ED4 Future Employment Allocations - Preferred Options

This area is green belt land, and should remain as such.
The current apprach to Rayleigh, is a soft transition from countryside to residential areas on the edge of town.
This scheme will give a hard transition, and be an eyesore exactly like the ugly development in Rawreth Lane adjacent to farmland to the West ie Makro. Could you not have made some screening a condition of the granting of planning permission?.
Also, this scheme will add to the loss of land between Rayleigh and Wickford, unless a few fields are all that are required to say coallescence has not occured.

The relocation of rawreth industrial site and possibly imperial park to a new site vaguely in the carpenters arms area south of london road is unacceptable to rawreth as it is more erosion of green belt which admittedly is in a poor state but not without some merit .We suggest a site put forward bounded by the A130,A127,A1245 and the railway to the north would improve an eyesore and for the future give alternative transport options .This should be achieved by compulsory purchase as the existing illegal use should not allow the benefit to accrue to the landowners.

HAWKWELL PARISH COUNCIL

RESPONSE TO ROCHFORD DISTRICT COUNCIL ON THE CORE STRATEGY.

GENERAL BACKGROUND:
Members of Hawkwell Parish Council have had some opportunity to consider the Core Strategy Document issued by Rochford District Council. Whilst we are grateful to the District for providing 6 copies, this is a very large document needing considerable time to read and digest. Limitation of our access to 6 copies means that each document has had to be studied by up to 3 Members thus creating time constraints that should not be suffered with such an important document.

We note that the objective of this exercise is, primarily, to allow residents to respond to the options that have been identified as preferred. However we wish to make a number of observations to assertions made in the introductory remarks.

We are concerned that we are being asked to respond before we have had a chance to consider the Allocations Development Plan Document that is to be issued shortly. Whilst many sites have been the subject of speculation we cannot respond specifically until we have had the benefit of the formal statement identifying the actual sites and numbers of property to be built thereon. We therefore require the Planning Authority to provide good opportunity for residents to consider specific sites prior to their approval.

LISTENING TO YOUR VIEWS.

1. Page 3: In response to the comment that there is too much residential development proposed in our village/town. You have said you have reconsidered the matter but have given no indication of your conclusions. Do you accept the assertion or do you reject it, and if so on what basis.
2. Page 4 Intensification: We are concerned that you have inserted the phrase as 'far as is practicable' yet in H1 you state that you will resist intensification on smaller sites. Is this comment also subject to the aforementioned caveat, if not what powers will you rely on to achieve this and why can you not resist intensification currently.
3. Page 8 Priority 5: You state that walking and cycling are to be encouraged. With the greatest of respect, with an ageing population (Core Strategy Document penultimate paragraph page 14) is it realistic to brush aside the opportunity to ease an already almost gridlocked transport system and ignore the additional pressure to be imposed by an additional 3.5K houses by expecting elderly people to walk or cycle everywhere? Though much of the transport congestion experienced in the district is from the district much of it is also traffic travelling from outside Rochford to Southend.
4. Page 8 Priority 6: You say you are committed to improving access to sporting facilities yet we understand you recently rejected a central government initiative to give free swimming to the older people in Rochford. This decision is set against an acknowledgement that the population of over 65's is increasing and is expected to outnumber the under 20s by 2015! This aspiration does not sit well with the insistence on franchising the public sporting facilities out to the private sector that charge high entrance/membership fees thus reducing the ability of fixed income people to make use of these facilities.

CHARACTERISTICS, ISSUES AND OPPORTUNITIES:
Page 20 Settlements: We are incensed by the failure to recognise Hawkwell as a settlement in its own right. As the biggest Parish (based on population) and second only to Rayleigh Town we have, in this report, apparently been subsumed into Hockley. Whilst you may argue that, at the recent Central Area Committee, residents expressions of concern about the number and locations of new houses was premature, we cannot help but feel that, as a settlement that is ignored in the Core Strategy, we are having little say in the allocations of housing to our parish.

HOUSING:
We now wish to make the following observations in response to the chapter on Housing:
General Observation:
It is stated on page 23 (penultimate paragraph) that a balance of 2489 units have to be delivered before 2021 and the total to be delivered by 2025 is 3489, this figure after allowing for the 1301 units identified by the urban capacity study. This represents a 10% in housing and whilst we fully endorse the need to re-use land (brown-field sites) and allow small infill developments where the impact on the local infrastructure can reasonably be accommodated, we cannot agree that finding locations for almost three and a half thousand new homes (or a 10% increase) should be addressed on the basis of cramming them into existing settlements. We suggest that this requires a much more strategic view and the piecemeal approach based on a 'call for sites' is totally inadequate. In our policy document sent to the Planning Authority in December 2007/January 2008, we supported the view that a new settlement should be developed where the infrastructure needs can be properly developed and accommodated and where the additional housing will have the minimum impact of existing overdeveloped settlements. We believe there is strong argument that a new settlement would be far greener and thus, in the longer term, more sustainable that a myriad of smaller in fill sites. This option must not be rejected out of hand as is currently the case

H1 Distribution - Preferred Option
We are concerned that whilst our Planning Authority has adopted a policy against the intensification under this preferred option, this is contrary to what is currently happening with the increase in the number of flats being approved and the number of plots being turned from single dwelling sites to multiple dwelling sites. We are currently told that such intensification cannot be resisted, how then will the new policy be enforced? That said we would support the limitation on intensification and require that new lower levels agreed be adhered to.

