ED3 Existing Employment Land - Preferred Option

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.

Is it really sensible to use existing long established industrial sites/employment land for new housing?

In the current economic climate some such sites may be underused, but an upturn in the economy in later years could easily reverse that situation.

In the case of the Rawreth Industrial Estate, the planning authority is proposing to release green belt land to replace it. How can this be regarded as acceptable?

We would appreciate details of how the highways are to be improved to Baltic Wharf so that we evaluate future employment opportuities in a rural area

Essex Chambers of Commerce supports the review of existing employment land and the reallocation for housing where appropriate. It is considered essential to improve the highway infrastructure serving Baltic Wharf to sustain employment, but it is also essential to improve the highway infrastructure and access to all industrial estates, especially Purdys.

The review of existing employment land requirements, and the reallocation of sites for housing, where appropriate, is fully supported. The redevelopment of vacant industrial land for new housing will minimise the need to release Green Belt land, and will allow for the removal of contamination, the re-use of existing on-site materials, and the general environmental and ecological enhancement of the site and surrounding area.

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.

ECONOMIC DEVELOPMENT

ED1 preferred option.

We support the concept.

But they need to consider improved access

Pressurise Central Government for funds to improve infrastructure for example Stobart is an infrastructure user

Ensure it's a driver for employment.

Ensure it maintains its highly skilled workforce of its engineering base.



ED2 preferred option

The Chamber needs to see the Area Action Plan details to enable them to comment on this proposal.



ED3 preferred option

We support,

However we need further details of the infrastructure plans to this and other major employment site eg the Airport.

We doubt the viability of relocating businesses for housing.

The danger of this policy in relocating businesses, will more than likely lead to relocation out of the area, probably westwards where infrastructure is better.



ED4 preferred option

The areas infrastructure needs considerable improvement to ensure employment retention and growth so that the areas economy improves to the well being of the area.



ED5 preferred option.

We support





ENVIRONMENTAL

ENV6 preferred option

Disagree



ENV6&7 items 1&2

The plan needs to look at and consider other options such as

Combined Heat & Power plants

District heat

Use of the water powers in the River Crouch with such items as;

Underwater generators

A barrage across the River Crouch west of Lion Creek to generate Hydro Electric Power as they do in Scotland, and at the same time it will create an excellent new leisure facility.



TRANSPORT

T1 preferred option

It's a nice concept

The plan will need more than developer 106 contributions.

Reflect reality the car is here to stay as per paras 5&6 highways page 65 and base policies accordingly



RETAIL

RTC4

Neither support nor object.

Until we see the Area Action Plan to enable us to comment constructively

The profile of Rochford needs raising to improve the economy to improve social standing.



UPPER ROACH VALLEY and WALLASEA ISLAND

URV2 preferred option.

Whilst we support the RSPB project their should be adequate facilities for visitors and the infrastructure improved to the site from Rochford, they should ensure 106 agreements are in the consent.

Dear Mr Scrutton

Consultation on the Core Strategy Preferred Options

Thank you for the opportunity to comment on the proposed Core Strategy Preferred Options for Rochford District Council.
EEDA receives a number of requests of this kind, as a statutory consultee, and our experience to date suggests a number of points on Core Strategy documents which your authority may wish to consider.
EEDA's principal role is to improve the East of England region's economic performance. Our main concern with Core Strategy documents is therefore that they will help deliver, and provide the spatial framework for:
• sustainable economic development and regeneration in the East of England, and in particular,
• the new Regional Economic Strategy (Inventing the Future - Collective Action for a sustainable economy, 2008).

Planning Policy Statement 1 'Delivering Sustainable Development', 2005 reminds local authorities that in preparing local development plans they should seek to provide a positive planning framework for sustainable growth in support of the Regional Economic Strategy (RES). The RES advocates a region that is internationally competitive with a global reputation for innovation and business growth that harnesses and develops the talents and creativity of all and is at the forefront of a low carbon and resource efficient economy.

