Protection of the Green Belt

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

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

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

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

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

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

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

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

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

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

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

Best regards

Stop further development in the whole area and concentrate on health & well being of existing residents! We are entitled to an improving quality of life - not the slow chipping away cased by creeping over population in this area! No more building - protect all the existing green belt.

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).

why is Green Belt under consideration for building? Our town Rayleigh is turning into a concret jungle. I feel that doing this would turn people off moving here anyway so no need for 100 houses in the south west

Thank you for consulting the Government Office on the Rochford District Council Local Development Framework Core Strategy Preferred Options Report.

As you are aware, we have commented in the past on earlier documents published in relation to the Rochford Core Strategy. In line with our earlier comments we consider that the document is well organised, comprehensive, set out in a systematic fashion and is easy to read and comprehend. The authority is to be commended for achieving this. We do though have some general comments and concerns as well as detailed observations that relate to many of the intended policies. These are set out in the paragraphs below.

Going forward under a revised PPS12

You will also be aware that on the 4th June this year CLG published a revised PPS12 along with revised regulations, which are now in place. The revisions are aimed mainly at streamlining the process further to help ensure that production of DPD's is able to happen as quickly as possible, whilst ensuring that public participation is effective and its results taken fully into account. As well as this, a key motivation of the revisions is to provide local planning authorities with greater freedom to determine the most appropriate way to prepare or revise DPD's. There is now more flexibility particularly in terms of consultation, where consultation on the DPD during the preparation phase of the plan is expected to be proportionate to the scale of the issues involved in the plan. On this basis, the regulations have now removed one of the formal stages of consultation - the preferred option stage. As well as this, the regulations now require that consultation and representations are made on a DPD before submission to the Secretary of State.

You should refer to the new PPS in taking forward this DPD, but essentially you will need to comply with the following principles in the PPS on:

• Participation and stakeholders (see section 4.20, 4.25 & 4.27);
• Not repeating national and regional policy (4.30);
• Being subject to a sustainability appraisal (4.39 - 4.42);
• Being justified, effective and consistent with national policy (4.36 & 4.44) and
• Being produced according to the timetable set out in the LDS to ensure that the DPD is produced in a timely and efficient manner (see section 4.53 & 4.54)

Further guidance, including examples of best practice, is provided in the Plan Making Manual, which may be accessed via the Planning Advisory Service's website: www.pas.gov.uk/planmakingmanual. Additional content will become available in further updates of the Manual.

The DPD must be prepared in accordance with the Local Development Scheme and in compliance with the Statement of Community Involvement and the Town and Country Planning (Local Development) (England) Regulations 2004 as amended, be subject to a sustainability appraisal, have regard to national policy and any sustainable community strategy for the area and conform to the RSS. To be sound, the DPD should be justified (founded on a robust and credible evidence base, and be the most appropriate strategy when considered against the reasonable alternatives), effective (the document must be deliverable, flexible and be able to be monitored) and consistent with national policy.

The key consideration before drafting the final DPD, is to be satisfied that the process of testing and refining of the options and consulting with key stakeholders has been undertaken adequately and satisfactorily in an appropriate and proportionate manner in relation to the issues arising in respect of this particular DPD.

Presentation of Options

There will be an expectation when the Core Strategy is submitted for examination, that the Council is able to demonstrate that it's decisions for deciding on certain options and ruling out others has been underpinned and informed by a robust Sustainability Appraisal (SA). I am surprised that there are not many references to the SA in the main text of the Core Strategy preferred options document, especially in the context of the presentation of options. It is not explicitly evident from reading the Core Strategy document, that the findings in the SA report support the Authority's preferred options and how decisions about the spatial strategy have been reached.

At submission, the Authority will need to be able to demonstrate that the DPD's policies represent the most appropriate response in all the circumstances, having considered all the relevant alternatives, and that they are founded on a robust and credible evidence base; and that all reasonable and deliverable options have been equally presented at the Issues and Options stage, all underpinned by relevant sustainability information and other evidence. In order to meet this requirement, we firmly recommend that the subsequent documents make explicit linkages between the SA process and the decisions on chosen options and disregarded options.