In the penultimate paragraph on page 26 (General Locations) it is asserted that you have adopted a balanced strategy in respect of the location of housing development, we cannot see how the emerging proposals for Hawkwell are, in anyway, balanced allocations.

H2 General Locations & Phasing - Preferred Option:
Members hold the view that our policy developed and forwarded to the Head of Planning and Transportation in January 2008 still holds good. A copy of our policy is attached. Our view is that the Core Strategy appears to distribute new housing development on an uneven basis. We hold the view, as clearly stated in our policy, that if additional housing has to be distributed amongst existing towns and villages then it must be done on a sensible and defensible base such as existing population or geographical size and not on the ad hoc base that the call for sites appears to have produced. We strongly object to being subsumed into a settlement called Hockley/Hawkwell and then being expected to take the lions share of new houses that the Core Strategy allocates to this pseudo-settlement. (as indicated by the table in H2)

We do not believe that the argument against Rayleigh taking more of the allocation as given in H2 Alternatives (top of page 29) gives any sensible basis for rejection of this option, if the comment 'best access to services' still holds good then it must be properly considered and not thrown out as a result of clamour from the Rayleigh lobbyists on the District Council.

Transport
The diagram provided on the last page of the document shows a heavy concentration of development within Hawkwell and Rochford. This will inevitably have an impact on Rectory Road, Ashingdon Road, Main Road, Hawkwell and Hall Road ensuring a triangle of congestion on all routes to and from our village.

We cannot help but feel that the options in this section are pious hopes with little real substance. Seeking contributions from developers for public transport provision is laudable but transport companies and developers are ephemeral, housing estates are less so. We have experienced the way the private sector has progressively withdrawn service from our village, what safeguards are offered to sustain this transport when the provider decides it is not profitable and withdraws the service?

T7 Parking Standards:
We are concerned by the decision to apply minimum parking standards in residential developments. The District has insufficient resources to manage the consequential bad parking that occurs with cars parked over pavements causing obstruction to pedestrians and traffic alike. It is not sensible to adopt such a policy without also properly evaluating the consequence and then resourcing the appropriate methods of enforcement.

RTC 4 & 5 - Preferred Options:
We understand from the various consultations that the Hockley and Rochford Town Centre Studies have not yet been completed and we would require that these are completed and properly considered before any decisions are taken.

Economic Development Preferred Options: ED1 to ED 4
Contrary to what is stated in the Core Strategy there is too much reliance on the development of the airport and its environs involving the release of green belt land to provide jobs, it appears to be assumed that the new residents of Hawkwell will work there thus justifying the large proportion of housing in or adjacent to our parish.

We feel the Core Strategy and the JAAP in respect of Southend Airport should be properly integrated so that recommendations are consistent.

Character of Place:
Hawkwell Parish Council welcomes the re-introduction of the local list.

Community Infrastructure, Leisure and Tourism:
CLT 1 Planning Obligations and Standard Charges - Preferred Option
We are concerned that the interpretation of sustainability has been insufficiently addressed and we request that any proposal for a specific site be accompanied by a clear and unequivocal statement of the results of the test of sustainability and that only developments where the assessment shows a clear positive result in respect of sustainability are approved. Furthermore we would request that each site is tested against the sustainability test developed for a 'new' settlement to allow a fair comparison of advantages and disadvantages.

We note that government policy is that 60% of the development should be on brown field sites and the balance on green field, the indications emerging from the Core Strategy document seem to have reversed the policy with the higher percentage on green field sites and the balance on brown field.

It would be better to create the employment park at Southend Airport, rather than use land to the south of London Road, Rayleigh.

However, if an employment park is created south of London Road, it should not be any larger than the existing Rawreth Lane Industrial Estate which the planning authority proposes using for future housing allocation.

I would object strenuously to any land currently allocated as public open space in the Rochford District Local Plan being used to create an employment park in this location.

As the London Road is one of the primary approaches into the town of Rayleigh, the appearance of any employment park should not detract from the experience of entering Rayleigh - the design of any industrial/commercial buildings would be important in this respect. A procession of ugly warehouse type buildings along the London Road would be totally unacceptable. Landscaping should be generous. The proposed new housing to the north of London Road would be adversely affected by the creation of an employment park on the south side of the road.

POLICY ED4 OBJECTION

Lubards Lodge Farm Mixed Employment and Residential Development Option

1. We object to the exclusion of the land to the north of Rayleigh, at Lubbards Lodge Farm, from policy ED4. Whirledge & Nott made a call for sites submission for this site on behalf of the owners, Messrs Pinkerton. This representation relates to the same area of land.

