of interest and the site is not of any historic or significant landscape value. There are no landscape or ecology policy designations that prohibit development.
- There is a flood zone within the land but any development planning can take into account this constraint.
- There are some pylons running through the land, but we have confirmation that these can be relocated if required.
- Due to the limited nature of constraints on site, the adequate highway capacity on roads linking the site to the strategic highway network, land under option can be brought forward at an early opportunity (there are no significant delivery constraints).
- Whilst in the Green Belt, the land is less sensitive in terms of coalescence, as the gap between Rayleigh and Wickford is the largest gap between settlements around Rayleigh (other gaps between Rayleigh and other settlements are far more sensitive in terms of shorter gaps and landscape or ecology value).
- Any impact upon nearby residents will be carefully considered in any master planning of the development site.

We argue in our comments below that land west of Rayleigh (north of London Road) could accommodate more than the 650 units identified. I also argue that the land north of London Road could accommodate the employment opportunity currently identified for south of London Road, and could therefore form part of a comprehensively planned mixed use development scheme.

Our comments on those relevant policies (preferred options) and alternative options are set out on the attached pages. Please do not hesitate to contact me on the number given above if you have any queries regarding our representations.

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.

Please find enclosed representations made on behalf of Martin Dawn Plc in relation to the Core Strategy.

I look forward to hearing from you in due course, but please do not hesitate to contact me should you have any queries.

Re: Rochford District Council - Core Strategy Preferred Options

Thank you for consulting the Assembly on this matter.

The Regional Planning Panel Standing Committee considered the attached report at its meeting on 5th December 2008 and endorsed the following recommendation:

'Overall, the preferred options put forward in the Core Strategy respond well to the RSS. The Assembly does have some minor concerns but considers that these do not give rise to any major conformity issue'

Our detailed comments, which are set out in Appendix A of the attached report, constitute the Assembly's formal response to this consultation.

If you have any queries concerning the content of the report or any other issue relating to conformity with the Regional Spatial Strategy, please contact myself or James Cutting, Team Leader - Strategy & Implementation

Regional Planning Panel Standing Committee

5th December 2008

Subject: Rochford District Council's Core Strategy Preferred Options consultation document

Report by: Regional Secretariat

Purpose

To give a response to Rochford District Council's Core Strategy Preferred Options consultation document

Recommendation

The Standing Committee is asked to consider the recommendation that the comments in this report and those in Appendix A constitute the Assembly's formal response to Rochford's Core Strategy Preferred Options consultation document.

1. Introduction

1.1 Rochford District Council has published for consultation a revised version of its Core Strategy Preferred Options Development Plan Document. This is the second stage in the Local Development Framework (LDF) process and will, in due course, lead to a Submission Version. As the principle document in Rochford's LDF, the Core Strategy sets out the overall strategy for the district until 2021 and, where appropriate, beyond.

1.2 The Council consulted on an earlier version of its Core Strategy during June and July 2007 (see RPPSC 15 June 2007 - Item3). In submitting its response, the Assembly noted that whilst the document responded well to the then emerging East of England Plan there were issues with regards to affordable housing and major releases of land from the Green Belt.
1.3 The closing date for comments on this revised Core Strategy is 17th December 2008. Further details can be found on Rochford District Council's website.

1.4 A copy of the Core Strategy Key Diagram is included at Appendix B.

2. Background

2.1 Rochford District covers an area of approx. 168 sq. km's (65 sq. miles) and is situated within a peninsula between the Rivers Thames and Crouch. Bounded to the east by the North Sea, it shares land boundaries with Basildon and Castle Point District and Southend-on-Sea Borough Councils. It also has marine boundaries with Maldon and Chelmsford Districts. The A127 and the A13 provide a strategic road link to the M25 Motorway and there are direct rail links into London. London Southend Airport is also located within the district boundary.