Habitats Directive

As a result of the recent European Court of Justice ruling in relation to the Habitats Directive, Local Planning Authorities are now required to assess whether an Appropriate Assessment (AA), the purpose of which is to assess the impacts of a land-use plan against the conservation objectives of a European Site and to ascertain whether it would adversely affect the integrity of that site, is necessary and to carry out the AA in the preparation of a DPD or SPD where it is required.

Replacement of Local Plan Policies

It is a regulatory requirement for the Council to identify which extant saved local plan policies will be replaced/superseded by the Core Strategy upon its adoption. We would suggest that any early consultation documents should give a broad indication of the extant policy areas likely to be replaced and the submission Core Strategy document to include this information in detail, perhaps as an appendix.

Consultation Statement

We remind you that when you submit the relevant DPD, you will be required to provide a statement setting out which bodies were consulted at earlier regulated stages, how they were consulted, and a summary of the main issues raised and how these have been addressed. It is important therefore that you document clearly the consultation that you are undertaking now, and in the future, to inform this requirement.

Specific Comments on the Rochford District Council Local Development Framework Core Strategy Preferred Options Document

• It might be helpful in the introductory paragraphs of your eventual Submission document to explain in slightly more detail, what has preceded the stage you have now reached (i.e. the earlier stages) in terms of the evolution of your Core Strategy, particularly in relation to the chronology and 'frontloading' (statutory consultees/stakeholders) including public engagement.
• You might like to consider whether in your Submission document you should distinguish what is in effect your 'Spatial Portrait' (i.e. term it as such) from the other information that forms the 'Characteristics, Issues and Opportunities' in the introductory section.
• On page 14 under population, I think you are suggesting that the average household size in Rochford is a function of the relatively large number of families which is a feature of the District's population structure. The way you have expressed it appears to be somewhat ambiguous to me and this section of text may therefore benefit from being expressed in a way that is simpler and provides for clarity.
• Under the section entitled 'Vision', the text referring to the latter seems to be based more upon the separate document 'Vision to Reality' that is referred to. In addition, the initial Vision Statement that is then set out as text amounts to little more than a 'Statement of Intent'. The way I feel the Vision should be expressed is in fact much like the way you have expressed it in text boxes at the start of each theme- based section that follows in the document. This is an unconventional way of handling the matter and consequently you will need to be satisfied that it is an appropriate method. Clearly though, I feel that the linkage between the section entitled 'Vision' and what is written subsequently in the initial text and later in the text boxes, is inconsistent and at present confusing (the Vision and the Objectives that follow from it, should set the scene for the Core Strategy policies and proposals, particularly in terms of time scales (which you do outline) local distinctiveness, the scale of development intended and its broad locations).
• The objectives as currently expressed are very general and not distinctive or 'spatially specific' to Rochford.
• Policy H1 - The spatial dimension to this policy is in fact provided by Policy H2 and therefore there should be a cross reference in the text of Policy H1 to provide this linkage.
• Some of the text boxes are clearly making reference in 'plain English/general terms' to the 'Evidence Base' (i.e. when not setting out the Vision) without providing a reference to the appropriate 'Evidence Base' document. Given that the 'Evidence Base' is listed in detail in the first section of the Core Strategy document, it might be helpful to devise a system of Codes, or similar, to provide for cross references from the text box statements to the appropriate 'Evidence Base' document in the earlier list (the same system could be used in respect of 'non-specific references' to the 'Evidence Base' in the main text).
• You should avoid repeating national policy within the Core Strategy. In some instances in the supporting text you actually reproduce sections of PPSs. It may be appropriate in such instances to refer to such policy in general terms (a text box is a good way of doing this) but reproduction of actual PPS text should be avoided. Where references are made in some cases within policy wording to national policy (PPSs etc.) then the policy must be re-written in the Submission document to remove such references. The Core Strategy can only interpret national policy, indicating how it is to be applied to the local area - it must not repeat it.
• Whilst the use of text boxes is to be commended in general, that on P42 contains text which is repeated in some of the main text virtually alongside it. This occurs elsewhere in the document and it should be avoided in the Submission document.
• Several policies (e.g. GB1, ED2) are expressed in terms of: 'we will seek to direct'; 'we will encourage'; 'we will ensure'; we will enhance' etc. Expressed in this way the policies amount to little more than 'statements of intent'. Such expressions beg the questions 'how?', 'when?', 'where?'; and 'what?' etc. The policies in the Core Strategy need to relate to firm actions (albeit 'criteria based' if appropriate) and if there are not clear intentions in relation to delivery, then it is not appropriate to include the policy at all. I accept that as currently written, the policies may be indicating what the 'preferred option' for the policy is, rather than expressing it currently in its final form.
• In policy ED3 other than mention being made of 'Baltic Wharf', the existing employment sites to be reviewed are not identified. In order for the policy to be 'spatially specific' the other sites should be identified.
• Other than mention being made in the supporting text that there is an identified requirement for 2 hectares of office space, there are not any allocations made in terms of quantum of floorspace, or land areas, to meet the jobs requirement for the District. Furthermore, a policy has not been developed in terms of the distinction between locational implications of different uses (i.e. B1, B2 and B8). The submission policy should provide a clearer articulation of the locational implications relative to employment use types B1, B2 and B8 including any relevant split of land requirements relative to the different uses.
• In policy ENV4 'large scale' development is not defined.
• You will need to ensure that the wording in respect of Policy ENV6 wholly accords with the PPS1 Supplement on Climate Change. At present the wording appears to suggest a greater level of restraint than that intended by national policy.
• When/what date will Code Level 3 in Policy ENV8 be introduced? What is your 'Evidence Base' (as required by virtue of the PPS1 Supplement) to justify (in terms of viability) introducing this requirement in Rochford?
• In respect of Policy ENV9, what is your 'Evidence Base' (as required by virtue of the PPS1 Supplement) to justify (in terms of viability) introducing this requirement in Rochford?
• Where is the contaminated land referred to in ENV10 to be found in the District? What are the broad locations?
• In policy RTC1 what is the amount of retail floorspace that is being directed to the stated locations?