2. Lubards Lodge Farm, extending to about 40 hectares overall, provides an excellent
opportunity to create a sustainable urban extension by building a mixed and integrated
development providing housing, employment, leisure and community facilities, whilst reinforcing a strategic undeveloped gap to ensure the permanent separation of Rayleigh and Hullbridge.

3. Development north of Rayleigh would be the least damaging option for the town in landscape impact terms. The land south of London Road, Rayleigh is highly visible from the A1245 and A127, whereas the land at Lubards Lodge Farm, which dips sharply northwards from Rawreth Lane, is not visible from major roads.

4. A legal undertaking would be offered to ensure that about 16 hectares of land towards
the northern end of Lubards Lodge Farm were reserved in perpetuity partly for open leisure uses and partly for extensive woodland planting. This, together with the existing golf course to the east of Hullbridge Road, would provide a very effective landscaped buffer between the two settlements ensuring their permanent separation in accordance with the aims of Green Belt policy.

5. Lubards Lodge Farm contains an existing vibrant employment area of 3.5 hectares on
a rectangular site on the western side of Hullbridge Road, about 450m north of its
junction with Rawreth Lane. This site presently consists of a large number of former farm
buildings of various shapes and sizes and has gradually become established over the years as an important reservoir of premises for local start up businesses. Before releasing green field land for employment development the potential for redevelopment and new development within the confines of the existing Lubards Lodge Farm employment site should be realised. This would have the following advantages:-

• Existing relatively unattractive buildings could be adapted or redeveloped to improve the appearance of the site.

• Established businesses would have greater potential for expansion on their existing
sites.

• New buildings could be constructed on existing underused but previously developed land within the framework of the existing employment area.

6. The existing employment area could accommodate part of the employment growth
identified in policy ED2 and could also provide the anchor for an expanded employment
area to the south, which could accommodate the balance of the estimated employment
growth requirement.

7. This would create an Employment Park superior to the current preferred option south
of London Road, Rayleigh as it would be closely integrated with the existing employment
area to the north and with the proposed housing development occupying the fields to the
west and south up to Rawreth Lane. These fields have an area of about 18 hectares, capable of accommodating 540 dwellings at 30 dph. The appropriate balance between employment and housing land could be debated, but this option offers the potential to integrate new employment with new housing effectively to create a genuinely sustainable community, unlike the distinct housing and employment site options being considered west of Rayleigh.

8. In transport terms the site would be 1.5kms from Rayleigh station and could be integrated into the town's public transport network. New footpath and cycle routes would be developed, not only within the urban extension, but also linking across Rawreth Lane and Hullbridge Road into the existing urban area, by tunnel or bridge or both. These new links would have the added benefit of bringing the open countryside to the north, especially the area of open leisure uses suggested as part of this proposal, within easier
reach of the existing resident population of Rayleigh. Some upgrading of the junctions of
Rawreth Lane/ Hullbridge Road and Rawreth Lane/A1245 would be desirable and could
be funded from these proposals.

I believe the moving of the Rawreth Industrial Estate and, possibly the Imperial Park Industrial Estate to, vaguely "South of London Road" is totally inappropriate. There is a site next to the A127, along the A1245 - Michelin Farm - which is currently under an Enforcement Order, which would provide excellent links to the A127 and A130 and which would be much more suitable for an industrial estate. There is already one along the A127 in the immediate area.

Essex Chambers of Commerce supports this preferred option as it provides opportunities for better quality business premises much closer to the A13/A127/A130, whilst creating housing development opportunities on current poorly positioned employment estates.

LDF Core Strategy Preferred Options

Response On Behalf Of Rayleigh Town Council

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

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

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

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

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

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

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

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

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

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

This statement must be made more prescriptive.

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

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

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

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

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

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

(7) Page 57 ENV4 Sustainable drainage systems

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

This section needs to be far more robust

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

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

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

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

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

At last the voice of reason and common sense!!

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

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

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

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

Comments from the FSB SE Essex Branch Vice Chairman.

Due to the lack of a sustainable road transport infrastructure in the district, the need to ensure that each centre of population has a concentration of suitable commercial premises to enable local employment to succeed. This could be attained by the careful introduction of commercial centres within the community. Better utilization of existing building and out buildings, farm and redundant properties which would lead to local employment possibilities. Local mini business centres could mushroom with the right type and size of accommodation for starter companies. There would be a need for various types of business accommodation as not all businesses will be in the high tech category. This could lead to growth areas being formed which could lead onto larger estates sited in the west of the district.

There is a common belief that we need to embrace high tech industries. The presented base information indicates not only are we an area of small and ultra small businesses there is a vast diversity of trades of which many are service based.

With the recently announced purchaser of the Airport the potential development based on other locations, leans to the possibility of large warehousing and transport based industry. This, though it will bring employment to the area, will only bring a certain type of employment and the need to have a better scatter of types of businesses in the location possibly has been missed. There will now be an urgent need to upgrade the road and rail infrastructure to cope with the increase in goods movement. The demise of yet another air support company may in turn mean a problem for growth in the form of commercial air travel, thus aircraft based industries must not be relied upon as the answer to future employment. The need to open the immediate area to low tech industries and small and micro small businesses is paramount.

