H Appendix 1

The proposals recognise the need for infrastructure improvements but these have not been considered , costed, or funded.
Many roads are at or near capacity but no plans on how to address the extra traffic.

The Government's regional funding allocation has been cut to £80 million, which will have to be split across East Anglia. This is insufficient.

Once the CS locations have been accepted it will be difficult/impossible to change them. Infrastructure costs must be identified before agreeing sites.

Infrastructure proposals will be paid for by use of "standard charges" No details given of how this will work or likely levels. Costs may render small locations un-viable.

Page 97 identifies the need for additional youth facilities. 12 housing sites scattered across the District does not provide sufficient scale to pay for extra youth facilities.

Page 93 proposes a primary care centre for Rayleigh. Rayleigh has the best GP/patient ration in SE Essex; the largest GP practice has just significantly expanded; and the area has relatively lower numbers of additional housing.
No improvements are recommended for the Rochford area which has the worst GP/patient ratio in SE Essex and the most houses proposed.

Infrastructure proposals will be paid for by use of "standard charges". No details given of how this will work or likely levels. Costs may render small locations un-viable.
No consideration given to how standard charges will work in facilities required to support more than one site e.g. a health centre covering several locations or road improvements indirectly required because of development elsewhere

I cannot stress enough the need for adequate drinage systems for any developments returning surface water to the river Crouch. Developments in the Wickford and Rayleigh area have made a number of houses in the Rawreth Parish more vunerable to flooding. The SUDS policy does not work and serious attention should be given to improvments to drainage systems out to the Crouch.

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.

The outlines for infrastructure make no reference to roads, Rawreth Lane, the A1245 and London Road are already over used, they struggle during rush hour as it is, with increased car movement from development in this part of Rayleigh these roads will not cope.

Without precise locations it is difficult/impossible to assess the impact and more information is needed.

The location descriptions used in the CS are misleading eg Rayleigh really means Raweth; Ashindon really means Rochford.

What can we trust?

the proposals have not been costed and are likely to be unachievable. Further information is needed.

A primary Care centre is proposed for Rawreth. The Rayleigh area has the best GP ratio in SE Essex (PCT Data).

Rochford/Hockley has the worst GP ratio and the highest number of houses allocated but no health improvements!

if there are more houses to be built in the hockley area, why are there no proposed schools, healthcare, infrastructure/transport link proposals?

The report continually talks about sustainability and we are concerned that no definition of sustainability has been made and we would seek clarification on this point. The additional homes will put an enormous strain on the infrastructure of our area, particularly the road system, which has not been addressed in the document.

Whilst accepting the need for some improvement in housing stock for Hockley (i.e. 50 houses), no provision has been made for the knock-on impact on Hockley of additional housing in the adjacent areas.

Both of the preferred Rayleigh sites are required to be accompanied by a number of major infrastructure requirements to support the level of housing proposed. There is capacity at existing primary schools and doctors surgeries in other areas of Rayleigh i.e. to the south east, and development in this alternative location would make best use of existing resources and should be utilised allied with housing growth in this area before the provision of new facilities is made. This approach is endorsed in PPS3.

Land North of London Road, Rayleigh:

The proposed public open space parkland buffer must act as a 'stop' to prevent further development into the green belt beyond the new housing. For this reason, consideration should be given to making the buffer land over in ownership to an organisation (eg National Playing Fields Assocation or the Woodland Trust) which would protect it from being released for development at a later date. There must be a footpath link between the proposed new public open space and the existing Wheatley Wood open space owned by The Woodland Trust on the other side of the London Road. To have no link through between the two pieces of land woudl be an unacceptable lost opportunity. There would be merit in continuing the woodland theme through into the new open space parkland to create a really extensive area of woodland in this part of Rayleigh/Rawreth.

The spine road of the new housing development should incorporate a cycle path. It should be possible to create a cycle path along part of the London Road as an element of the new development, maybe all the way up to the Carpenter's Arms roundabout.

I am disabled so I can only comment on areas round Rayleigh that I have been around before I became disabled.

1. South West Rayleigh has boundaries, to the north by railway and on the south by the A127. I presume that development will be add on to Great Wheatley and Highmead. The Primary School situated off the High Street is an old building and fair distance from any new development. It can be anticipated that young families will occupy the new dwellings. If the school is too far away parents will transport their children by car causing more traffic congestion outside the school. Even if public transport is enhanced parents for convenience would use their cars to take children to school.

