RTC1 Retail - Preferred Option

Local retail should offer as much diversity as possible but any pretensions towards 'big store' capabilities are non-starters.

Hockley Town Centre Enhancement Plan is to be prepared. The HTCEP will have a major impact on Hockley, probably including extra houses. It is impossible to assess the combined impact of the Core Strategy and the HTCEP until both have been published.

town centres should be renovated not increased.

Thank you for consulting the Government Office on the Rochford District Council Local Development Framework Core Strategy Preferred Options Report.

As you are aware, we have commented in the past on earlier documents published in relation to the Rochford Core Strategy. In line with our earlier comments we consider that the document is well organised, comprehensive, set out in a systematic fashion and is easy to read and comprehend. The authority is to be commended for achieving this. We do though have some general comments and concerns as well as detailed observations that relate to many of the intended policies. These are set out in the paragraphs below.

Going forward under a revised PPS12

You will also be aware that on the 4th June this year CLG published a revised PPS12 along with revised regulations, which are now in place. The revisions are aimed mainly at streamlining the process further to help ensure that production of DPD's is able to happen as quickly as possible, whilst ensuring that public participation is effective and its results taken fully into account. As well as this, a key motivation of the revisions is to provide local planning authorities with greater freedom to determine the most appropriate way to prepare or revise DPD's. There is now more flexibility particularly in terms of consultation, where consultation on the DPD during the preparation phase of the plan is expected to be proportionate to the scale of the issues involved in the plan. On this basis, the regulations have now removed one of the formal stages of consultation - the preferred option stage. As well as this, the regulations now require that consultation and representations are made on a DPD before submission to the Secretary of State.

You should refer to the new PPS in taking forward this DPD, but essentially you will need to comply with the following principles in the PPS on:

• Participation and stakeholders (see section 4.20, 4.25 & 4.27);
• Not repeating national and regional policy (4.30);
• Being subject to a sustainability appraisal (4.39 - 4.42);
• Being justified, effective and consistent with national policy (4.36 & 4.44) and
• Being produced according to the timetable set out in the LDS to ensure that the DPD is produced in a timely and efficient manner (see section 4.53 & 4.54)

Further guidance, including examples of best practice, is provided in the Plan Making Manual, which may be accessed via the Planning Advisory Service's website: www.pas.gov.uk/planmakingmanual. Additional content will become available in further updates of the Manual.

The DPD must be prepared in accordance with the Local Development Scheme and in compliance with the Statement of Community Involvement and the Town and Country Planning (Local Development) (England) Regulations 2004 as amended, be subject to a sustainability appraisal, have regard to national policy and any sustainable community strategy for the area and conform to the RSS. To be sound, the DPD should be justified (founded on a robust and credible evidence base, and be the most appropriate strategy when considered against the reasonable alternatives), effective (the document must be deliverable, flexible and be able to be monitored) and consistent with national policy.

The key consideration before drafting the final DPD, is to be satisfied that the process of testing and refining of the options and consulting with key stakeholders has been undertaken adequately and satisfactorily in an appropriate and proportionate manner in relation to the issues arising in respect of this particular DPD.

Presentation of Options

There will be an expectation when the Core Strategy is submitted for examination, that the Council is able to demonstrate that it's decisions for deciding on certain options and ruling out others has been underpinned and informed by a robust Sustainability Appraisal (SA). I am surprised that there are not many references to the SA in the main text of the Core Strategy preferred options document, especially in the context of the presentation of options. It is not explicitly evident from reading the Core Strategy document, that the findings in the SA report support the Authority's preferred options and how decisions about the spatial strategy have been reached.

At submission, the Authority will need to be able to demonstrate that the DPD's policies represent the most appropriate response in all the circumstances, having considered all the relevant alternatives, and that they are founded on a robust and credible evidence base; and that all reasonable and deliverable options have been equally presented at the Issues and Options stage, all underpinned by relevant sustainability information and other evidence. In order to meet this requirement, we firmly recommend that the subsequent documents make explicit linkages between the SA process and the decisions on chosen options and disregarded options.