The presented vision of creating a business park for larger concerns in the west of the district, to release much needed housing allocation, is in the bases a reasonable solution. Large transporters would not have to negotiate the restricted road infrastructure of the district. Though we have existing large companies who are well established within the district, some who would have trouble relocating due to the type and size of their operation eg Baltic Wharf .

There also could be a counter argument in that due to the lack of road infrastructure, there may be a problem of access at peak times for staff. This is a common problem on our existing trading estates such as Purdies Estate Rochford. Also the need to move staff from one side of the district to the other will not help the already inadequate transport system. The positive is there is direct access to major road system. But there may be also a need to investigate if there is a need of an upgrade of the rail infrastructure, this is due to the inadequacy of the national road infrastructure of the future.

The three main retail centres are at this time having a real challenging time. Due to the restraints of public spending and the need to use car parking fees as a source of revenue does not make it easy for the high street retailers. As the district originated from market towns and we can't compete with the out of town shopping centres and large super markets, should we be. looking at returning to the small centres with convenience/service stores. With more "on street" drop by parking, maybe pedestrian walk ways areas. Smaller towns and villages to adopt a similar style of small retail outlets. New residential developments should be required as part of the development include "Corner Shop" type units. This not only forms a micro community but helps in retaining the "spend" within the district and the need not to have to travel to the major shopping areas for the basic essentials.

If the ideals of the tourism initiative are implanted into the district, the need for more cheap but adequate accommodation within the newly developed countryside, eg Wild Coast at Wallasea, Jubilee Park at Hawkwell. There will be a need to change planning policy to accept this type of development. Yet there must also be suitable hotel accommodation in the west of the district to cover the proposed new industrial area.

There are concerns that the Core Strategy does not cover the future of the Roach and its tributies from the aspect of the existing users of the river. There seems to be scant regard to the illegal waterside development in the area, House boats, live a board's, waterside constructions. Following the latest Appeal Decision at Pagelsham Boatyard is the now a need to look again at a coherent policy on House boats/ Live Aboard Craft on the rivers.

The lack of access by the public to the riverside both on the Roach and the Crouch. There is a great need to open up such public access to the rivers as we only have one point at Hullbridge which is not designated as a slipway but a road end.

The proposed increase in commercial boat yards/ Marina's is not matched by the decrease in river traffic and boats in the rivers. The CHA report a marked drop in mooring take up, to gain better access to the water will mean negotiations with bordering land owners. The problem as always will be controlled access and costs.

In reflection and in reading the document again after composing the contents of this reply I note many of the points raised have been covered or partially discussed in the LGF (October revision) document.

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.

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.

Regarding the Core Strategy Preferred Options document, I would to make my opinions known concerning several points mentioned in the document and I refer to a few additional suggestions from me in general.

I am strongly against the construction of new areas of housing in Rochford District. We have already seen a very great number of developments in Rochford, Rayleigh and in the 14 or so villages in the RDC over many years.

I am strongly against the construction of new industrial estates in most of Rochford District. We already have several in the RDC area and within most, there are some vacant properties and a few areas for expansion within them.

I am strongly against the construction of new major roads in Rochford District.

I am in favour of developing Southend Airport and its passenger terminals, new railway station, freight facilities, engineering and industrial areas.

I am fully in favour of the work done by RDC in the expansion of recreational, leisure and wildlife areas, such as the many woods and the Cherry Orchard Country Park.

I am prepared to accept incremental expansion of existing areas, mainly in or very close to the urban areas.

I am strongly against the further expansion of any of the villages in the RDC area. The villages are already over-developed, over-crowded and in many cases spoilt by what has been built in the past.

I am against the considerable expansion of housing and population in our District. If we were in the middle of the country with a full 360 degrees of surrounding areas and a "hub and spoke" star pattern of routes, population areas, directions, destinations, routes of escape and scope for access and expansion, it might be a different matter. But, we do not have that geography.

With Rochford located where it is - nestled or trapped hard up against the sea in the east and surrounded and enclosed north and south by two major rivers - The Thames and The Crouch and enclosed by the ribbon urban expanse of Southend-on-Sea Borough along The Thames, it is impossible to fit in any more routes or infrastructure. Apart from heading west along completely inadequate and insufficient roads - much of which we have to share with the very populous Southend-on-Sea Borough population - there is nowhere else to go to get in or out. It is a narrow one way approach.

With the infrastructure that we have and the limited space within our District, there is simply no room nor scope for more than a small amount of expansion.

The existing population in the RDC is too high for the roads that we have.

I must add to that the much higher population of Southend-on-Sea Borough competes with us for the same scarce and inadequate resources.

There are no relief roads and no room for any of any significance to be built. I and many people whom I know would protest very strongly against the very suggestion of brand new highways built on green fields.

There is no choice of alternative routes for when congestion is bad or when it will get worse, nor for a theoretical higher population.

one of the problems that we will encounter with new housing in our area is the strain to be felt on roads and traffic, public services, schools, doctors and much more needed for larger populations. We must remember that: For every 1000 houses, we can expect in excess of 2000 more cars on the roads for the residents plus more for visitors and deliveries. For every 1000 houses we can expect in excess of 2500 more people. For every 1000 houses we can expect at least 1000 more school children. For every 1000 houses we will need some more doctors' services.