2. Development at north Rayleigh and south west Rayleigh will add to school population despite falling birth-rate. I think there is a need for primary school in south west Rayleigh and an additional secondary school somewhere along Rawreth Lane.

In the table in H Appendix 1, the first bullet in the list of infrastructure required for the two locations 'North of London Road Rayleigh' and 'West Rochford' should be expanded to read 'Primary School with Early Years & Childcare provision'. In addition to the specific new educational infrastructure listed in the table for these two locations and for East Ashingdon and South East Ashingdon, development at other proposed locations will require an increase in capacity at other existing school sites and for expansion of early years and childcare facilities.

North of London Road, Rayleigh - no explanation as to the significance of a Public Park Land buffer?

Are public open spaces different/separate to Play Spaces as most locations appear to include both?

LDF Core Strategy Preferred Options

Response On Behalf Of Rayleigh Town Council

(1) Page 3.
There is a statement that the purpose of the Core Strategy is not to identify specific locations, but in stating preference for a particular area ("North of London Road" AKA Between London Road and Rawreth Lane), this document has contradicted the statement, automatically by its' wording ruling out other suitable sites identified in the "call for sites" exercise.
This statement needs to be reworded to allow other areas to be considered

In addition despite links with the A127 and A130 (or possibly because of ) this area suffers considerable road congestion for large parts of the day with London Road and Rawreth Lane at times being at a complete standstill, a situation which can only be exacerbated with the additional traffic generated by this proposal.

The Town Council question as to whether the fact that 3 schools already exit on to this road, with attended traffic problems of pick-ups and drop offs has been thought of. If more homes are built there, the army of buses taking pupils to secondary schools would increase. There is already an army of buses taking the students to Sweyne Park School, LONDON ROAD, causing an almost impossible situation for the residents of the adjacent roads, they cannot park, and the buses struggle to get in and out. Traffic hold ups are legion.

Also the A127 is already exceeding its' designed capacity with little prospect of future improvement and the A130 is very near to the limit. E-ON Call Centre exiting to LONDON ROAD means further traffic congestion at shift change times to and from Rayleigh.

Poor Transport along LONDON ROAD, for older residents visiting Southend and Basildon Hospitals. Shopping problems for all without cars, no direct bus service to
ASDA, Rawreth Lane.

These links cannot be relied upon ad infinitum.
In introducing the document to the West Area Committee recently, Cllr Hudson stated "we will only release Green Belt land after every scrap of brown field land has been used up".

This appears to be a contradiction of H2 General Locations and Phasing in that there is no reference to any brown field sites in Rayleigh and, as stated above, automatically rules out suitable alternatives.

The argument in H2 on P29 against North Rayleigh applies equally to the preferred option "North of London Road".

(2) Page 8 Priority 5
This statement is unrealistic in that it ignores the fact that public transport is poor with little prospect of improvement and walking or cycling are not viable alternatives for the not so young or fit.

(3) Page 37 H7 Gypsy and traveller accommodation
Where particular traveller sites have been identified as being undesirable, the temptation to ignore the results of legal process, to designate such sites as appropriate and not continue enforcement action simply for administrative convenience must be resisted.

This statement must be made more prescriptive.

(4) Page 49 Land south of London Road
Once again reliance on A127 and A130 links cannot be guaranteed ad infinitum.

This general area was apparently ruled out for housing development after objections from the Highway Authority and would therefore appear to be unsuitable for commercial or industrial use.

(5) Page 38 Infrastructure required and Page 93 CLT4 Healthcare

Rather than the fashionable (with the PCT) primary care centre (Polyclinic?) located in the preferred area, a better alternative is considered to be the provision of an outreach outpatient centre associated with Southend Hospital to perform routine blood tests, x-rays and a minor injuries clinic etc. reducing the need to travel and relieving the pressure on hospital services while leaving GP provision where it is at present.

(6) Page 41 Protection of the green belt
Strongly agree the five bullet points at the head of the page

(6) Page 50 ED5 Eco enterprise centre
There is little indication as to where such a centre would be located and the statement is far too vague.