• In policy CLT5 what are the standards that will be applied?

• In policy CLT7 what are the standards that will be applied?

• In policy CLT8 what are the standards that will be applied?

• The Key Diagram should preferably be located much earlier on in the document - it could even be located after the background section and preceding the theme based sections. It appears that some potential designations are missing e.g. AQMA's.

• It is important for a Core Strategy to set out a strategic housing trajectory, expressing the Council's broad expectations for the delivery of housing over the Core Strategy period. It is accepted that it will need to be done at a strategic level, since individual development sites have yet to be identified, but it could set out the general expectations for the broad quantum (in general terms) and sources of completions (existing commitment, unallocated urban capacity/windfall sites, brownfield allocations, Greenfield sites/urban extensions etc) over the plan's lifetime. The trajectory should preferably be in the form of a bar chart, or similar, setting out expected development rates and indications of which main locations in each year that development is likely to be forthcoming.

Conclusions

We commend you for the work carried out so far. Where any soundness issues arise, either through our consideration of the work done to date to comply with Regulation 25, or later, through our consideration of the further documents that you will publish to comply with Regulations 25 and 27, we hope that they can be resolved prior to the DPD's submission and subsequent examination.

In genera;, we (and probability virually everyone else) support retention of the greenbelt. However, the plans for distributing houses across the district, as a result of this policy) have to be viable in their own right. The absence of infrastructure makes the CS unsustainable.

Renaissance Southend (RSL) acknowledges the importance of the constraints imposed by the Green Belt and supports the general thrust of the Green Belt Policy. However, RSL would urge that the Core Strategy (CS) is more explicit in providing for the potential amendment to Green Belt boundaries through the Joint Area Action Plan for the Airport & Environs (JAAP), in order to meet recognised regional and sub regional objectives for economic development and employment growth.

C and S Associates support changes to the green belt boundary to enable the required employment and residential development and, more specifically, to enable the development of the Brickworks site as identified in the JAAP. The draft JAAP recognises that without this amendment to the green belt this may hinder development and we agree with this; the green belt boundary can be amended to enable the beneficial development of the Brickworks to take place without compromising any adjoining green belt. The site can provided with defensible boundaries which will afford future protection of the surrounding green belt, should it remain, and so development will not threaten the function and purpose of the green belt.