Habitats Directive

As a result of the recent European Court of Justice ruling in relation to the Habitats Directive, Local Planning Authorities are now required to assess whether an Appropriate Assessment (AA), the purpose of which is to assess the impacts of a land-use plan against the conservation objectives of a European Site and to ascertain whether it would adversely affect the integrity of that site, is necessary and to carry out the AA in the preparation of a DPD or SPD where it is required.

Replacement of Local Plan Policies

It is a regulatory requirement for the Council to identify which extant saved local plan policies will be replaced/superseded by the Core Strategy upon its adoption. We would suggest that any early consultation documents should give a broad indication of the extant policy areas likely to be replaced and the submission Core Strategy document to include this information in detail, perhaps as an appendix.

Consultation Statement

We remind you that when you submit the relevant DPD, you will be required to provide a statement setting out which bodies were consulted at earlier regulated stages, how they were consulted, and a summary of the main issues raised and how these have been addressed. It is important therefore that you document clearly the consultation that you are undertaking now, and in the future, to inform this requirement.

Specific Comments on the Rochford District Council Local Development Framework Core Strategy Preferred Options Document

• It might be helpful in the introductory paragraphs of your eventual Submission document to explain in slightly more detail, what has preceded the stage you have now reached (i.e. the earlier stages) in terms of the evolution of your Core Strategy, particularly in relation to the chronology and 'frontloading' (statutory consultees/stakeholders) including public engagement.
• You might like to consider whether in your Submission document you should distinguish what is in effect your 'Spatial Portrait' (i.e. term it as such) from the other information that forms the 'Characteristics, Issues and Opportunities' in the introductory section.
• On page 14 under population, I think you are suggesting that the average household size in Rochford is a function of the relatively large number of families which is a feature of the District's population structure. The way you have expressed it appears to be somewhat ambiguous to me and this section of text may therefore benefit from being expressed in a way that is simpler and provides for clarity.
• Under the section entitled 'Vision', the text referring to the latter seems to be based more upon the separate document 'Vision to Reality' that is referred to. In addition, the initial Vision Statement that is then set out as text amounts to little more than a 'Statement of Intent'. The way I feel the Vision should be expressed is in fact much like the way you have expressed it in text boxes at the start of each theme- based section that follows in the document. This is an unconventional way of handling the matter and consequently you will need to be satisfied that it is an appropriate method. Clearly though, I feel that the linkage between the section entitled 'Vision' and what is written subsequently in the initial text and later in the text boxes, is inconsistent and at present confusing (the Vision and the Objectives that follow from it, should set the scene for the Core Strategy policies and proposals, particularly in terms of time scales (which you do outline) local distinctiveness, the scale of development intended and its broad locations).
• The objectives as currently expressed are very general and not distinctive or 'spatially specific' to Rochford.
• Policy H1 - The spatial dimension to this policy is in fact provided by Policy H2 and therefore there should be a cross reference in the text of Policy H1 to provide this linkage.
• Some of the text boxes are clearly making reference in 'plain English/general terms' to the 'Evidence Base' (i.e. when not setting out the Vision) without providing a reference to the appropriate 'Evidence Base' document. Given that the 'Evidence Base' is listed in detail in the first section of the Core Strategy document, it might be helpful to devise a system of Codes, or similar, to provide for cross references from the text box statements to the appropriate 'Evidence Base' document in the earlier list (the same system could be used in respect of 'non-specific references' to the 'Evidence Base' in the main text).
• You should avoid repeating national policy within the Core Strategy. In some instances in the supporting text you actually reproduce sections of PPSs. It may be appropriate in such instances to refer to such policy in general terms (a text box is a good way of doing this) but reproduction of actual PPS text should be avoided. Where references are made in some cases within policy wording to national policy (PPSs etc.) then the policy must be re-written in the Submission document to remove such references. The Core Strategy can only interpret national policy, indicating how it is to be applied to the local area - it must not repeat it.
• Whilst the use of text boxes is to be commended in general, that on P42 contains text which is repeated in some of the main text virtually alongside it. This occurs elsewhere in the document and it should be avoided in the Submission document.
• Several policies (e.g. GB1, ED2) are expressed in terms of: 'we will seek to direct'; 'we will encourage'; 'we will ensure'; we will enhance' etc. Expressed in this way the policies amount to little more than 'statements of intent'. Such expressions beg the questions 'how?', 'when?', 'where?'; and 'what?' etc. The policies in the Core Strategy need to relate to firm actions (albeit 'criteria based' if appropriate) and if there are not clear intentions in relation to delivery, then it is not appropriate to include the policy at all. I accept that as currently written, the policies may be indicating what the 'preferred option' for the policy is, rather than expressing it currently in its final form.
• In policy ED3 other than mention being made of 'Baltic Wharf', the existing employment sites to be reviewed are not identified. In order for the policy to be 'spatially specific' the other sites should be identified.
• Other than mention being made in the supporting text that there is an identified requirement for 2 hectares of office space, there are not any allocations made in terms of quantum of floorspace, or land areas, to meet the jobs requirement for the District. Furthermore, a policy has not been developed in terms of the distinction between locational implications of different uses (i.e. B1, B2 and B8). The submission policy should provide a clearer articulation of the locational implications relative to employment use types B1, B2 and B8 including any relevant split of land requirements relative to the different uses.
• In policy ENV4 'large scale' development is not defined.
• You will need to ensure that the wording in respect of Policy ENV6 wholly accords with the PPS1 Supplement on Climate Change. At present the wording appears to suggest a greater level of restraint than that intended by national policy.
• When/what date will Code Level 3 in Policy ENV8 be introduced? What is your 'Evidence Base' (as required by virtue of the PPS1 Supplement) to justify (in terms of viability) introducing this requirement in Rochford?
• In respect of Policy ENV9, what is your 'Evidence Base' (as required by virtue of the PPS1 Supplement) to justify (in terms of viability) introducing this requirement in Rochford?
• Where is the contaminated land referred to in ENV10 to be found in the District? What are the broad locations?
• In policy RTC1 what is the amount of retail floorspace that is being directed to the stated locations?

