GB1 Green Belt Protection - Preferred Option

This option offers a well rounded arguement

I attended the CAC Meeting in Hawkwell.

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

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

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

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

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

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

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

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

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

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

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

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

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

Although I have already sent you comments on behalf of Hockley Parish Plan Group, I would now like to register my own comments as a resident of Hockley:

The Core Strategy proposes to add 1,550 new homes on Greenbelt land in the pleasant semi-rural region comprising Hockley, Hawkwell, Ashingdon and Rochford, plus a further undefined number of homes on brownfield sites, and a further undefined number of homes in the Hockley and Rochford town centre developments. The new homes will reduce the open spaces between these parishes, closing the boundaries, and leading to the loss of their individual community identities.

Residents enjoy living (and retiring) in this region. However, the infrastructure of the area is already stretched in terms of roads, public transport, parking, schools, community services, and healthcare. The Core Strategy proposal gives very little detail of infrastructure improvements to support the increased population and traffic. It provides no details of costs or responsibilities for infrastructure implementation. By spreading the locations of new homes, it will be more difficult to ensure that developers incorporate and pay for new infrastructure.

Although average daily traffic on the B1013 is stated to be only 72% of the maximum capacity, there are no figures available that highlight the current congestion in peak periods, where traffic is almost at a standstill. Unless significant highways development is introduced, especially in the vicinity of the Spa roundabout, the additional traffic resulting from the Core Strategy proposed homes in Rochford and Hawkwell, will create gridlock. Proposed Southend Airport development will add further traffic problems through Hockley. The Core Strategy is not sustainable without a solution to the highway network bottlenecks in and around Hockley. No solution is provided to the lack of cycle path networks in the region.

The bus service in the Hockley and Hawkwell region is about to be cut back, but will need to be increased to support the additional number of residents proposed in the Core Strategy. Agreements with Arriva must be included to make the Strategy viable.

Car parks in Hockley are regularly overfull creating queues especially in Spa Road. Exits from the car parks in Spa Road are hazardous and will one day inevitably lead to a serious accident. Space in Hockley town centre is at a premium, but additional and safer car parking is essential to support the proposed additional traffic, or again the Core Strategy is not sustainable.

The Core Strategy includes new primary schools in Rochford and Rayleigh and an extension to King Edmund secondary school, but there is no proposal for additional school places in Hockley and Hawkwell. I assume that the majority of additional younger children in the Hawkwell region will go to Westerings School, where the roads in the locality are already a hazard during the 'school runs' where mothers drop off and pick up their children. Local residents regularly have to weave between cars and drive on pavements to avoid a collision. Without major improvements to the road networks in this region, the increased numbers of cars will undoubtedly cause havoc and lead to accidents. There are no proposals in the Strategy to accommodate additional secondary school children at Greensward College, which is the nearest school for Hawkwell West.

Community Services such as crime prevention, street cleaning, waste collection and road maintenance are already stretched, and will not be able to cope with the additional homes without a considerable increase to their budgets. It is unlikely that increased Council Tax revenue from the additional population will support the extra costs.

Doctor and dentist to patient ratios are currently unacceptable for residents in Hockley and would need to improve significantly to support the additional number of residents.

In conclusion, although many of these obstacles can be overcome with possibly cost effective justification, the necessary changes to highway networks and car parking in and around Hockley to support additional traffic volumes are massive, and probably not feasible due to cost and space limitations, leading to the Core Strategy not being sustainable in Hockley and the surrounding area.

The protection of green belt in South West Rayleigh is paramount, given the high landscape value of the area, and looking at aerial photos of SW Rayleigh, it is difficult to see where 100 houses could be accommodated without harming the landscape and the green belt itself. This hilly area is particularly sensitive to development, and has been protected since 1960 when the last major development in the area took place. I can see no reason to remove this protection now, and do irreparable harm to the historic setting of Rayleigh as viewed from the North and Western approaches.

CPBC support the protection of the Green Belt and the release of Green Belt based on how well the land helps to achieve the purposes of the Green Belt and separation of settlements.

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).