The text explaining the philosophy regarding protection of the Green Belt recognises that a small proportion of the District's land that is currently allocated as Green Belt will have to have its designation reviewed due to the need to develop additional housing and employment uses. This is compounded by the limited opportunities to accommodate development outside of the Green Belt. Stolkin and Clements support this approach.

Green Belt boundaries will need to be amended to enable the required development to take place. If the Tithe Park site is taken out of the Green Belt, careful modelling of the proposal can provide well managed and defensible boundaries which will afford protection in the future to the areas to the north and west, thereby preventing any potential coalescence.

The statement that "some Green Belt land is more worthy of protection than others" is welcomed. Unfortunately it has not been applied to Policy H2 which identifies land at South Hawkwell (presumably Land off Thorpe Road) as being suitable for development although the Local Plan Inspector said the Green Belt had an important function in this location.

I agree with all the principles of the Green Belt but must emphasise that H2 development "North of London Road" is the complete opposite of these aims. The land should be covered by ALL 5 points of the purpose of Green Belt.
It should also not be developed in accordance with ALL the points under PPPG2.

Para 6 'Previous community...' describes minimal development. Does this mean development other than residential as preferred option GB2 is for no residential development in green belt? Or is there a difference between urban and rural green belt?! This section is unclear in these matters?

If we want to potect urban areas and maintain sustainibility criteria, yet allow for futher development, green belt use is the only option. But this MUST be strictly controlled and based on specific green belt assessment criteria.

The section also does not clearly explain green belt definitions and how it can be redesignated?

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))

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

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

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

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

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

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


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

Response to Core Strategy - Local Government Framework Oct 2008-12-24

Thank you for opportunity to comment on the above and I make the following objections.

HOUSING

I object to proposals in Preferred Options under this heading in following 10 paras.

Numbers. I object to ordained housing numbers. Up to 2025, East of England Plan requires 5,600 minimum, of which, after actual and projected completions, gives remainder of 4,700, based on current need - adult children wanting to leave home, break-up of relationships, population projected increase from 78,489 to 87,000 by 2020s. This is largely supposition. Even the original remainder of 3,500 to 2021 after projected completions is too many. Notional redistribution of numbers around District centres following last Core Strategy consultation is fruitless when one studies the map showing areas excluded from development due to: flood plain, SSIs, conservation etc which comprise the bulk of the District. The built area plus projected green belt release won't sustain it. Don't forget, based on history, post 2025 Government will require ever more notional numbers accommodated.

Population. Planning Services express fear of continued out-migration due to housing shortage. In fact much known such migration is caused precisely by over-development, families looking to move to roomier, less claustrophobic environments. It will be necessary to discourage inward migration by persuading other Local Authorities to make improvements to education etc.

Much is made of the old causing a housing problem. This is skewed logic. The under 20 age group will not fall. The Office of National Statistics has reported a further baby boom commenced 2001 - an increase. The over 65 population will increase solely because the ageing earlier baby boom generation mostly under that age now will join them, but that doesn't increase population. The 24 to 64 age group will lose at the top and gain at the bottom.

In this connection complaint is made of the old hanging onto houses instead of down-sizing to so-called sheltered housing and allied ghettoes. If over-65s are found a problem, Third Reich had a solution that should appeal to EEDA: they could set up termination camps, with double benefit: get rid of them and clear their homes for redevelopment.

It should be pointed out much over-large new build market housing is for upwardly mobile, but middle and old aged persons from elsewhere, whose children have left home. An estate of 5 such units houses 10 persons. Some mansions are built or bought purposely for one person.

Distribution/General locations. I appreciate new concern with 'town cramming' and note view that Government target of 60% on 'brownfield' land is unrealistic (that damage already done) and that you propose much less. If this can be done with one Government target, why not cut down others?

I regret, however, that the newly restrictive approach against town cramming does not apply to 'windfall' development - very much of that has been done - over-dense, out of scale with existing dwellings, particularly in Hockley.