I am strongly against the growth in traffic calming measures and road layout changes. They are called "traffic calming". But, they are anything but calming, they are antagonizing, irritating, inefficient and in many cases - absolutely dangerous. I fear that with a significant growth in housing and traffic, there is going to be the desire to interfere with road layouts and architecture. In my experience from observations locally, regionally and nationwide, road narrowing, pinch points, road-centre islands, tarmac projections to deviate the path of traffic and many similar types of traffic manipulation result in traffic momentarily delayed and sometimes considerably delayed. The result of that is that traffic having been held up, sppeds away at a speed far in excess of what it would have done if progress had not been impeded. Traffic which approaches pinch points has to pass oncoming traffic much too close to the centre of the road and too close to other vehicles with a closing speed of 60 miles per hour (or more) being the 30mph limit times two. Traffic approaching islands which block one lane with priority in the other direction causes traffic to speed up before they reach the obstruction - to avoid getting held up if they arrived more slowly. Then having rushed through the obstruction, it is a while before they can reduce speed. Road centre islands are a death-trap for cyclists and horse riders which leaves them and the traffic with nowhere to go when a motorist comes upon an island without seeing them until too late. The cycling and riding community are fully aware that the authorities are using them and their fragile bodies as part of the traffic calming obstacles and measures.

Quite frankly, I am against any more development. I understand that there has to be some new houses and services. I would not block all of it, but it has to be limited, delayed and phased in a progressive, slow and sustainable way.

If it is the central government which is demanding new development, then it our duty as citizens and local authorities to object and if need be refuse to accept the development where it is not sustainable, or not wanted. Central government like any type of government has to remember that they are not our bosses who can push us around. On the contrary, we are their bosses and they are our servants, and they should do as we - the voting public tell them to do, or as we tell them not to do.

I feel very strongly about all of these points and if it is of any interest, I am expressing the same or similar views of many people who have told me about such points, just as I have listed in my letter above.

I look forward to hearing from you.

REPRESENTATIONS TO CORE STRATEGY PREFERRED OPTIONS DPD (OCTOBER 2008)

Iceni Projects Ltd (Iceni) has been instructed by Colonnade Land LLP (Colonnade) to submit
representations in respect of the Rochford Local Development Framework Core Strategy Preferred Options Development Plan Document (DPD).

a) Background

Colonnade is a strategic land company with a particular interest in the future development of the District as a consequence of a number of sites that it controls, particularly around Rochford. The representations set out below respond principally to the Housing and Employment chapters of the DPD, but do also take in other issues.

b) East of England Plan Review

You will be aware that representations have been made by Colonnade to the EERA Call for Proposals consultation, which closed in October 2008. The consultation forms an early part of the comprehensive long term review of the East of England Plan, which will address the growth strategy for the East of England Region, to include Rochford District, to 2031. Any associated changes to Rochford's growth strategy triggered by the East of England Plan Review will as a necessity, require a subsequent review to Rochford's Core Strategy, but as a consequence, are not matters that the current Core Strategy needs to directly contemplate.

c) Overview

Iceni consider the Core Strategy Preferred Options DPD to be a balanced, responsible, and legible document. Whilst we inevitably make observations, and in places objections, these are issued with the intention of improving the Core Strategy, and to ensuring that the DPD is both sound and responsive to future changes.

The downside to delivering a succinct document is that much of the material that is presented in the evidence base is left out of the Core Strategy DPD. Iceni believe that further cross referencing must be made in order to ensure the recommendations suggested within the evidence base are carried through.

For example, the employment policy should reflect and cross-reference the Employment Land Study 2008 recommendations.

As a general comment, Colonnade believes that the Core Strategy could place a greater focus on promoting Rochford as the principal settlement within the District. In the longer term, London Southend Airport has the potential to become a key catalyst for employment growth in the town. Such an opportunity warrants
identifying Rochford as the most logical and sustainable location for associated growth, not only in terms of housing, but also retail, community and education facilities. Coupled with the planned delivery of the new London Southend Airport Railway Station and the opportunity to connect with South Essex Rapid Transit (SERT), Rochford has the obvious credentials to function as the principal settlement within the District.

d) Site-Specific Interest

i) Residential

Your Authority will be familiar with Colonnade's interest in Coombes Farm, which it has previously registered through the LDF Call for Sites exercise. In our opinion, Coombes Farm is the most logical location for residential development abutting the urban area of Rochford. Coombes Farm has the ability to
direct pedestrians and cyclists through the town centre, to the benefit of existing retail and service
businesses, which will benefit from through-trade. Our representations accordingly reflect this opinion.