Whole hearted support as long as the term "seek" is interpreted as putting sufficient resources into following a process at looking at genuine alternatives.

It is important to support our local businesses by not eroding green belt in which they rely on. In particular I quote farmers; in ensuring that agricultural farmland and other land essential to running a farm is left intact for generations to come.

I totally support your theory, but once again I do not feel that you are carrying out what you say, the proposals for West Rayleigh/Rawreth are largely on greenbelt land where several other brownfield sites are available, I therefore object totally with your proposals for the siting of developments in Rawreth and West Rayleigh, but wholly agree and support that greenbelt land should not be used

Loss of Greenbelt should be avoided but scattering development across the District will exacerbate the impact.

green belt land must be preserved and brown field sites used for development.

I believe that the Government recommendation is that only 30% of land released for new housing should be green-belt. We must keep as much space as possible between our villages and towns and I am not convinced that up to 70% of land in the preferred option needs to be green-belt.

Agree with sentiments but H2. seems to contradict GB1 in the case of land north of london road rawreth and also land in sw hullbridge where in both cases land of lesser importance and value is available .

I support the protection of Green Belt and particularly the separation of distinct communities. With 3500 houses to be built in the Rochford area and an unspecified number under the Hockley Masterplan, it is essential that development is concentrated near to existing centres, not spread thinly all over the countryside. We do not want existing centres to be joined up by strip development.

The protection of green belt in South West Rayleigh is paramount, given the high landscape value of the area, and looking at aerial photos of SW Rayleigh, it is difficult to see where 100 houses could be accommodated without harming the landscape and the green belt itself.Why are the council even considering releasing this type of land??? Lets stop any development of our precious area now before its too late

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.

Policy GB1 should be amended to provide for the potential need to alter Green Belt boundaries as part of the Joint Area Action Plan for the Airport and Environs (JAAP) where this is required to meet the economic development and employment growth needs of the district and wider sub region.

The reference to preventing coalescence accords with Government policy, but conflicts with Policy H2 which identifies land at South Hawkwell where the Local Plan Inspector said the Green Belt had an important function in separating settlements.

There are too few open spaces in South West Rayleigh. Building on them will degrade the life of your loyal council tax payers. It will exacerbate traffic problems at Rayleigh Weir and the railway station and will increase the hazards for children going to Rayleigh Primary School and their sports field in Spring Gardens. Green Belt land MUST be protected to keep our town from becoming an 'urban sprawl'. Building on our land reduces areas for wildlife, has a detrimental effect on the water table and causes unwanted pollution. DO NOT PILLAGE OUR GREEN BELT.

Sufficient flexibility needs to be allowed for within policy GB1 for the various important economic growth options of the Joint Area Action Plan for the Airport and Environs [JAAP].This opportunity represents the most significant economic driver for South East Essex for the foreseeable future and Rochford's planning must reflect this.

The objective of GB1 to direct development away from the Green Belt is strongly supported although this is at odds with an expectation that 70% of new housing will need to be provided on Greenfield sites.

CPRE are very concern that such a high proportion of the proposed houses should be built on Greenbelt land. Brownfield sites should be the preferred option.

H2 would appear in direct conflict with this objective

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

1.0 Instructions and Introduction

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

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

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

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

Peter Kneen BSc (Hons) MSc MRTPI
Planner

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

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

2.0 Housing:

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

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

Policy H1 - Distribution

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

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

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

Policy H2 - General Locations and Phasing

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

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

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

Policy H3 - General Locations Post 2021

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

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

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

Policy H4 - Affordable Housing

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

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

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

Policy H5 - Dwelling Types

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

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

Policy H6 - Lifetime Homes

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

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

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

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

Policy GB2 - Rural Diversification and Recreational Uses

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

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

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

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

Policy ENV4 - Sustainable Drainage System (SUDS)