In this respect I'm sceptical of your new good intentions, as revised Urban Capacity Study 2007 notes 'intensification of existing residential land has made significantly larger contribution to housing figures than other forms of development..'.

Presumably the proposals listed under H2 and H3 are based on the 'call for sites' letter 2007 and have been offered by developers. The total for south Hawkwell of 350 to 2025 is over the top in relation to impact and land availability. It is bounded by over-busy B1013, former country lane. New roads required for it will mean compulsory purchase and some green belt residents will have to go.

Hockley seems unusually favoured with 50 units, but only as officials know well that windfall development will continue without restriction, as in the past, so no need to overdo target.

Core Strategy Preferred Options is a blank cheque, exact locations to be given in later allocations document.

AFFORDABLE HOUSING

I object to outlined proposals as follows. The noted dire shortage, with waiting list of young looking to leave home, etc, has resulted from shed loads of council housing having been sold off under the Thatcher Government in 1980s, or you would not need this genre. Council housing was meant for two sections: first those who would never be able to afford a mortgage and should not be pressured to do so; secondly, first-timers who could not initially afford ownership, but with aid of cheap rent could save over time for a deposit on their own place.

CHARACTER OF PLACE AND DWELLING TYPES

I object to proposals for reasons in following 7 paras.

Traditional. It is noted that the District 'has character, appearance, much of which stems from traditional buildings that still dominate towns and villages'. Unfortunately, as I noted under housing, much of that has been eliminated, many remaining dwellings now threatened with same, as Locally Listed buildings and their environs have gone, especially in Hockley, though Rochford, Rayleigh, small settlements have been reasonably well spared in this respect.

Intensification. Rochford District recognises defects of intensification of residential areas and proposes limiting redevelopment not in keeping with density and character of the area. But failure to clarify that those terms both mean not only destruction of heritage, but replacement with edifices out of scale in bulk, area, height, will lead to jeopardy of existing homes. Some new build may be out of character, but might be acceptable if not out of scale. Planning Services have been known to decide planned over-large buildings comply with density - they might do numerically, but are over-dense proportionally.

Strategic Housing Market Assessment is happy for market housing to be out of scale with existing: '...recommends Local Authorities don't set rigid requirements for size of dwellings, particularly...market housing, market is adept at matching dwelling size to market demand at local level'. Precisely. The upwardly mobile private sector have no regard for others and want multi-bedroomed dwellings massively out of scale with neighbours (who are often unfortunate to be north of them) plus all sorts of intrusive security systems to match. This should be resisted.

Planning Policy Statement 3 states: 'Design which is inappropriate in its context and which fails to take opportunity for character and quality of area should not be accepted. Development which is not inclusive and does not fit with surroundings..'. This is just what the typical 'executive' house, in gated site, 'town' house (also 3 storey where locale is 2 storey), flats etc, encouraged for Hockley has done. So clearly Government dictate has not been followed in this regard.

Character of place. Much has been made of the idea that, unlike Rochford, Rayleigh, the small settlements, Hockley village is not where once sited - around Hockley Church a 12C Listed building, but is a construct arising with the railway in 1887, all growth haphazard and dated subsequently, having no heritage value. This is inaccurate.

The road from Rayleigh to Rochford, via Hockley was a country lane. What is now B1013 was made a toll road in 18C for coaches, which is why it by-passed the church. To my certain recollection a dozen period houses, as good or better than Rochford's, from Marigold Corner (Hawkwell end of Hockley hill) to the Spa Hotel, dating 17C to 19C, have been destroyed since c.1975 for redevelopment.

4 Tiers. Core Strategy proposes dividing District settlements into 4 tiers of graded sustainability for more housing, those in the 4th tier being thought unsuitable. No wonder such places as Paglesham, Foulness, Stambridge have closed schools, churches, for lack of people.

MATERIALS

My objections here should be included in those under Character of Place. Core Strategy notes 'modern standardised building materials and design have begun to erode character of the District'. That is very true: there is a new element of hard sell by contractors, who want to replace traditional work, materials, with eg. Plastics, spray paint, steel. Personally, to avoid this I have had to engage a contractor specializing in heritage work to do standard painting, repair of external cast iron, timber work. Formerly, any general building would have done the work required as asked without argument.