The site warrants recognition through the Core Strategy as a general location for residential development. At a more local scale, Colonnade is also pursuing the allocation of land adjacent to Little Wakering Road, which abuts the existing urban area and an existing playspace, and presents an excellent opportunity for a
focussed residential development in the rural area, which in particular, can deliver affordable housing. It is anticipated that the Site Allocations DPD will provide a more appropriate forum to advance these proposals, as well as reaffirming the support for Coombes Farm.

ii) Employment

In addition to the above, Colonnade will look to pursue the allocation of Three Ashes Farm for employment purposes, which abuts the western boundary of the Purdeys Industrial Estate. The Employment Land Study 2008, recommended that Purdeys Industrial Estate is a 'fit for purpose industrial estate which should be maintained and, if possible, expanded'. Colonnade consider Three Ashes to be an excellent location for
localised employment growth in Rochford, in view of its proximity to existing businesses and residential properties, which will be further enhanced by the development of the planned London Southend Airport Railway Station. Colonnade note with interest the Core Strategy's aspirations for an Eco-Enterprise Centre, which could be incorporated within the site, and underpins Colonnade's aspirations to provide a high quality buffer between existing residential properties and the boundaries of Purdeys Industrial Estate.

e) Plan Representations

For the sake of clarity, the representations made are presented in the same order as the Core Strategy Preferred Options DPD.

i) Page 24: Distribution

We concur that it is not realistic to expect Rochford's housing allocation to be met mainly on Brownfield sites, and support the aim of delivering 30% of development on previously developed sites.

ii) Policy H1- Housing Distribution

The policy objective of resisting intensification of smaller sites in residential areas is supported, both in terms of the stated intention of protecting the special character of existing settlements, and ensuring that the District's housing programme is not dominated by the development of flatted developments, which
typically provide an oversupply of one and two bedroom properties. Furthermore, this approach accords with the general thrust of the guidance within PPS3 which confirms that allowance for windfall sites should not be included in the calculation of the first 10 years of housing land supply.

Whilst the general principle of directing housing development towards previously developed land is accepted, deliverability of identified sites must be carefully monitored. This is particularly important in the current market as many of the sites identified as previously developed land will not be viable for development and will therefore not come forward within the first five years of the Core Strategy. The policy should be sufficiently flexible to allow for additional sites to be brought forward in order to demonstrate the
continuous delivery of a five year housing land supply.

iii) Page 26: General Locations

Colonnade concur with the general principle of the settlement hierarchy, albeit would reaffirm its view that Rochford has the potential to stand above all other settlements due to its proximity to London Southend Airport. The Airport, along with London Gateway, is one of the two most significant employment opportunities within the Essex Thames Gateway. The Core Strategy should more specifically acknolwdge this opportunity, and reflect this in its approach to all policies and objectives.

iv) Policy H2: General Locations and Phasing - Preferred Option

Policy H2 provides for the development of 1,450 dwellings by 2015. The concluding paragraph on page 27 implies a start date of 2006, with reference to an annual delivery rate of 261.7 units over the period 2006-2015 (which in turn, represents a notional target of 2,617 for the ten year period). Allowing for the sites identified in Policy H2, this would imply a continuing requirement for 1,167 units to be brought forward from previously developed land. In contrast, the second paragraph under Distribution (on page 24) indicates an anticipated delivery of 805 units by 2015. Iceni would suggest that this issue deserves clarification. Subtracting the anticipated urban capacity and the identified H2 sites from the ten year delivery target suggests a shortfall of 362 units. In view of the guidance provided by PPS3 it is important that the Core Strategy is not perceived as placing a continuing reliance on windfall sites. Should this be the case, the
Core Strategy should look to identify additional land to meet its housing target under Policy H2.

In respect of the general areas identified for the delivery of housing, it is recognised that the detailed location and quantum of development will be articulated within the Allocations DPD. However, without providing any notional site areas, development density, or land take of associated facilities (such as those listed within H Appendix 1) it is difficult to quantify how likely it is that these site will be capable of meeting
the District's housing target. Iceni would suggest that this information needs to be incorporated within further iterations of the Core Strategy.

Regarding the relative strengths of the housing areas, at this juncture, Colonnade is content to focus on the merits of promoting Coombes Farm (or East Rochford) as a suitable location for residential development rather than criticising those areas identifed, for two principal reasons: firstly, areas rather than sites are listed, and consequently, it would be inappropriate to pass judgement until greater information is known of
actual sites, their size, potential constraints, and so on. Secondly, in advance of clarification on the above issue (in respect of windfall sites) it is possible that there will be a requirement to incorporate additional areas for residential development in any event.

