ED5 - Eco-Enterprise Centre - Preferred Option

CPBC would encourage Rochford DC to prepare evidence that demonstrates the deliverability of the eco-enterprise centre. It is important to ensure that the Core Strategy is realistic and achievable.

The proposed Eco-Enterprise Centre is supported as a sensible solution for reducing the rate of business start-up failure in the district. But its very development is reliant upon external funding and the good will and capability of the local business community. In the current economic circumstances the viability of such projects needs to be carefully considered - much will depend on the current financial status of the project in terms of whether funding, even in principle, has yet been secured.

The location and function of the Eco-Enterprise Centre should be considered in the context of the wider area because there are a number of proposals for such facilities across South Essex. Key to the economic development of Rochford District will be an offer to businesses from the Centre that is clearly differentiated from that of competing centres so that best efforts are not diluted and maximum benefit may be derived for the future local economy.

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))

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.

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: Rochford District Council - Core Strategy Preferred Options

Thank you for consulting the Assembly on this matter.

The Regional Planning Panel Standing Committee considered the attached report at its meeting on 5th December 2008 and endorsed the following recommendation:

'Overall, the preferred options put forward in the Core Strategy respond well to the RSS. The Assembly does have some minor concerns but considers that these do not give rise to any major conformity issue'

Our detailed comments, which are set out in Appendix A of the attached report, constitute the Assembly's formal response to this consultation.

If you have any queries concerning the content of the report or any other issue relating to conformity with the Regional Spatial Strategy, please contact myself or James Cutting, Team Leader - Strategy & Implementation

Regional Planning Panel Standing Committee

5th December 2008

Subject: Rochford District Council's Core Strategy Preferred Options consultation document

Report by: Regional Secretariat

Purpose

To give a response to Rochford District Council's Core Strategy Preferred Options consultation document

Recommendation

The Standing Committee is asked to consider the recommendation that the comments in this report and those in Appendix A constitute the Assembly's formal response to Rochford's Core Strategy Preferred Options consultation document.

1. Introduction

1.1 Rochford District Council has published for consultation a revised version of its Core Strategy Preferred Options Development Plan Document. This is the second stage in the Local Development Framework (LDF) process and will, in due course, lead to a Submission Version. As the principle document in Rochford's LDF, the Core Strategy sets out the overall strategy for the district until 2021 and, where appropriate, beyond.

1.2 The Council consulted on an earlier version of its Core Strategy during June and July 2007 (see RPPSC 15 June 2007 - Item3). In submitting its response, the Assembly noted that whilst the document responded well to the then emerging East of England Plan there were issues with regards to affordable housing and major releases of land from the Green Belt.
1.3 The closing date for comments on this revised Core Strategy is 17th December 2008. Further details can be found on Rochford District Council's website.

1.4 A copy of the Core Strategy Key Diagram is included at Appendix B.

2. Background

2.1 Rochford District covers an area of approx. 168 sq. km's (65 sq. miles) and is situated within a peninsula between the Rivers Thames and Crouch. Bounded to the east by the North Sea, it shares land boundaries with Basildon and Castle Point District and Southend-on-Sea Borough Councils. It also has marine boundaries with Maldon and Chelmsford Districts. The A127 and the A13 provide a strategic road link to the M25 Motorway and there are direct rail links into London. London Southend Airport is also located within the district boundary.

2.2 The district has a noticeable east - west divide. The majority of the population, which recent estimates put at 81,300 (expected to rise to 87,000 by 2021), live in the west where the three main urban areas of Rochford, Rayleigh, Hockley are located. To the east, the district is more rural in nature, and is characterised by stretches of unspoilt coastline and countryside, with a scattering of smaller settlements. Approximately 75 per cent of the district is designated as Metropolitan Green Belt.

2.3 A significant proportion of the districts workforce (estimated to be around 68 per cent) work beyond the district boundary. Southend-on-Sea exerts a particularly strong influence, not just as an employment location but also as the largest retail centre in the sub-region. Beyond the three main urban areas of Rochford, Rayleigh and Hockley, which offer greater opportunities to access public transport, there is a high dependency on private car use.

3. Regional and Local Policy

3.1 Regional planning guidance for Rochford is contained within the adopted East of England Plan (hereafter referred to as the RSS) and the remaining six "saved" structure plan policies for Essex and Southend-on-Sea. At a local level, the Core Strategy and other LDF documents will replace the Rochford District Replacement Local Plan (2006).

3.2 In considering general conformity the Core Strategy was assessed against all policies contained within the RSS, with particular attention paid to policies relating to the Essex Thames Gateway (ETG1 - ETG5).

4. Comments

4.1 Overall, the preferred options put forward in the Core Strategy respond well to the RSS. There is recognition that growth needs to be delivered in a sustainable manner and evidence of continued joint working with neighbouring authorities, and the County Council, to ensure delivery of regionally significant schemes such as London Southend Airport and the South Essex Rapid Transit system.

4.2 The Assembly does have some minor concerns over the amount of development that is planned to come forward on previously developed land, and also on the Council's position with regards to larger scale renewable energy schemes. However, it considers that these do not give rise to any major conformity issue.