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

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

Policy ENV8 - Code for Sustainable Homes

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

5.0 Transport:

Policy T1 - Highways

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

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

Policy T2 - Public Transport

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

Policy T4 - Travel Plans

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

Policy T5 - Cycling and Walking

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

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

Policy T7 - Parking Standards

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

6.0 Character of Place:

Policy CP1 - Design

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

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

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

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

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

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

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

Policy CLT6 - Community Facilities

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

8.0 Summary:

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

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

I accept the need to build more houses, but strongly object to using PRIME FARMLAND (eg area 144 north of London Road bordering Rawreth Lane.) which is totally unsustainable and unnecessary because we need the farmland for FOOD PRODUCTION and because NO NEW ROADS are planned to cope with the resultant increase in traffic. Furthermore, using ONE LARGE SINGLE SITE such as 144 concentrates the traffic chaos for the whole area. Already surrounding roads cannot cope at peak times and when problems occur (eg accidents on A127; flooding of Watery Lane in November) when all surrounding roads become completely grid locked. Using this one large site seems a very convenient solution for the PLANNERS, but is not the best solution for the COMMUNITY.

Why is no priority being given to using EXISTING BROWNFIELD AND RESIDENTIAL SITES? (eg area 73 and the garage opposite it, 28, 89, 135 etc). Their sites have the advantage of NOT being prime farmland and those which are at present UNSIGHTLY will BE IMPROVED. Also, because they are scattered and not concentrated in one single site, the resulting increase in traffic congestion will not be so detrimental to the area.

We also have no objection to area 17 and the extreme northern area of the golf course (area 19) being used because they are near existing residential areas bordering Lower Road, Hullbridge. But we strongly object to the whole of area 99 and the southern part of area 19 because they border EXISTING WOODLAND AREAS.

Since moving to this area of Rawreth Lane a few months ago (on a brownfield site development). I have noticed the severe traffic problems that arise especially at rush hour due to the sheer volume of existing traffic. Indeed it only needs a slight problem on one of the neighbouring roads (ie Watery Lane was closed recently) for the entire area to become gridlocked.

I strongly object to using prime farmland off Rawreth Lane (north of London Road, Rayleigh) (No 144). If we continue to build on our farmland how are we going to support and feed our families in the future?

Why can't we make the already marked brownfield and residential areas available for building houses? Some of these sites will in fact look much better after they're developed (ie land on A1245 garage is a particular eyesore at the moment).

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

Dear Sir / Madam,

Rochford District Council Local Development Framework, Core Strategy Preferred Options Consultation Document

We are instructed by our client, Fairview New Homes Ltd, to submit comments on the published Preferred Options Core Strategy Document, and these are set out below. For ease, specific reference has been made in accordance with the paragraph numbers as contained in the published document.

Vision

The Council's key planning objectives include the following:

o To work towards sustainable development by making the most effective and efficient use of land.
o To improve the quality of life of the inhabitants of the District by providing the best possible environment, and satisfying social needs by making accessible provision for the necessary health, housing, educational, community and leisure facilities in the interests of the total well being of all groups within the population.
o To ensure the availability of land in appropriate locations for housing, commercial and industrial uses.
o To retain, conserve and enhance the built and natural environments, including the architectural and historical heritage, flora, fauna and their habitats throughout the District.
o To make provisions for transportation improvements to effect the most environmentally sustainable, efficient, convenient movement of goods and people.
o To define and protect the Metropolitan Green Belt, the undeveloped coast and area of ecological interest by directing development towards the District's established settlements.
o To enable the existing business community to function as efficiently as possible and to support economic and regeneration development throughout the Borough.

Whilst our client would like to provide support for the Council's key planning objectives, at present there are a number of aspects which are currently inconsistent or do not accurately reflect the sentiments of the Preferred Policies set out in the remainder of the draft Core Strategy.

Firstly, there is currently no recognition within the Council's key objectives of the most appropriate direction for development. Whilst it is understood that these are overarching aims, it is considered particularly important that locating future development within and adjacent to the Borough's existing larger settlements is essential in order to uphold national, regional and local sustainability aims. This requirement is in line with our further comments on this particular subject below.

Further, it should be made clear as part of objective six that the Green Belt boundary is to be re-defined. This provision will ensure that the objective is consistent with the allowances made in preferred Policy GB1 and the associated supporting text to release some Green Belt land where deemed appropriate and necessary.