The above notwithstanding, in Iceni's opinion, it is evident that there are compelling grounds for identifying Coombes Farm (within an East Rochford area designation) under Policy H2, and that in particular, it should be recorded as a priority location for helping to meet the District's five year housing land supply. The site is
located adjacent to the existing urban area, the River Roach acts as a defensible boundary to avoid coalescence with Southend, and it provides an opportunity to promote a sustainable residential development in close proximity to both Rochford Town Centre and Rochford Railway Station. Colonnade has conducted a detailed site analysis and is in the process of preparing an evidence base to a sufficiently detailed standard to underpin a planning application. Colonnade's emerging development proposals avoid the use for residential purposes of any land at risk of flooding, land within the existing (or future) public safety zone of London Southend Airport, or any other constrained land. A highly qualified consultant team have been appointed, including John Thompson Architects and Buro Happold engineers, who have deduced that the site is capable of accommodating circa 300 houses, the majority of which would be provided as family accommodation, as well as satisfying the District Council's affordable housing objectives.
Moreover, and despite the criticism provided within H2-Alternative Options, the proposals can be progressed without detrimental impact on congestion levels through Rochford Town Centre. Indeed, the site's proximity to Rochford Town centre is a virtue, as all other potential areas for development in Rochford/Ashingdon would bypass the town centre entirely. As a final point, it remains to be seen whether other landowners and developers will be prepared to proceed with a planning application and commit to implementation of any planning permission in the present economic climate. Colonnade in contrast is fully committed to Coombes Farm.

v) Policy H3 - General Locations Post 2021

Colonnade welcomes the fact that the Core Stratey correctly responds to the requirements of PPS3 in identifying broad locations for the delivery of a fifteen year housing land supply. In keeping with representations on H2, it remains to be seen whether the areas identified are sufficiently robust to meet the District's longer term housing requirements, because at this stage, there is insufficient information to
comment. In so far as Colonnade would anticipate Coombes Farm being fully delivered well in advance of 2021, the Company has no significant observations to make at this stage on the proposed policy.

vi) H4- Affordable Housing

Colonnade supports the proposed affordable housing target of 35%, albeit the actual percentage and tenure split is more appropriately determined at a planning application stage. It is likely that only Greenfield housing sites will be capable of meeting this target, as Rochford historically, and Brownfield sites generally, have consistently failed to meet affordable housing targets, as reflected in the critical under supply of affordable housing identified by the Thames Gateway South Essex Strategic Housing Market Assessment. Between
2001 and 2007, Rochford have only delivered 8% of their total housing stock for affordable dwellings, presenting a shortfall of 1,338 affordable units over the Plan Period to the end of 2007. The inability of sites to typically deliver more than 35% affordable justifies an over provision of housing sites to deliver a greater
quantum of affordable housing and housing as a whole.

Colonnade would also recommend that the Core Strategy specifically enables 100% affordable housing schemes to be brought forward on unallocated sites, potentially as rural exception proposals.

vii) H5- Dwelling Types

Colonnade welcomes the emphasis placed in the Core Strategy on delivering a mix of dwelling types, whilst making specific reference to the provision of family and affordable housing. Colonnade supports the promotion of Rochford District as a location for housing rather than flatted developments.

viii) H Appendix 1

There is concern that the table in H Appendix 1 fails to provide the necessary justification for the proposed improvements in infrastructure. Whilst the preamble seeks to clarify why the infrastructure is sought, the inclusion of this list should be fully justified, otherwise it is of little value. Furthermore, it would be of benefit to provide further details of the existing community infrastructure provision and capacity within the evidence base.

For the avoidance of doubt, Colonnade would welcome similar information being provided as a caveat for the allocation of Coombes Farm. Colonnade is fully committed to delivering infrastructure and community improvements, and for Coombes Farm to properly address the needs of future and existing residents.

ix) Proposed Policy GB3

Colonnade would promote the inclusion of an affordable housing exception policy within the Core Strategy, which will particularly aid the delivery of community housing within rural areas. Passing land values will typically preclude such developments on Brownfield sites. However, the limited and justified release of small
parcels of Green Belt land would fundameltally enhance the viability of 100% affordable schemes without setting a precedent for open market housing developments.

x) ED1- London Southend Airport

Colonnade supports the identification of London Southend Airport in providing a significant role for the economic development of the District, not only within the confines of the development location and Airport uses only, but also through the expansion of other employment uses in nearby locations. The policy does not provide any indication of the number of jobs it will provide within the Plan period through the
redevelopment/extension of the Airport. The supporting text explains that there is pportunity for economic development around the Airport that is not necessarily linked, but it does not commit to the amount of employment land that might be appropriate and where this should be ideally located.

Three Ashes is located adjacent to the existing Purdeys Industrial Estate and is located close to Southend Airport. As discussed above, the site is an opportunity to provide employment land in the short-term which can cater for 'spin off' Airport uses, or for more general employment purposes adjacent to the existing Industrial Estate. The Three Ashes site would be further justified by its close proximity to the planned
London Southend Airport Railway Station.

xi) ED2- Employment Growth

Colonnade agrees that Rochford's economy must diversify and modernise through the growth of existing businesses and through the creation of new enterprises. Whilst the general principle of encouraging growth of existing businesses is accepted, further employment growth is likely to be necessary, as identified within the Employment Study 2008.

The policies of the Green Belt chapter should reflect the requirement for Green Belt releases and in accordance with policy 2.12 of PPG2, consideration should be given to the identification of additional safeguarded land to meet employment and job targets to allow flexibility and ensure Green Belt policies do
not put employment delivery at risk.

xii) ED4- Future Employment Allocations

The policy indicates that only one new location for employment should be carried forward, located on land to the South of London Road, Rayleigh, and otherwise relies solely on the Airport to deliver the required employment land within the District. The level of employment to come forward from the Airport is likely to be
delivered towards the end of the Plan period and beyond, and therefore presents further employment land to be identified.