(7) Page 57 ENV4 Sustainable drainage systems

SUDS relies on the Environment Agency to maintain watercourses and ditches in a suitable manner (Which at present is sadly lacking) without this there will undoubtedly be future problems

This section needs to be far more robust

(8) Page 66 T1 Highways
Strongly support this. What safeguards can be built in to ensure that S106 agreement finance is actually used for the infrastructure improvements for which it is intended in the light of recent revelations of the loss of such monies?

(9) Page 67 T2 Public transport
Encouraging alternatives to the use of the private car must not be used as an excuse to lower standards of parking and vehicle storage
This section needs to be more prescriptive.

(10) Page 88 CLT1
In his introduction Cllr Hudson stated that approximately £1 Billion is needed to make up the shortfall in infrastructure provision. It is unrealistic to expect this to be made up by "standard charges" (around £300,000 per dwelling across the district?)

It is therefore essential to state that these plans are unsustainable without considerable government funding.

(11) Page 71 T7 Parking standards
Strongly support the application of minimum parking standards

At last the voice of reason and common sense!!

(12) Page 94 CLT5 Open spaces
This needs to be more specific and robust, in particular in forming a barrier between any new
development and the A1245, preventing further westward sprawl in future years

(13) Page 95 CLT6 Community facilities
Strongly support this statement

(14) Page 98 CLT9 Leisure facilities
It is considered that an opportunity exists to obtain developer contributions to expand
leisure facilities in the provision of a swimming pool at Rayleigh leisure Centre
Suggest that this is included in CLT9

(15) Page 103 CLT appendix 1 New healthcare centre Rayleigh
New proposed residential areas are too far away from eastern areas of Rayleigh .The location
should be as near to the town centre as possible (see also (5))

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.

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.

I have been instructed to forward representations of behalf of my clients Robinson and H R Philpot & Sons (Barleylands) Ltd.

Attached are responses to the Rochford LDF Core Strategy Preferred Options October 2008 concerning:

H2 General Locations and Phasing - Preferred Options
H3 General Locations Post 2021 - Preferred Options
H Appendix 1
ENV2 Coastal Protection Belt - Preferred Options
ED2 Employment Growth - Preferred Options
CLT5 Open Space - Preferred Options
Hullbridge Expansion drawing B.9006/a

I look forward to confirmation of receipt for these representations from the Council which have not been submitted online.

Dear Sir / Madam

Rochford Core Strategy Preferred Options Document

On behalf of the Aston Unit Trust and Mr John Needs, I enclose formal representations in respect of the Rochford Core Strategy Preferred Options.

Whilst the individual representation forms set out my clients comments on each policy, it may be of assistance briefly to summarise their overall perspective on the Preferred Options. The main criticism is the decision to shift a much higher proportion of the greenfield housing allocations to the second and third tier settlements compared to the 2007 Preferred Options.

The 2007 Preferred Options was the subject of a Sustainability Analysis which concluded that the option of providing only 10% of the total housing provision (460 units) in these minor settlements was the most sustainable option. The 2008 Preferred Options now proposes to allocate 860 units on greenfield sites in second and third tier settlements. When completions and commitments are added to this figure, the total level of housing growth in these lower tier settlements will be considerable. There is nothing in the evidence base to justify such a change and since it results in a less sustainable spatial strategy it is unsound.

The solution is to reduce the level of greenfield allocations in the second and third tier settlements and increase the proportion in the three towns. It is not the role of these representations to suggest a detailed Policy H2 redistribution, however land at Wellington Road, Rayleigh is capable of delivering around 200 dwellings at a sustainable location in the 'principal town' in the district. This site is within walking distance of a wide range of services, facilities, employment and public transport in Rayleigh. As a consequence, future residents of this site have a real choice not to use their cars for most day to day trips. This choice does not exist in the lower tier settlements of Hullbridge, Great Wakering and Canewdon.

My clients support the tariff or 'CIL' approach set out in Policy CLT1 and the representation on Appendix 1 sets out the social and physical infrastructure which would be expected to accompany the residential development of the Wellington Road site.

Should you wish to discuss the delivery of the Wellington Road site in more detail, please do not hesitate to contact me.

Yours sincerely,
R Sellwood
Sellwood Planning Ltd
cc. Aston Unit Trust
J Needs