Housing

In response the Council's method regarding the location, type and timing of housing development, as set out on page 24 of the draft Core Strategy Document, care should be taken to ensure that the requirements stipulated at Paragraph 54 of PPS3 are adhered to. In particular, the deliverability of sites should be carefully considered when taking decisions on the timing of housing development, in that the site should be available, suitable and achievable, in order that the five year housing supply is realistic in its aims.

Distribution

The Council's Preferred Option for housing distribution is set out as follows:

Policy H1 - Distribution - Preferred Option

We will prioritise the reuse of previously developed land identified as being appropriate as part of our Urban Capacity Study, having regard to the need to protect sites of ecological importance. Areas coming forward for residential development identified within the Urban Capacity Study will be required to conform to all policies within the Core Strategy, particularly in relation to infrastructure, and larger sites will be required to be comprehensively planned.
In order to protect the character of existing settlements, we will resist the intensification of smaller sites within residential areas. Limited infilling will be acceptable if it corresponds to the existing street pattern and density of the locality. We will encourage an appropriate level of residential intensification within town centre areas, where higher density schemes (60+ dwellings per hectare) may be appropriate. The remaining housing requirement will be met through the allocation of land on the edge of existing settlements as outlined in H2.
Our client would like to provide support to the realistic approach taken by the Council in respect of brownfield development within existing settlement boundaries. However, in order that the character of existing settlements can be maintained and Policy H1 can be adequately implemented, Policy GB1 relating to Green Belt protection will need to incorporate a sufficient level of flexibility to allow the release of Green Belt land where it is considered appropriate.

General Locations

At present, support cannot be provided to the Settlement hierarchy as set out on Page 26 of the draft Core Strategy Document. Whilst it is considered appropriate for Rayleigh to be designated as a Tier 1 settlement, the draft Core Strategy is currently not consistent throughout in this respect. It is noted on Page 20 of the Strategy that Rayleigh is the only first tier settlement which could be classed as a 'principle town centre'. Rayleigh is also considered to have the best access to services in the District. However, when considering the general locations for housing development there is no consideration of the higher order level of the settlement of Rayleigh. Rayleigh should be considered the priority direction for housing development given the greater level of services available and public transport connections, in line with the designation set out on Page 20. The greater concentration of services available within Rayleigh results in adequate capacity being available to support a higher level of resident development. In addition, directing development in this manner will act to support the Council's environmental and sustainability aims, particularly, Preferred Policies ENV1,2 and 3.

We, therefore, recommend on behalf of Fairview New Homes that the settlement hierarchy set out on Page 26 be amended in order to reflect the higher level order of Rayleigh.

The Council's preferred option for the general location and phasing of housing development is as follows:

Policy H2 - General Locations and Phasing - Preferred Option

We will extend the residential envelope of existing settlements for the purposes of residential development in the following areas to deliver the following approximate number of units by 2015 or between 2015 and 2021, as stipulated below and indicated on the Key Diagram.

Area - North of London Road, Rayleigh
No. of units by 2015 - 450
No. of units 2015 - 2021 - 200

Area - South West Rayleigh
No. of units by 2015 - 100
No. of units 2015 - 2021 - 0

Area - West Rochford
No. of units by 2015 - 300
No. of units 2015 - 2021 - 100

Area - West Hockley
No. of units by 2015 - 50
No. of units 2015 - 2021 - 0

Area - South Hawkwell
No. of units by 2015 - 100
No. of units 2015 - 2021 - 100

Area - East Ashingdon
No. of units by 2015 - 120
No. of units 2015 - 2021 - 0

Area - South East Ashingdon
No. of units by 2015 - 20
No. of units 2015 - 2021 - 0

Area - South West Hullbridge
No. of units by 2015 - 0
No. of units 2015 - 2021 - 450

Area - South West Great Wakering
No. of units by 2015 - 100
No. of units 2015 - 2021 - 100

Area - West Great Wakering
No. of units by 2015 - 50
No. of units 2015 - 2021 - 100