2.2 The district has a noticeable east - west divide. The majority of the population, which recent estimates put at 81,300 (expected to rise to 87,000 by 2021), live in the west where the three main urban areas of Rochford, Rayleigh, Hockley are located. To the east, the district is more rural in nature, and is characterised by stretches of unspoilt coastline and countryside, with a scattering of smaller settlements. Approximately 75 per cent of the district is designated as Metropolitan Green Belt.

2.3 A significant proportion of the districts workforce (estimated to be around 68 per cent) work beyond the district boundary. Southend-on-Sea exerts a particularly strong influence, not just as an employment location but also as the largest retail centre in the sub-region. Beyond the three main urban areas of Rochford, Rayleigh and Hockley, which offer greater opportunities to access public transport, there is a high dependency on private car use.

3. Regional and Local Policy

3.1 Regional planning guidance for Rochford is contained within the adopted East of England Plan (hereafter referred to as the RSS) and the remaining six "saved" structure plan policies for Essex and Southend-on-Sea. At a local level, the Core Strategy and other LDF documents will replace the Rochford District Replacement Local Plan (2006).

3.2 In considering general conformity the Core Strategy was assessed against all policies contained within the RSS, with particular attention paid to policies relating to the Essex Thames Gateway (ETG1 - ETG5).

4. Comments

4.1 Overall, the preferred options put forward in the Core Strategy respond well to the RSS. There is recognition that growth needs to be delivered in a sustainable manner and evidence of continued joint working with neighbouring authorities, and the County Council, to ensure delivery of regionally significant schemes such as London Southend Airport and the South Essex Rapid Transit system.

4.2 The Assembly does have some minor concerns over the amount of development that is planned to come forward on previously developed land, and also on the Council's position with regards to larger scale renewable energy schemes. However, it considers that these do not give rise to any major conformity issue.

5. Recommendations

5.1 The Standing Committee is asked to consider the recommendation that this report and the comments in Appendix A constitute the Assembly's formal response to Rochford District Council's Core Strategy Preferred Options consultation document.


Appendix A
LOCAL DEVELOPMENT DOCUMENT CHECKLIST
PART TWO - GENERAL POINTS

Question - Does the area covered lie within the Eastern Region?
Answer - Yes


Question - Are all references to the East of England Plan correct?
Answer: - Yes

Question - Does the area covered include a Key Centre for Development and Change?
Answer - Yes
Comments - London Southend Airport is included within the Essex Thames Gateway policy area.

Question - Are there any key issues covered by the document that are of strategic or regional importance?
Answer - Yes
Comments - Expansion at London Southend Airport and the regeneration of the Thams Gateway are of regional importance.

PART THREE - CONSISTENCY/CONFORMITY CHECKLIST

Question - Is there a clear push for sustainable development?
RSS Policy - SS1
Local Policy - All
Comments - The overall objectives and policies seek to achieve a balance between bringing forward sufficient new growth to meet the needs of the district whilst protecting its natural and historic built environment. There is also clear recognition of the need to ensure that the necessary infrastructure is delivered in a timely and effective manner.

Question - Does policy seek to maximise the use of previously developed land (PDL), and will it contribute towards the 60% target?
RSS Policy - SS2
Local Policy - H1
Comments - (See also comments below relating to Green Belt.)
While local policy H1 supports prioritising the reuse of PDL, the findings of the Council's recent Urban Capacity Study (2007) and concerns over town cramming will mean that only some 30% of new housing development will come forward on PDL.
Although accepting that the 60% target may not be deliverable in all parts of the region, the Council is encouraged to maximise the development potential of all brownfield sites (including "windfall' sites) and, through its monitoring procedures, ensure that delivery does not fall below the proposed 30% level.

Question - Is there a clear pattern of development for 'Key Centres' or for other urban and rural areas?
RSS Policy - SS3, SS4
Local Policy - Various

Question - Is the role of city/town centres clear? Is there a clear retail hierarchy?
RSS Policy - SS6
Local Policy - RTC1 to RTC5
Comments - The influence of out-of-district shopping facilities; particularly those provided at Southend, is acknowledged. Local policy seeks to maintain and enhance the current market share of retail spending, with the focus for development centered on Hockley, Rayleigh and Rochford.