5. Recommendations

5.1 The Standing Committee is asked to consider the recommendation that this report and the comments in Appendix A constitute the Assembly's formal response to Rochford District Council's Core Strategy Preferred Options consultation document.


Appendix A
LOCAL DEVELOPMENT DOCUMENT CHECKLIST
PART TWO - GENERAL POINTS

Question - Does the area covered lie within the Eastern Region?
Answer - Yes


Question - Are all references to the East of England Plan correct?
Answer: - Yes

Question - Does the area covered include a Key Centre for Development and Change?
Answer - Yes
Comments - London Southend Airport is included within the Essex Thames Gateway policy area.

Question - Are there any key issues covered by the document that are of strategic or regional importance?
Answer - Yes
Comments - Expansion at London Southend Airport and the regeneration of the Thams Gateway are of regional importance.

PART THREE - CONSISTENCY/CONFORMITY CHECKLIST

Question - Is there a clear push for sustainable development?
RSS Policy - SS1
Local Policy - All
Comments - The overall objectives and policies seek to achieve a balance between bringing forward sufficient new growth to meet the needs of the district whilst protecting its natural and historic built environment. There is also clear recognition of the need to ensure that the necessary infrastructure is delivered in a timely and effective manner.

Question - Does policy seek to maximise the use of previously developed land (PDL), and will it contribute towards the 60% target?
RSS Policy - SS2
Local Policy - H1
Comments - (See also comments below relating to Green Belt.)
While local policy H1 supports prioritising the reuse of PDL, the findings of the Council's recent Urban Capacity Study (2007) and concerns over town cramming will mean that only some 30% of new housing development will come forward on PDL.
Although accepting that the 60% target may not be deliverable in all parts of the region, the Council is encouraged to maximise the development potential of all brownfield sites (including "windfall' sites) and, through its monitoring procedures, ensure that delivery does not fall below the proposed 30% level.

Question - Is there a clear pattern of development for 'Key Centres' or for other urban and rural areas?
RSS Policy - SS3, SS4
Local Policy - Various

Question - Is the role of city/town centres clear? Is there a clear retail hierarchy?
RSS Policy - SS6
Local Policy - RTC1 to RTC5
Comments - The influence of out-of-district shopping facilities; particularly those provided at Southend, is acknowledged. Local policy seeks to maintain and enhance the current market share of retail spending, with the focus for development centered on Hockley, Rayleigh and Rochford.

Question - If appropriate, is there a policy dealing with the Green Belt?
RSS Policy - SS7, ETG1
Local Policy - Page 4, GB1, GB2
Comments - RSS policy SS7 states that the broad extent of the Green Belt in the region is appropriate and should be retained. There are no plans for a Green Belt review around Rochford.

Whilst local policy seeks to protect the existing Green Belt, it does allow for some limited reallocation in order that built development can come forward. Where this release is considered to be unavoidable, the Core Strategy proposes that development occurs at a reasonably high density.

In accepting that some Green Belt land will be released, using that which contributes least to its main purpose seems appropriate. Either through this document or through relevant future documents, the Council should clarify what level of development constitutes a 'reasonably high density'.

Question - Is there a policy on coastal issues?
RSS Policy - SS9
Local Policy - ENV2
Comments - The biological/landscape value of the District's coastline is recognised.

Question - Is the East of England Plan employment target met?
RSS Policy - E1, ETG5
Local Policy - Econ' Dev' Chapter, ED1, ED2
Comments - The introductory paragraphs set out districts job requirement figure as quoted in RSS policy ETG5. There is acknowledgment of the important role that London Southend Airport can play in bringing forward employment and other economic development opportunities, as expressed through local policy ED1.

Question - Is employment land protected and is its designated use consistent with relevant RSS policies?
RSS Policy - E2 - E4
Local Policy - ED3, ED4, ED5

Question - Is the RSS housing target met? Is there a housing policy post 2021?
RSS Policy - H1
Local Policy - Housing Chapter H2, H3
Comments - The introductory section sets out district housing figures in line with RSS requirements. Local policies H2 & H3 relate to general distribution, including indicative housing numbers within settlement areas for the period to 2015, from 2015 to 2021, and post 2021.

Question - Is there an affordable housing policy and does it meet the RSS target?
RSS Policy - H2
Local Policy - H4, H5
Comments - The Preferred Option is consistent with the RSS target (35%) and national site size thresholds (15 or more dwellings). It is noted that local evidence shows the actual level of need is much higher, but that the Council is seeking to strikes a balance between deliverability of affordable housing and overall site viability.

Question - Is there a clear policy for meeting the accommodation needs of Gypsies and Travellers?
RSS Policy - H3
Local Policy - H7
Comments - Local policy H7, which states that provision will be made in line with recommendations set out in the RSS Single Issue Review, is welcomed. It is also noted that local authorities in Essex have expressed concerns over the RSS review process.
The Assembly encourages all local authorities to make provision in line with its recommendations to 2011 and beyond, noting that they will need to be mindful of any amendment to district pitch requirement figures as the RSS Single Issue Review is progressed.