It is a joke that design is expected to be sympathetic to locale and in-house building styles to fit local setting, not other way round. It is too late. Developers have strived to spoil local setting precisely to jeopardise existing housing, so it can be acquired for redevelopment.

LOCAL LIST

I list my objections to proposals for preferred options under this heading in following 6 paras.

I note Rochford District Council dropped Local List just prior to enabling demolition of Black's Farm (1 Southend Road), which was on that list, a house and garden that certainly conformed to 'local distinctiveness and [central to] a cherished and local scene' in Hockley.

The List was ostensibly dropped as, so a former Planning policy Manager said, 'Government frowns on such Lists'. Other councils, unaware of that, retained theirs. His comment to an Inspector on objection to proposed flats redevelopment of 1 Southend Road 'Just politics, lot of local interest, nothing of character in that area', presumably presaging his plans for the area. He also remarked on intended replacement 'flats sell well' - not a planning consideration. Surprise, surprise! As soon as the item was successfully demolished, we learned more recent Government guidance encouraged Local Lists! 'There is now positive encouragement from Government in recent White Paper for such Lists and we propose to reintroduce one for the District'. How disingenuous can you get.?. Were they holding it back, then?

It seems to me where Hockley is concerned notional land values for developers are more important than anything standing on it. In fact a former councillor once said exactly that.

An adviser proposed an Article 4 Direction be served for 1 Southend Road (an embargo on demolition while listing is considered. If it fails, compensation may be payable to the developer by council). The council refused because of that risk. English Heritage, well documented, as also Dept. of Culture, didn't visit, but left the matter to Essex County Council heritage department, who were inevitably not interested from scratch. After all was too late, English Heritage even advised another time one should get a period building under threat put on the Local List! Meanwhile in the time when 3 Hockley period houses were demolished for redevelopment, including No1, there was sickening sight of several Rochford buildings under repair 'sponsored by English Heritage' and other funded organisations. In Rayleigh large sums of public money, including from Thames Gateway, Lottery, were spent on schemes such as the Mill. And to think the council begrudged an unlikely financial risk in respect of Article 4 on 1 Southend Road Hockley.

I insist that a draft Local List be issued for consultation for ALL residents, which right to propose or refuse what goes on it. If, as suggested in earlier Strategy document, new development is to be included, then all adjacent properties are to be included as a conservation area.

Heritage, etc, Award by RDC. In view of all the above, there is hypocrisy in this scheme for heritage style redevelopment. Period houses now demolished, are replaced with out of scale pseudo-period redevelopment, particularly, as a planner said, on 'important, significant hill top, hillside sites' (money) such as Etheldore Avenue and Southend Road. These are of doubtful marketability, but this award is a pretence of concern with heritage to hide the real facts.

INFRASTRUCTURE AND TRANSPORT

I list objections to proposals under this heading in following 5 paras.

Standard Charges. Though I welcome proposals at CLT 1 for developers to pay towards the problems caused by their plans, it is a pity these are not to be set at a realistically punitive level to discourage them from excessive schemes. It has been suggested if a developer won't provide required infrastructure, opportunity will be given to another who will. But what if first developer already owns the site council is keen to see developed? Also, there is still a risk that retention of S.106 Planning Agreements will cause developers to buy Consents they might not otherwise get.

South Hawkwell building proposal. Re H2 alternative options, namely N E Hockley thought unviable for development due to impact on highway network of traffic heading through/out of Hockley to Ashingdon, but development south of Hawkwell found better placed in relation to highway network and employment growth at Southend Airport - this is grossly illogical.