Three Ashes Farm provides an excellent opportunity to deliver employment growth in the short term. The Employment Land Study 2008 stated that Purdeys Industrial Estate is fit for purpose, and recommended that if possible, the Industrial Estate is expanded. Three Ashes could deliver this outcome, providing a natural extension to Purdeys Industrial Estate and being strategically located close to the Airport. Three
Ashes would address the negative impacts that the nearby residential area experiences from the existing Industrial Estate by providing a buffer between established uses and the residential area with less intensive employment activities. The highways analysis that has been carried out has suggested that it would not have an adverse impact on roads and congestion. Furthermore, there are very few opportunities for businesses to expand and Three Ashes could provide this opportunity.

The evidence base presented within the Urban Capacity Report 2007, suggests that it is likely that a significant amount of employment land will be taken up for residential development. This puts further pressure on the demand for employment opportunities within the District. The potential loss of employment sites would trigger the need for a further allocation of employment land. The policy should be flexible
enough to allow for other areas to be considered to meet the minimum job target set by the EEP.

Cross-referencing to the Employment Land Study should be provided within this chapter in order to demonstrate that more information has been issued on the consideration of general locations for employment land.

xiii) ENV5- Eco-Enterprise Centre

Colonnade support Rochford's aim of securing an Eco-Enterprise Centre within the District and consider Three Ashes to be an excellent location. This would provide a high-quality employment development that may also incorporate uses associated with the Airport. The site would further justify its sustainability benefits
by being located within close proximity to the London Southend Airport Railway Station and Rochford Town Centre.

xiv) ENV8- Code for Sustainable Homes

In seeking to go above and beyond the policy targets set out by Central Government, which propose zero carbon (i.e. Code 6) by 2019, the proposed policy does not set achievable targets for developers. The proposed imposition of stricter targets will have a potentially negative impact on housing delivery after 2010.

This is exemplified by the findings of the recent Communities and Local Government report entitled 'The Cost Analysis of the Code for Sustainable Homes' (July 2008) which confirms that costs for achieving the Code 6 would increase between 41% and 52% of the cost for meeting 2006 Building Regulations per unit
(detached). These additional costs would further impact upon the viability of housing schemes and thereby reducing housing delivery.

Accordingly, Iceni would suggest that rather than identifying specific targets, a generic policy should be incorporated confirming that housing development should accord with Central Government targets for the Code for Sustainable Homes.

xv) T1/T2 Highways and Public Transport

Colonnade supports the principle of improving public transport provision and reducing reliance on the private car. However, it is to be noted that the Core Strategy provides no information on how surface access improvements are to be delivered to London Southend Airport, which is a fundamental caveat for the growth of the Airport, and therefore the District's employment strategy. Equally, the policy provides no information on the planned development of a London Southend Airport Railway Station. Notwithstanding the planned programme off a Joint Area Action Plan with Southend-on-Sea Borough Council, the transport and
infrastructure implications of the Airport deserve further scrutiny within the Core Strategy.

xvi) T7- Parking Standards

The guidance in PPG13 is clear regarding the imposition of parking standards. Paragraphs 52-56 of PPG13 confirm that the Local Planning Authorities should apply maximum not minimum parking standards. Such a clear dismissal of adopted Central Government policy guidance is undermining the Strategy. Policy must reflect PPG13 to promote sustainable transport choices and further provide incentives for developers to
locate further residential land closer to local service centres by requiring maximum parking standards for residential developments.

xvii) CP1- Design

The Council should not seek to impose further demands on developers where existing regulations provide sufficient requirements regarding design. In this instance, Design and Access Statements provide sufficient design guidelines for developments.

xviii) Planning Obligations and Standard Charges

The principle of providing for planning gain associated with new development proposals is widely accepted. However, there needs to be a careful balance struck to ensure planning gain does not place undue burdens on developers, particularly in difficult market conditions. There is considerable risk that the imposition of high tariffs will mean that development will not come forward, further reducing affordable housing delivery and planning gain as a whole. The policy should refer to guidance contained within a Supplementary Planning Document (SPD) and should allow for flexibility to acknowledge reasonable negotiation on s106 agreements to ensure development proposals continue to come forward thereby contributing to
deliverability, whilst allowing realistic reductions for marginal schemes.

The supporting text to Policy CLT4 refers to the potential requirement to undertake a Health Impact Assessment. However, it fails to confirm what information should be contained within Health Impact Assessments and as such, further clarification of what is involved in the assessment and the expected outputs should be provided as it is not made available in the Core Strategy Preferred Options consultation document.

Colonnade Land LLP welcomes the opportunity to be an active stakeholder in the consultation process for developing the standard formula for Planning Obligations and formally requests that an invitation is extended by Rochford District Council.

Conclusion

Iceni Projects, on behalf of Colonnade Land LLP trust that the Council will find these representations to be constructive and helpful in taking forward the Core Strategy. Should you wish to discuss any aspect of these representations further, please do not hesitate to contact me.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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