Question - Are culture issues addressed?
RSS Policy - C1, C2
Local Policy - CLT6 - 11

Question - Is there a policy seeking to change travel behaviour? Is there a policy seeking to enhance provision for non-motorised forms of transport?
RSS Policy - T2, T9, T13 & T14
Local Policy - T1 - T6
Comments - The Core Strategy recognises that, away from the three main urban areas, there will continue to be a high dependency on private car use. Policies that encourage and bring forward the delivery of alternate and non-motorised forms of transport are supported.
Opportunities to facilitate home-working within new development proposals should not be ignored.

Question - Are any major transport generators covered by appropriate proposals?
RSS Policy - T11, T12
Local Policy - ED1
Comments - [The Council is referred to concerns raised by the Assembly during recent consultation on the JAAP Issues & Options consultation stage - see RPPSC 18 July 2008, Agenda item 4]

Question - Are any transport schemes being promoted that match regional priorities?
RSS Policy - T15
Local Policy - T3
Comments - Local policy T3 supports the implementation of the South Essex Rapid
Transport (SERT) scheme.

Question - Is there a policy dealing with green infrastructure?
RSS Policy - ENV1
Local Policy - ENV1, ENV2, T6

Question - Are landscape, wildlife and other conservation issues addressed?
RSS Policy - ENV2, ENV3
Local Policy - ENV1, ENV2, URV1, URV2

Question - Is agricultural land and soil conservation covered by a policy? Is there a policy relating to rural diversification?
RSS Policy - ENV4
Local Policy - GB2
Comments - The introductory paragraphs in the Environmental Issues chapter (pg 51) states that the Council will endeavour to ensure that the districts agricultural land will not be adversely affected. Local policy GB2 offers support for rural diversification schemes within the designated Green Belt.

Question - Are woodlands protected by a policy?
RSS Policy - ENV5
Local Policy - ENV1, URV1 (ENV6)
Comments - The Preferred Options seek to ensure that areas of ancient woodland are protected.

Question - Is the conservation/enhancement of the historic environment addressed?
RSS Policy - ENV6
Local Policy - CP2, CP3
Comments - The Council intends to reinstate a 'Local List' which will afford protection to local buildings with special architectural / historic value.

Question - Is there a policy that seeks to achieve a high quality built environment, including sustainable construction?
RSS Policy - ENV7
Local Policy - H6, ED5, ENV8, ENV9, CP1
Comments - Local policies ENV8 & ENV9 advocate the implementation of Code for Sustainable Homes (CSH) and BREEAM3 standards. It would be helpful if a timescale was included showing when the Council expects to implement the various code standards.

Question - Is there a policy dealing with the reduction of CO2 emissions? Is there a policy on renewable energy, including the setting of a target?
RSS Policy - ENG1, ENG2
Local Policy - ENV6, ENV7
Comments - The Core Strategy contains two policies on renewable energy - ENV6 and ENV7. While the Assembly is supportive of any policy that actively seeks to implement renewable energy technologies it is concerned that (i) as worded, policy ENV6 seemingly discourages any large scale scheme from coming forward and, (ii) that whilst local policy ENV7 is welcomed, difficulties may arise in measuring the effectiveness of small scale schemes and relating this back to regional and national targets.

Local policy ENV6 should be more 'proactive' by, for example, indicating which type of scheme(s) the Council would be wiling to support. The Assembly will be looking to the relevant Development Control documents to ensure that appropriate targets are set in line with regional targets.

Question - Is there a policy promoting water efficiency?
RSS Policy - WAT1
Local Policy - ENV8, ENV9
Comments - Water efficiency measures are being promoted through policies that adopt BREEAM and Code for Sustainable Homes (CSH) standards

Question - Is Flood Risk Management addressed? Are proposals to implement Sustainable Urban Drainage technologies included?
RSS Policy - WAT4
Local Policy - ENV2, ENV4

Question - Is there a policy dealing with waste management?
RSS Policy - WM1 - WM8
Local Policy - ENV8, ENV9
Comments - It is implied that domestic/commercial waste management practices will addressed through adoption of CSH and BREEAM Standards.

Question - Is there a policy that deals with implementation and monitoring?
RSS Policy - IMP1 - IMP2
Local Policy - Page 107 and Table

PART FOUR - OVERALL ASSESSMENT

Question - Is the document in general conformity with the RSS? If the answer is 'no', what is needed to rectify this?
Answer - Yes
Comments - Overall, the preferred options put forward in the Core Strategy respond well to the RSS. There is recognition that growth needs to be delivered in a sustainable manner and evidence of continued joint working with neighbouring authorities, and the County Council, to ensure delivery of regionally significant schemes such as London Southend Airport and the South Essex Rapid Transit system.

The Assembly does have some minor concerns over the amount of development that is planned to come forward on previously developed land, and also on the Council's position with regards to larger scale renewable energy schemes. However, it considers that these do not give rise to any major conformity issue.