Question - If appropriate, is there a policy dealing with the Green Belt?
RSS Policy - SS7, ETG1
Local Policy - Page 4, GB1, GB2
Comments - RSS policy SS7 states that the broad extent of the Green Belt in the region is appropriate and should be retained. There are no plans for a Green Belt review around Rochford.

Whilst local policy seeks to protect the existing Green Belt, it does allow for some limited reallocation in order that built development can come forward. Where this release is considered to be unavoidable, the Core Strategy proposes that development occurs at a reasonably high density.

In accepting that some Green Belt land will be released, using that which contributes least to its main purpose seems appropriate. Either through this document or through relevant future documents, the Council should clarify what level of development constitutes a 'reasonably high density'.

Question - Is there a policy on coastal issues?
RSS Policy - SS9
Local Policy - ENV2
Comments - The biological/landscape value of the District's coastline is recognised.

Question - Is the East of England Plan employment target met?
RSS Policy - E1, ETG5
Local Policy - Econ' Dev' Chapter, ED1, ED2
Comments - The introductory paragraphs set out districts job requirement figure as quoted in RSS policy ETG5. There is acknowledgment of the important role that London Southend Airport can play in bringing forward employment and other economic development opportunities, as expressed through local policy ED1.

Question - Is employment land protected and is its designated use consistent with relevant RSS policies?
RSS Policy - E2 - E4
Local Policy - ED3, ED4, ED5

Question - Is the RSS housing target met? Is there a housing policy post 2021?
RSS Policy - H1
Local Policy - Housing Chapter H2, H3
Comments - The introductory section sets out district housing figures in line with RSS requirements. Local policies H2 & H3 relate to general distribution, including indicative housing numbers within settlement areas for the period to 2015, from 2015 to 2021, and post 2021.

Question - Is there an affordable housing policy and does it meet the RSS target?
RSS Policy - H2
Local Policy - H4, H5
Comments - The Preferred Option is consistent with the RSS target (35%) and national site size thresholds (15 or more dwellings). It is noted that local evidence shows the actual level of need is much higher, but that the Council is seeking to strikes a balance between deliverability of affordable housing and overall site viability.

Question - Is there a clear policy for meeting the accommodation needs of Gypsies and Travellers?
RSS Policy - H3
Local Policy - H7
Comments - Local policy H7, which states that provision will be made in line with recommendations set out in the RSS Single Issue Review, is welcomed. It is also noted that local authorities in Essex have expressed concerns over the RSS review process.
The Assembly encourages all local authorities to make provision in line with its recommendations to 2011 and beyond, noting that they will need to be mindful of any amendment to district pitch requirement figures as the RSS Single Issue Review is progressed.

Question - Are culture issues addressed?
RSS Policy - C1, C2
Local Policy - CLT6 - 11

Question - Is there a policy seeking to change travel behaviour? Is there a policy seeking to enhance provision for non-motorised forms of transport?
RSS Policy - T2, T9, T13 & T14
Local Policy - T1 - T6
Comments - The Core Strategy recognises that, away from the three main urban areas, there will continue to be a high dependency on private car use. Policies that encourage and bring forward the delivery of alternate and non-motorised forms of transport are supported.
Opportunities to facilitate home-working within new development proposals should not be ignored.

Question - Are any major transport generators covered by appropriate proposals?
RSS Policy - T11, T12
Local Policy - ED1
Comments - [The Council is referred to concerns raised by the Assembly during recent consultation on the JAAP Issues & Options consultation stage - see RPPSC 18 July 2008, Agenda item 4]

Question - Are any transport schemes being promoted that match regional priorities?
RSS Policy - T15
Local Policy - T3
Comments - Local policy T3 supports the implementation of the South Essex Rapid
Transport (SERT) scheme.