• In policy CLT5 what are the standards that will be applied?

• In policy CLT7 what are the standards that will be applied?

• In policy CLT8 what are the standards that will be applied?

• The Key Diagram should preferably be located much earlier on in the document - it could even be located after the background section and preceding the theme based sections. It appears that some potential designations are missing e.g. AQMA's.

• It is important for a Core Strategy to set out a strategic housing trajectory, expressing the Council's broad expectations for the delivery of housing over the Core Strategy period. It is accepted that it will need to be done at a strategic level, since individual development sites have yet to be identified, but it could set out the general expectations for the broad quantum (in general terms) and sources of completions (existing commitment, unallocated urban capacity/windfall sites, brownfield allocations, Greenfield sites/urban extensions etc) over the plan's lifetime. The trajectory should preferably be in the form of a bar chart, or similar, setting out expected development rates and indications of which main locations in each year that development is likely to be forthcoming.

Conclusions

We commend you for the work carried out so far. Where any soundness issues arise, either through our consideration of the work done to date to comply with Regulation 25, or later, through our consideration of the further documents that you will publish to comply with Regulations 25 and 27, we hope that they can be resolved prior to the DPD's submission and subsequent examination.

Essex Chambers of Commerce supports the RTC1 preferred option.

Comments from the FSB SE Essex Branch Vice Chairman.

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

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

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

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

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

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

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

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

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

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

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

Core Strategy Preferred Options


Thank you for your letter of 5 November consulting The Theatres Trust on the Preferred Options for the Core Strategy.



The Theatres Trust is the national advisory public body for theatres and a statutory consultee on planning applications affecting land on which there is a theatre. This applies to all theatre buildings, old and new, in current use, in other uses, or disused. Established by The Theatres Trust Act 1976 'to promote the better protection of theatres', our main objective is to safeguard theatre use, or the potential for such use but we also provide expert advice on design, conservation, property and planning matters to theatre operators, local authorities and official bodies.



Due to the specific nature of the Trust's remit we are concerned with the protection and promotion of theatres and therefore anticipate policies relating to cultural facilities.



This document is a great improvement on the 2007 version but is still lacking any cultural content.