In addition, Planning Policy Statement 12 'Creating Strong Safe and Prosperous Communities through Local Spatial Planning', 2008 recognises that spatial planning is a critical element in relation to economic growth and regeneration. The RES supports and complements the East of England Plan and EEDA supports the implementation of policies within that strategy.

It is within this context that EEDA makes its response.

Thames Gateway South Essex is defined as an Engine of Growth within RES. As such, Thames Gateway South Essex and its urban sub region are expected to disproportionately drive growth, given the importance of agglomeration and the concentration of assets. The strategic ambitions are identified below and should be expressed in your core strategy.

• achieve levels of productivity and earnings of at least the regional average
• radically improve the skills base through employer-led learning opportunities and the creation of 21st century education facilities, including schools, new university campuses and industry-led skills academies
• London Gateway as a national logistics and ports enterprise hub - a centre for research and technical support as part of an associated cluster, including the Port of Tilbury
• reinvent and revitalise the city and town centres in Southend-on-Sea, Basildon, Thurrock and Castle Point with thriving residential, retail and leisure offers
• become renowned for high-quality public and green spaces and attractive waterfront development
• become a niche centre in the creative industries, including the Production Campus and Creative National Skills Academy in Thurrock and a focused offer in Southend-on-Sea built around the university, METAL and thriving arts and new media businesses
• realise and harness the potential of London Southend Airport as a key transport gateway for the Thames Gateway, by improving operational capacity, surface access and supporting business development in engineering and maintenance.

By addressing these key elements of the RES, the Core Strategy will provide the context needed to maintain the prosperity of the East of England, enhancing its regional competitiveness and giving support to business growth.

EEDA welcomes priority 8 of your Council's Core Strategy and the identification of London Southend Airport as a key employment opportunity within the district. The Thames Gateway area is a national priority for regeneration and growth with the need to accommodate 3000 jobs within the district of Rochford. The Core Strategy further identifies that a significant proportion of these jobs can be accommodated as part of the growth of the airport and EEDA supports this.

In addition, the RES clearly identifies the potential of the airport as a key transport gateway for the Thames Gateway, as identified above. EEDA welcomes the preferred policy ED1 for London Southend Airport and the Council's joint approach with Southend Borough Council to develop an Area Action Plan. This approach should ensure that the role of the airport and its potential as a focus and catalyst for economic growth can be fully harnessed and developed.

EEDA also supports the Council's approach to reviewing existing employment land allocations within the district through an employment land review and welcomes policy ED3 - Existing Employment Land in relation to this. Policy ED2 - Employment Growth seeks to provide a range of employment uses and whilst EEDA supports this policy it could be strengthen by including this aim within the policy wording.

EEDA, Go East and EERA have reviewed existing methodologies for Employment Land Reviews across the region have published a guidance manual on Employment Land Reviews. I would encourage your authority to consider this guidance note in finalising your Core Strategy

The Council's aspiration for an Eco-Enterprise Centre as a focal point for business in the form of an enterprise or incubation hub would increase the offer for start up businesses within the district. Its aim to be an exemplar in sustainable construction and act as a flagship building further enhances this offer both in terms of high specification office space and the benefits related to this in terms of lower energy costs. It should further encourage the inward investment of businesses whilst aiding in the creation of higher value jobs.

If you would like to discuss any of these matters in further detail, please do not hesitate to contact me at the above address.

LDF - Core Strategy - Preferred Options.

On behalf of Rawreth Parish Council I confirm that this letter is a formal response of Objection to the Core Strategy Preferred Options with particular reference to the allocation of 1050 houses to be sited within the Parish of Rawreth - 650 initially "North of London Road", with a further 200 on the Rawreth Industrial Estate and 200 more at the edge of Hullbridge.

We believe that no development should take place until local infrastructure is in place and the roads are able to take the increased traffic that would result.

1. We believe that Rawreth should be included in Tier 4 - all other settlements, where additional development is considered unsustainable. Rawreth presently has 373 dwellings and to put in developments of 1050 houses which equates to a 228% increase is totally unjustifiable, unsustainable and would completely destroy the
character of Rawreth.