Area - South Canewdon
No. of units by 2015 - 60
No. of units 2015 - 2021 - 0

Total no. of units by 2015 - 1450
Total no. of units 2015-2021 - 1050

The detailed location and quantum of development will be articulated within the Allocations Development Plan Document.
Development with the above areas will be required to be comprehensively planned. A range of other uses and infrastructure (including off-site infrastructure), having regard to the requirements of the Core Strategy, will be required to be developed and implemented in a timely manner alongside housing. H Appendix 1 outlines the infrastructure that will be required for each residential area, and should be read in conjunction with Preferred Option CLT1.

We will maintain a flexible approach with regards to the timing of the release of land for residential development to ensure a constant five year supply of land.

Fairview New Homes would like to offer strong support in response to Preferred Policy H2 as well as to the general housing locations as shown on the accompanying Key Diagram. In particular, it is requested that the intention to extend the existing settlement boundary in the south west area of Rayleigh is retained when formulating the Core Strategy Submission document. Our client has an interest in a large parcel of land in this location of Rayleigh which is available for redevelopment in the immediate future, therefore, reflecting the phasing option set out in Preferred Policy H2.

In addition, the retention of a flexible approach to the timing of the release of the areas of land set out in Policy H2 is particularly important in order that sites can come forward when available and required.

Affordable Housing

The Council's preferred option for affordable housing is set out as follows:

Policy H4 - Affordable Housing - Preferred Option

At least 35% of dwellings on all developments of 15 or more units, or on sites greater than 0.5 hectares, shall be affordable. These affordable dwellings shall be spread (pepper potted) throughout larger developments. Affordable dwellings shall be required to remain affordable in perpetuity - this will be secured through legal agreements.

This requirement will only be relaxed in highly exceptional circumstances, for example where constraints make on-site provision impossible or where the developer is able to definitely demonstrate that 35% provision will be economically unviable, rendering the site undeliverable. In such cases we will negotiate the proportion of affordable dwellings based on the economic viability calculations. It is expected that affordable housing will be provided on each development site; in rare cases, taking account of particular site characteristics, the affordable housing contribution may be provided by way of a commuted sum towards off-site affordable housing.

The Council's realistic approach to securing affordable housing throughout the Borough is supported by Fairview New Homes. In particular, the flexibility and recognition that it may not be possible to provide the full requirement of affordable housing on all sites is offered strong support by our client. In this respect full consideration should be had towards individual locations and specific sites depending on the findings of the Strategic Housing Needs Assessment (PPS3 Paragraph 29 Part 3).

It is requested that the Council seek to retain an element of negotiation within Policy H4 when developing the Core Strategy to submission stage in order to allow a sensitive approach to local housing need as it fluctuates throughout the Council's administrative area rather than a blanket approached.

Further, the first part of the preferred policy requires that affordable housing be spread "(pepper potted)" throughout new development. Whilst my client is sure you are aware, management is a real issue for social landlords, and often it is not practical to adopt a 'pepper pot' approach, and further consideration should be had of the 'user' / 'management' requirements when developing the Core Strategy to Submission Stage.

Lifetime Homes

The Council's preferred policy for Lifetime Homes is as follows:

Policy H6 - Lifetime Homes - Preferred Option

We will normally require all new housing developments to comply with the Lifetime Homes Standard from 2010. Exceptions will be made where such a requirement threatens the viability of developments, in which case we will seek a proportion of units to comply with the standard.

In line with our comments in respect of Preferred Policy H4 Fairview New Homes would like to provide support to the recognition that in some instances the Lifetime Homes Standard will not be able to be met. It is requested that this level of flexibility is retained when developing the Core Strategy Submission Document.

The Green Belt

Protection of the Green Belt

Whilst it is recognised that there is a need to protect Green Belt land throughout the Borough, on behalf of our client, we would like to provide full support to the acknowledgement on Page 41 that a proportion of the currently allocated Green Belt land will need to be released for redevelopment. When considering areas of land for release, those adjacent to the existing settlement boundary should be prioritised in order that settlements within the Borough are coherently extended.