RTC1 Retail and Town Centres

The preamble to this topic includes ensuring that the District's town centres are vibrant places and the text refers to the 2008 Retail and Leisure Study. However, to quote from PPS6 A diversity of uses in centres makes an important contribution to their vitality and viability. Different but complementary uses, during the day and in the evening, can reinforce each other, making town centres more attractive to local residents, shoppers and visitors. Local planning authorities should encourage diversification of uses in the town centre as a whole, and ensure that tourism, leisure and cultural activities, which appeal to a wide range of age and social groups, are dispersed throughout the centre.



PPS6 also states that the main town centre uses are retail, leisure, offices, arts, culture and tourism. Town centres are the heart of communities and an expression of their culture and identity. As well as shops they should provide a range of realistic functions for leisure, recreation and cultural activities centred on restaurants, pubs, clubs, theatres, cinemas, libraries and museums. As such all these elements play an active role in creating and maintaining vibrant town centres and contributing to a stimulating night-time economy.



We would expect therefore to see other town centre uses mentioned in this section and some findings regarding your leisure offer from the Retail and Leisure Study. Or we suggest that you remove any general reference to town centres from this section as policy RTC1 only refers to their retail element.



RTC3 Rayleigh Town Centre

The Retail and Leisure Study is mentioned here which identifies a lack of leisure uses which includes pubs, bars, nightclubs, restaurants, bingo halls, cinemas etc. Here again, the policy only refers to the retail element of the town - no mention is made of any other shortcomings that may need addressing for this 'principal centre of the District'.



CLT1 Planning Obligations

We support a policy in the Core Strategy to show an overall approach to developer contributions with appropriate references to strategic sites and clear links to the details set out in an accompanying supplementary planning document. We look forward to being consulted on this document.



CLT9 Leisure Facilities

Surprisingly the 2008 Retail and Leisure Study isn't mentioned here and this section and the policy only focuses on sport and recreation through your leisure centres.



Your website under Arts and Leisure states that the District has a range of arts and leisure facilities. Your arts facilities should therefore be included in the text and within the policy. The wording of policies needs to be robust, clear and succinct because of the way they determine whether or not, and how development can take place and we therefore suggest that the title of this section be amended to Arts and Leisure Facilities for continuity and clarity.



The policy should ensure that your existing arts and leisure facilities are promoted and protected as without such wording it could become difficult to retain an essential community asset particularly where land values become higher for an alternative use. This policy should also state that the loss of an existing facility will be resisted unless it can be demonstrated that the facility is no longer needed, or it can be established that the services provided by the facility can be served in an alternative location or manner that is equally accessible by the community.



CLT11 Tourism

The opening accompanying text on page 100 states that the District has the potential to be the arts and cultural opportunities area for the sub-region. But there is no mention of this aspiration in any section nor this policy or any other policy.



Even though 'A Better Life' (Essex Cultural Strategy) and Rochford's Cultural Strategy are listed as 'relevant strategies' their content does not make an appearance in this document. Except on page 8 under Priority 6 More participation in sports, culture and volunteering ..... and on page 95 in the right hand column where the Audit Commission Report 2004 found that residents thought that cultural facilities in the District had got better or stayed the same. However there is no mention of cultural facilities in this policy or any other policy.





We look forward to being consulted on the Submission Core Strategy, Infrastructure and Standard Charges document together with Rochford and Hockley Area Action Plans.

Executive summary

RW Land & Planning Ltd welcome the opportunity to submit representations on
behalf of J F Spencer & Son Ltd in response to the Core Strategy Preferred Options, published by Rochford District Council in October 2008.
This submission is split into two parts:

1. Core Strategy Representations
It is felt that the "Core Strategy Preferred Options" does not provide a balanced or
justified distribution of the housing numbers throughout the district and that key
sustainability principles have been disregarded when identifying the preferred housing allocations.

Accordingly, it is considered that Hockley, as a first tier settlement within the district should be allocated a larger proportion of the housing numbers in the area already identified on the Key Diagram as being suitable for housing growth (West Hockley).

2. Site Suitability Appraisal - Land and property at Folly Chase, Hockley

A suitability appraisal of land off Folly Chase, Hockley including the residential plot
known as Thistledown, demonstrates its suitability as a deliverable location for housing in line with the Core Strategy principles. The sites location, within walking distance of Hockley town centre and the available facilities, services and public transport links locally and regionally identify this site as being able to meet sustainability principles and should be considered
appropriate for development.