2 The huge development of 650 houses "North of London Road" Rawreth is totally
unacceptable. This land is good quality agricultural land which is protected by the
Green Belt -GB1 - fulfils all purposes under PPG2 and should be retained as such.
Once used for development this land can never be returned to agricultural use, and if
you continue to erode into our Green Belt and farmland it will be lost forever.


3. This particular area is part of the "Gateway to Rochford " and is the "strategic buffer"
between Rayleigh and Wickford. Reference is made in the document to "avoiding coalescence" of villages/towns - a development of this size immediately erodes this buffer, starts coalescence and destroys the rural character of Rawreth.


4. The document clearly states that "Brownfield" sites would be considered before Green Belt land is used. This is not the case with the land ""North of London Road" and there are several sites within the area in the "Call for Sites" document that should be looked at first, these sites as we understand have not even been visited by the Local Development Framework Sub Committee and do not form part of the preferred options. These sites need to be visited, considered and the views of all the residents considered before any development areas become "site specific". A complete consideration has to be given to all the sites put forward in the "call for sites" and not just those that appear an easy option for development.

5. The roads and infrastructure in the Rawreth area are completely full to capacity. The A127, A1245, A129 London Road, Rawreth Lane and Watery Lane just cannot take any more traffic and this proposed development will increase traffic to a completely unsustainable level. On three occasions in the last month alone, incidents within and on the outskirts of this area have brought traffic to a standstill for hours along London Road, Rawreth Lane, Watery Lane/Beeches Road and the Hullbridge Road. It took some residents 1 ¼ hours to proceed along Rawreth Lane and into Hullbridge - a distance of 1 ½ miles.

The proposed development at the western edge of Hullbridge, which is, in fact, largely in Rawreth would also greatly increase the traffic problems in the area. We understand there would be a proposal to "widen/straighten" Watery Lane/Beeches Road, with a roundabout at the junction with the Hullbridge Road. This is an extremely dangerous junction even at the present time and would become increasingly so. There is also the question of where the traffic would go when it reaches Battlesbridge at the Western end, it cannot possibly cross the Bridge as this is "restricted" and in a Conservation Area, therefore, it would have to turn left and proceed to the A1245 -
a very dangerous junction.

6. The Services in the area would be unable to cope with this increase in housing - drains and sewers are already working to capacity. Recent heavy rain resulted in flooding in Watery Lane and the Rawreth Brook system has been very close to flooding twice already this year. During a meeting between the Parish Council and the Environment Agency we were advised that this situation will worsen with increased housing.

7. We believe that the appropriate amount of additional housing should be built on smaller existing sites thus enhancing the lives and environment of existing residents.
We believe RDC should consider the use of smaller sites that have been put forward, particularly in the Rawreth area and that the large development proposed "North of London Road" should be refused. We are at present in the process of developing our Community Garden in the centre of Rawreth Village with the help of a Community Initiatives Fund and believe that a reasonably sized development of houses in that area could be of benefit to our village. It may be that any development of this nature could include a village shop which would be of enormous value to local residents.

8. Large numbers of housing in one area, as stated in the infrastructure requirements, will necessitate a new primary school. County figures suggest that there will be surplus places in Rayleigh schools even with new housing. Obviously these will be in the wrong parts of the town so increasing the risk that an existing school could close .It makes sense to spread the development in smaller sites around the town, avoiding closure and preventing unnecessary provision of a new school.

9. Relocation of Rawreth Industrial site to a vague area south of the London Road near
Carpenters Arms would take further green belt, admittedly of moderate attraction, from the Parish. It is therefore suggested that an area bounded by the A127, A130, A1245 and the railway to the north gives the chance to provide high quality well designed industrial site with potential to use alternative forms of transport in the future.

10. Further use could be made of the land opposite Michelin farm. This land has been despoiled in recent years and landowners could and should be made to forfeit the full value of their land by way of compulsory purchase powers for use as a travellers site to provide some of the required pitches necessary for the Rochford District and to remove the illegal site on the A1245 at Bedloes Corner.

On behalf of Rawreth Parish Council I look forward to receiving an acknowledgement of this letter.