In particular, the area of land to the South West of Rayleigh, designated as a general location for housing in Preferred Policy H2, should be a key priority for reallocation. This land is available for development and is sited in a particularly sustainable location, therefore, meeting with the wider aims of the draft Core Strategy, as well as contributing towards the Council's housing requirements for the Borough. Release of small areas of Green Belt surrounding larger settlements will allow a concentration of development in key areas. In addition, there is no risk of coalescence of settlements should Green Belt land be release to the south west of Rayleigh.

Further, our client would also like to support the provision set out on Page 42 of the Draft Core Strategy document for high density development on the areas of Green Belt land released for development in order that remaining Green Belt land is sufficiently protected.

The Council's preferred policy for Green Belt Protection is stated as follows:

Policy GB1 - Green Belt Protection - Preferred Option

We will seek to direct development away from the Green Belt, minimise the reallocation of Green Belt land and will prioritise the protection of Green Belt land based on how well the land helps to achieve the purposes of the Green Belt.

The need to prevent the coalescence of individual settlements, in order to help preserve their identities, will be given particular consideration.

In line with our comments above, our client would like to endorse Policy GB1 in that some allowance remains within the policy to permit the release of Green Belt land where appropriate and necessary. This flexibility is essential in order that the Council are able to meet the housing provision requirements set out in the adopted East of England Plan in the plan period until 2021.

Transport

Parking Standards

Rochford Borough Council's preferred policy on parking standards is set out as follows:

Policy T7 - Parking Standards - Preferred Option

We will apply minimum parking standards, including visitor parking, to residential development. We will be prepared to relax such standards for residential development within town centre locations and sites in close proximity to any of the District's train stations.

Whilst applying maximum parking standards for trip destinations, we will still require such development to include adequate parking provision. Developers will be required to demonstrate that adequate provision for the parking, turning and unloading of service vehicles has been provided.

At present our client is unable to support Preferred Policy T7 in its current form, due to the lack of coherence with national planning policy set out in PPG13. The first part of the preferred policy specifies the Council's intention to apply minimum parking standards to residential development. Paragraph 17 of PPG13 clearly states that parking policies should not be expressed as minimum standards. Considering this against advice set out in PPS12 at Paragraph 4.52, Local Planning Authorities should ensure that Core Strategies are consistent with National Policy in order that the document can be considered to be sound. As this is the case we are unable to endorse Preferred Policy T7 in this respect. Instead, it is requested that the Council seek to enforce a maximum parking standard to ensure that the sustainable aims of PPG13 are upheld.

Open Space

The Council's preferred policy relating to the provision of open space is set out as follows:

Policy CLT5 - Open Space - Preferred Option

New public open space will be required to accompany additional residential development, having regard to local current and projected future need. Standard Charges may be applied to developments as necessary.

In particular we will seek the incorporation of a significant amount of public open space to accompany new, and be integrated with existing residential development in the west of Rayleigh.

Furthermore, the following existing uses will be protected, whether in public or private ownership:

• Parks
• Amenity areas
• Allotments
• Playing pitches
• Any other form of open space that has a high townscape value or is intrinsic to the character of the area.

New forms of the above will be promoted.

Fairview New Homes strongly object to the requirements set out in preferred Policy CLT5.
Whilst the sentiments of the policy are well founded and it is recognised that there is a need to provide public open space throughout the Borough, there is no justification as to why a significant amount of public space will be required in the west of Rayleigh. No information or evidence is provided to rationalise this requirement either as part of preferred Policy CLT5 or within the accompanying supporting text. Further, there is no explanation as to why this particular area of the Borough is specified for a higher than average provision of public open space, as an exception.

On behalf of our client, we would be grateful if you would acknowledge receipt of this submission and have due regard to these comments when making changes to the Core Strategy prior to the submission of the document.

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

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

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

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

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

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

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

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

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

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

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

Summary of Representations on behalf of MD Smith & Son

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

Details of Representations

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

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

Green Belt Study

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

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

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

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

Strategic Housing Land Availability Assessment

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

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

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

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