A Masterplan illustrates one of the many ways this site can be developed for housing and provide a deliverable opportunity to provide social housing within a sustainable location, reducing the reliance on the private car.
Appendix 1 - Site Suitability Matrix
Appendix 2 - Site Photographs

1. Core Strategy Representations
Sustainable Community Strategy - Page 6
We welcome the importance the Council place on the close links between the Sustainable Community Strategy and the Core Strategy including ensuring accessibility to services.
Housing Issues and Options - Page 16
We welcome the acceptance by the Council that infilling alone will not be able to provide the housing numbers necessary and that this would have an adverse effect on the character of the towns.

Whilst we acknowledge that the release of greenfield sites for development present
an opportunity to provide new infrastructure, it is surely more sustainable to concentrate additional housing on greenfield sites which benefit from existing infrastructure and nearby services. This would then enable Planning Obligations to improve services and facilities rather than having to focus on providing basic
infrastructure.

Transport Issues and Options - Page 18
It is acknowledged within the Core Strategy that car dependency within the district
is higher away from the main three settlements of Rayleigh, Hockley/Hawkwell and
Rochford/Ashingdon, primarily due to the rail links within these three towns.

This principle of sustainable development therefore dictates, unless there is a justifiable reason, that the majority of the housing proposed should be within or adjacent to the main three settlements.

Settlements Issues and Options - Page 20
We welcome the four tiers of settlements and the Council's acknowledgment that Hockley is classed as a Tier One settlement containing a "local town centre catering for local need".
We also agree that the Second tier Settlements of Hullbridge and Great Wakering have a "more limited range of services access to public transport is relatively poor".

H1 Distribution - Preferred Option
We acknowledge that brownfield sites should take priority over the development of
Greenfield sites. However, with a rising housing market over recent years, many of the sites identified in the Urban Capacity Study still remain undeveloped it could be argued that if the sites were suitable for development they would have come forward by now. The Council must therefore demonstrate that there is evidence to
suggest that the remaining sites are genuinely available and deliverable within the specified phased timescale.

If they are not deemed to be available, the housing must be allocated on greenfield sites associated with a Tier One settlement.

H2 General Locations and Phasing - Preferred Option

It is welcomed that the Core Strategy accepts that greenfield development will be necessary in order to achieve the required housing numbers.
As set out in the H2 chart and Key diagram, the reliance of Tier Two and Three settlements (Hullbridge, Great Wakering and Canewdon) to provide 860 houses pre 2021 is unsustainable, unjustified and contrary to sustainable planning
guidance at national, regional and local level.

It is acknowledged by the Core Strategy that the Tier Two and Three Settlements only having limited services and poor public transport links and despite this, over 34% of the greenfield housing allocations have been located here without justification.

We acknowledge that development in Tier Two and Three Settlements is necessary to ensure that village communities continue to grow. However, there has been no justification provided that warrants such a large percentage of the overall housing numbers being allocated to these lower tier settlements.

The distribution of the greenfield housing allocations as it stands is contrary to PPS3 which provides clear local level guidance for Core Strategies when deciding on housing locations:
"...at the local level, Local Development Documents should set out a strategy for
the planned location of new housing which contributes to the achievement of
sustainable development." Part of which is "...the contribution to be made to cutting carbon emissions from focusing new development in locations with good public transport accessibility and/or by means other than the private car..."
Even with significant public transport improvements, residents will have to travel a
substantial distance to Rayleigh, Hockley/Hawkwell or Rochford/Ashingdon in order to catch a train and go beyond the local area. This level of development in the lower tier locations are promoting a significant increase in carbon emissions, contrary to PPS3, even if the residents travel by public transport, which the Core Strategy accepts is not the current situation, with high car dependency.

Despite being a Tier One Settlement with an active and diverse town centre and good public transport including a train station, Hockley has only been allocated 50 houses (2% of the total greenfield allocation within the district). This goes against the Core Strategy vision of concentrating development on Upper Tier settlements which have the services and facilities to accommodate additional development.
In light of this unsustainable and unsound approach to housing distribution, Policy H2 General Locations and Phasing - Preferred Option and the Key diagram should be amended to reduce the proposed housing numbers associated with Tier Two and Three settlements and redistribute the surplus to Tier One Settlements and Hockley in particular which has received an unnecessarily low number of houses
despite existing services and facilities to accommodate additional development.