Question - Is there a policy dealing with green infrastructure?
RSS Policy - ENV1
Local Policy - ENV1, ENV2, T6

Question - Are landscape, wildlife and other conservation issues addressed?
RSS Policy - ENV2, ENV3
Local Policy - ENV1, ENV2, URV1, URV2

Question - Is agricultural land and soil conservation covered by a policy? Is there a policy relating to rural diversification?
RSS Policy - ENV4
Local Policy - GB2
Comments - The introductory paragraphs in the Environmental Issues chapter (pg 51) states that the Council will endeavour to ensure that the districts agricultural land will not be adversely affected. Local policy GB2 offers support for rural diversification schemes within the designated Green Belt.

Question - Are woodlands protected by a policy?
RSS Policy - ENV5
Local Policy - ENV1, URV1 (ENV6)
Comments - The Preferred Options seek to ensure that areas of ancient woodland are protected.

Question - Is the conservation/enhancement of the historic environment addressed?
RSS Policy - ENV6
Local Policy - CP2, CP3
Comments - The Council intends to reinstate a 'Local List' which will afford protection to local buildings with special architectural / historic value.

Question - Is there a policy that seeks to achieve a high quality built environment, including sustainable construction?
RSS Policy - ENV7
Local Policy - H6, ED5, ENV8, ENV9, CP1
Comments - Local policies ENV8 & ENV9 advocate the implementation of Code for Sustainable Homes (CSH) and BREEAM3 standards. It would be helpful if a timescale was included showing when the Council expects to implement the various code standards.

Question - Is there a policy dealing with the reduction of CO2 emissions? Is there a policy on renewable energy, including the setting of a target?
RSS Policy - ENG1, ENG2
Local Policy - ENV6, ENV7
Comments - The Core Strategy contains two policies on renewable energy - ENV6 and ENV7. While the Assembly is supportive of any policy that actively seeks to implement renewable energy technologies it is concerned that (i) as worded, policy ENV6 seemingly discourages any large scale scheme from coming forward and, (ii) that whilst local policy ENV7 is welcomed, difficulties may arise in measuring the effectiveness of small scale schemes and relating this back to regional and national targets.

Local policy ENV6 should be more 'proactive' by, for example, indicating which type of scheme(s) the Council would be wiling to support. The Assembly will be looking to the relevant Development Control documents to ensure that appropriate targets are set in line with regional targets.

Question - Is there a policy promoting water efficiency?
RSS Policy - WAT1
Local Policy - ENV8, ENV9
Comments - Water efficiency measures are being promoted through policies that adopt BREEAM and Code for Sustainable Homes (CSH) standards

Question - Is Flood Risk Management addressed? Are proposals to implement Sustainable Urban Drainage technologies included?
RSS Policy - WAT4
Local Policy - ENV2, ENV4

Question - Is there a policy dealing with waste management?
RSS Policy - WM1 - WM8
Local Policy - ENV8, ENV9
Comments - It is implied that domestic/commercial waste management practices will addressed through adoption of CSH and BREEAM Standards.

Question - Is there a policy that deals with implementation and monitoring?
RSS Policy - IMP1 - IMP2
Local Policy - Page 107 and Table

PART FOUR - OVERALL ASSESSMENT

Question - Is the document in general conformity with the RSS? If the answer is 'no', what is needed to rectify this?
Answer - Yes
Comments - Overall, the preferred options put forward in the Core Strategy respond well to the RSS. There is recognition that growth needs to be delivered in a sustainable manner and evidence of continued joint working with neighbouring authorities, and the County Council, to ensure delivery of regionally significant schemes such as London Southend Airport and the South Essex Rapid Transit system.

The Assembly does have some minor concerns over the amount of development that is planned to come forward on previously developed land, and also on the Council's position with regards to larger scale renewable energy schemes. However, it considers that these do not give rise to any major conformity issue.