T7 Parking Standards - Preferred Option

Restricting parking standards in residential developments does not appear to affect the number of cars owned. They are parked on the street or in any open space.
Near to railway stations there are always a large number of parked cars belonging to people from outside the district who cannot or will not use the railway car parks. This clogs up the streets, making it difficult and dangerous for local people.
This parking should be banned, usually by banning parking at certain hours such as 10 to 11am which makes it impossible for commuters. If this were done, it would be necessary to provide better public transport from areas such as Ashingdon which do not have a railway connection.
Many people do not shop locally because they have to pay for parking, when it is available. They would rather go to an out of town supermarket. This is reflected in the number of empty shops. If it is the intention of the Core Strategy to maintain the atmosphere of our town centres, this should be addressed by making short term parking free even if this means an increase in the council tax for residents. Of course, with more viable businesses in town centres, they would be able to pay more tax to offset the charges.

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.

Every development no matter how large or small should always be provided with adequate off street parking.

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))

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

1.0 Instructions and Introduction

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

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

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

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

Peter Kneen BSc (Hons) MSc MRTPI
Planner

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

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

2.0 Housing:

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

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

Policy H1 - Distribution

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

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

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

Policy H2 - General Locations and Phasing

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

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

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

Policy H3 - General Locations Post 2021

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

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

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

Policy H4 - Affordable Housing

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

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

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

Policy H5 - Dwelling Types

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

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

Policy H6 - Lifetime Homes

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

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

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

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

Policy GB2 - Rural Diversification and Recreational Uses

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

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

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

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

Policy ENV4 - Sustainable Drainage System (SUDS)

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

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

Policy ENV8 - Code for Sustainable Homes

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

5.0 Transport:

Policy T1 - Highways

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

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

Policy T2 - Public Transport

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

Policy T4 - Travel Plans

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

Policy T5 - Cycling and Walking

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

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

Policy T7 - Parking Standards

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

6.0 Character of Place:

Policy CP1 - Design

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

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

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

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

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

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

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

Policy CLT6 - Community Facilities

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

8.0 Summary:

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

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

Dear Sir / Madam,

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

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

Vision

The Council's key planning objectives include the following:

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

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

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

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

Housing

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

Distribution

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

Policy H1 - Distribution - Preferred Option

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

General Locations

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

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

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

Policy H2 - General Locations and Phasing - Preferred Option

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Affordable Housing

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

Policy H4 - Affordable Housing - Preferred Option

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

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

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

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

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

Lifetime Homes

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

Policy H6 - Lifetime Homes - Preferred Option

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

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

The Green Belt

Protection of the Green Belt

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

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

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

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

Policy GB1 - Green Belt Protection - Preferred Option

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

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

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

Transport

Parking Standards

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

Policy T7 - Parking Standards - Preferred Option

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

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

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

Open Space

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

Policy CLT5 - Open Space - Preferred Option

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

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

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

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

New forms of the above will be promoted.

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

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

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.

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.