I certainly don't support further development for N E Hockley. It is already burdened by Etheldore/Wood Avenue, Broadlands estate and much new else, and appreciate Greensward traffic, though less than main roads, does meet extra traffic traversing Lower Road. But to suggest that B1013 through Hockley and Hawkwell, busiest B road in UK, carrying 2000/hour quiet times, gridlock at peak times, now threatened by vast economic expansion proposal at the airport, is a suitable venue for 330 extra dwellings in south Hawkwell is ludicrous. Since opening of Cherry Orchard Bypass, all area traffic has been directed through Hockley and Hawkwell to Southend on B1013. B1013 (like the above roads) is a winding country lane. It has been hinted there will be new roads - where, and will this also involve compulsory purchase?

Highway improvements. I note these are under consideration to serve new developments, particularly to cast-west routes. Please do not subject home owners along B1013 winding lane to compulsory purchase of frontages to effect highway efficiency. This was done to owners on both sides of that road along Southend Road on Hockley hill in the 1960s. Apart from loss, speeds increased, accidents occurred and owners have had on-going problems. Any more and owners would lose homes as well.

Public transport improvements. Presumably as Standard Charges, are envisaged for new development at H Appendix 1 and CLT1. You need to watch crafty manoeuvres by services to get more money this way. For example, it is not coincidence that, since the revised Core Strategy consultation, with proposed large developments for Hawkwell, Ashingdon, Rochford was issued, Arriva bus company propose cutting back further their already abysmally poor Nos 7 and 8 services, presumably as ploy to get more money to reinstate them. Don't forget also that, unlike eg a community centre, classroom etc once provided a bus service is on-going. What happens to bus service when the builder has made his profit and moved on?

RETAIL AND TOWN CENTRES

I list my objections to proposals in Core Strategy under this heading in following 5 paras.

'2008 Retail/Leisure Study shows significant leakage out of the District...[should] direct retail development to town centres: Rayleigh/Rochford/Hockley'. You should understand Hockley has always been a village, traditionally having staple day-to-day shopping needs, eg grocers, butchers, bakers, fishmongers, greengrocers, haberdashers, hardware, newsagents, pharmacy, shoemenders, post office, building society or bank. Hawkwell also has a small shop parade with similar basics. At most, a modest extra supermarket might be set in the industrial estate in Eldon Way.

Regrettably, several prime Hockley units have become occupied by numerous estate agents. These should be reduced to two. An instructive example follows: in late 1980s, with already 6 agents, owner of one unit wanted change of use to estate agent. Planning Services refused on grounds it would be one too many. He appealed and won. In 1990 recession he closed, as did all the rest bar two, proving for once planners were right. A number of trivia shops have also arisen, which last a short time.

Residents have always expected to travel to Southend for furniture, clothing, large DIY stores other than hardware, bathrooms etc. This is NOT going to change. Any attempts have failed.

You need to understand there won't be any 'national multiples' in Hockley. Presumably Eldon Way industrial estate was considered a possible venue. The crowds and traffic would build up further in Spa Road, already a bottleneck. Remember your point that further housing for NE Hockley would increase traffic impact passing through Hockley. Also how would this fit with possible plans for extra housing in Eldon Way?

I have heard central Hockley central area might be regenerated. That will be resisted; there must be no demolition or compulsory purchase here, where there are listed and period buildings, too many of latter have been destroyed in Hockley already, intentionally to change its character.

There is also no space for large multiple stores in either Rayleigh or Rochford, which would be damaged. Southend High Street and Hamlet Court Road are ideal for large scale shopping.

ECONOMIC DEVELOPMENT AND EMPLOYMENT GROWTH

I object to proposals in Core Strategy preferred options as follows. 'East of England Plan specifies the number of jobs any sub-region must provide'. Apart from the airport, Rochford District is not within Thames Gateway and EEDA are not qualified to dictate 3000 jobs must be found. EEDA's idea the airport will generate large employment is unrealistic - jobs from this will be temporary.

Many attempts have been made to 'reduce reliance on out-commuting' without success. Vide the empty office blocks in Southend once occupied by eg Willis Faber, C E Heath & Co., Prudential, CU - all now elsewhere. You cannot replicate London employment in Rochford.

EDUCATION

I understood 'new residential development' was for extension of existing population, not meant to 'result in more people living in the District' already overcrowded. I'm surprised Hockley isn't expected to generate additional educational needs. I conclude the new upwardly mobile moving to executive mansions from elsewhere get their young tutored at private prep schools in Southend to pass the 11+ and get into Southend grammar schools. It should be noted parents have for years had a problem getting their children into any of the 3 overcrowded primary schools.