It is proposed in the analysis set out in Appendix 1 that Land at Folly Chase, West Hockley is suitable and capable of accommodating circa 200 houses. Policy H2 should be amended to reflect this.

We welcome a flexible approach to the release of land in order to maintain a five year land supply is supported and necessary. It is imperative, however that in assessing the release of land, the landowners willingness to sell or develop the site is taken into account.

We welcome the identification of West Hockley as being a suitable location for development pre-2015.

H2 Alternative Options
We welcome the comments regarding North East Hockley and agree that the location would place undue pressure on the highway network and that it is unviable for development.

H3 General Locations - Post 2021
The continued reliance on lower tier settlements post 2021 is again unjustified and
unsustainable with 340 homes proposed. These locations, even following improvements to the infrastructure will not provide genuine alternatives to the private car due to the length of journeys required to get to services, facilities and employment.

H4 Affordable Housing
The 35% level proposed must be based on sound qualitative evidence with the flexibility to be reduced if there are site specific circumstances that warrant it.

We do not accept the desire by the Core Strategy to "pepper pot" social housing
throughout developments, it causes difficulty for Housing Associations to manage their properties effectively and efficiently. This should be amended to allow for clusters of social housing units in say, groups of 15-20.

H5 Dwelling Types
Whilst we acknowledge that PPS3 suggests that local level planning documents should assist in developing a suitable mix of houses on sites, PPS3 para 23 also states that developers should "...bring forward proposals that reflect demand and the profile of households requiring market housing...". It is therefore imperative
that H5 makes reference to the influence of market demands and does not solely
rely on the advice of the Strategic Housing Team as the policy currently intimates.

H6 Lifetime Homes
We welcome the fact that the pursuit of 100% Lifetime Homes from 2010 will be viability tested.
H Appendix 1

We welcome the associated infrastructure required in relation to development at
West Hockley.

As part of the development of Land off Folly Chase, Hockley, further community benefits beyond those listed could be included, such as a new community woodland and play space.
Proposed development at the lower tier settlements (Hullbridge, Great Wakering
and Canewdon) are reliant on significant public transport improvements which sequentially is contrary to sustainability principles of focusing development in areas of good public transport, with the ability to improve further.

ENV3 Flood Risk
We welcome the proposal to pursue development in areas which fall into Flood
Zone 1 and the use of the sequential test in PPS25.

ENV4 Sustainable Urban Drainage
SUDS is not always the best environmental option for dealing with drainage. We welcome the viability test intended to identify those sites where SUDS is not appropriate.

ENV8 Renewable Energy
We recognise the Core Strategies desire to adhere to the Code for Sustainable Homes star rating, however, there remains a doubt as to whether Code Level 6 is realistically achievable within the current timescales. There will always be the potential for National Policies to alter the rating system and timescales. There is a
requirement for the Core Strategy to remain flexible and be in parity with The Code for Sustainable Homes, or its successor. Moving away from the Code should it alter, would alienate the Districts development sites from developers and reduce the likelihood of them being built within the Core Strategy phasing timescales.

We welcome the decision to not pursue the 10% renewable "Merton Rule" as piecemeal renewable energy production is not an efficient approach to its production.

T1 Highways
We welcome the objective to locate and design housing developments that reduce the reliance on the private car.

T2 Public Transport
We welcome the objective developments must be well related to public transport, or accessible by means other than the private car.

RTC1 Retail
We welcome the designation of Hockley as a district centre and that retail developments will be focussed towards it along with Rayleigh and Rochford.

RTC5 Hockley Town Centre
We welcome the proposals contained within this policy for the improvement of facilities, services and town centre living within Hockley Town centre.

CLT1 Planning Obligations and Standard Charges
We welcome the continued use of Planning Obligations to secure reasonable on and off site improvements as set out in Circular 05/2005.
Standard charges must take into account the level of impact the future residents are likely to have on the strategic infrastructure and be negotiated on a site by site basis.

[more details including photographs regarding the site put forward can be found our ref allocations no. 69]

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.