HEALTHCARE

It seems appropriate to propose under CLT4 that 'new developments be accompanied by a Health Impact Assessment... and developers be required to address negative effects prior to development implementation'.

Having, with other existing neighbours, experienced deafening noise 7am to 7pm 7 days per week for several years, polluting and furnace heating fires, daylight denying and night dark removing huge edifices in course of adjacent development, there is a definite impact on health by development.

PLAY SPACE

I object to preferred options proposals under this heading for following reasons. I thought Strategy said RDC would be abolishing practice of removing homes and gardens to get greater density. Gardens for children are essential. Even if out of sight, they are within earshot of adults. I note couples with small children are usually keen to have a place with garden. Communal play space advocated under CLT7 means children must be escorted. There is one on Hawkwell green, adults not permitted to enter.

AGEING POPULATION

I object to preferred options comments here. Core Strategy is obsessed with this. It is nonsense that ageing population leads to a smaller workforce with higher dependency ratio. Many persons of retirement age forced out of jobs by the baby boom continue to earn a living if allowed to do so, well beyond retirement.

Final insult under Youth Facilities '...ageing population (which could lead to increased demand for health and social care, rather than services for youth) it is important....needs of young people...catered for..'. The old, as well as striving to keep economically sound, also take steps to remain healthy and so are no more a burden to NHS and social services than younger groups.

As I said under Housing, if you feel the old are in the way in various ways, EEDA could clear them with termination camps.

PROTECTION, ENHANCEMENT OF LANDSCAPE AND HABITATS

I object that landscape and gardens in built area gardens have been excluded.

This is laudable, but it should be noted that landscape and habitat are also found in local gardens. Any wild life if found in same would need protection - definitely not translocation as at Etheldore Avenue etc, with unfortunate results. Developers have been known to drive protected wildlife out ahead of building and Rochford Woodland office to designate flourishing hedgerows 'dying, diseased'. So I object to landscape and habitats in gardens, built area being omitted from preferred options here.

CONCLUSION

I appreciate all this sounds negative, but development and inward migration ideas are out of hand.

Greenbelt. The perceived need to release some and recognition that existing settlements have increasingly limited space for further development clarifies that further government/developer demands must now be resisted. S E Essex is overcrowded and too small for further incursion.

Flood risk. Practically all Thames Gateway is a flood basin. From RDC map, most of the District is either at flood risk from N. Sea, rivers Crouch, Roach or else enjoys special protection. Permeable pavement is a good idea to stop surface flooding from paved residential frontages (now needing planning permission), but another problem is the many drainage ditches that have been filled in in residential and other areas.

Car dependency and congestion will continue with any population growth.

Energy consumption. Small wind turbines don't produce relevant energy. Most homes don't have cavity walls (doubtless an excuse for demolition as not sustainable).

In sum, I object to Core Strategy preferred options as further extensive development in Rochford District cannot be contained.

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.

CORE STRATEGY - PUBLIC CONSULTATION

Ashingdon Parish Council accepts that that more homes must be built in the District of Rochford.
The suggestion of sharing the burden of additional homes equally around the existing conurbations seems to us to be reasonable.
We agree that additional infrastructure must be provided to support the new residents and prevent existing residents suffering from stretched and weakened services; roads, schools, sewerage, health facilities, etc.
The Green Belt must be protected as much as possible;
every scrap of'Brownfield Land' should be sensitively used.
We will support you in demanding infrastructure improvements to accompany new developments.
Whenever possible developers must be required to pay for these improvements to the existing infrastructure.
We must work together to: pressurise government authorities responsible for infrastructure (roads, schools, sewerage, health, etc.) to agree that additional provision is required; and to ensure that these agreed improvements are actually made.


John Dyke - Clerk to Ashingdon Parish Council 15 December 2008.

We do not want our fields released for housing - at the moment we are seperated from Shoebury by a road and large fields which give our community the village image that is unique to us. Leave green belt as it should be.