RTC5 Hockley Town Centre - Preferred Option

I attended the CAC Meeting in Hawkwell.

Hockley must remain as a distinct community with boundaries and green spaces between Hockley and neighbouring parishes. Countryside in and around Hockley including woods, footpaths,bridleways play areas, playing fields and nature reserves must be 100% preserved. There should be no loss of greenbelt or open spaces in Hockley or the surrounding areas.

Due to shortage of available building land, housing development in and around Hockley must be minimal, and should include starter homes and affordable housing. Historic and listed buildings must be preserved.

Hockley Town Centre development must maintain the character of Hockley, and include a variety of shops, family restaurants,enhanced parking facilitiers, and facilities for the youth. It must consder appropriate facilities for people with disabilities.

Increased pollution in Hockley and its neighbouring parishes must be supported by additional healthcare (dentists and doctors)primary and secondary school places, community services, and leisure facilities.

Improved highways and cycle networks are essential in and around Hockley to support increased traffic volumes, improve road safety and eliminate congestion.

There must be no additional pollution in Hockley in terms of air quality and noise, particularly related to increased traffic volumes and airport expansion programmes.

Public transport must be improved in and around Hockley in terms of routes and frequencies to support additional population and to alleviate the impact of additional traffic volumes.

Additional controls must be introduced to ensure crime levels, vandalism and anti-social behaviour issues, in and around Hockley, do not increase due to additional population numbers.

The core strategy does not provide an option of placing all 3500 homes in one new locations, remote from Hockley, with provision of appropriate self supporting infrastructure (schools, healthcare,community services and leisure facilities) and including public transport and highway networks that do not impact on Hockley.

As the majority of proposed additional housing, pupulation and traffic is located to the east of Hockley, the plan is not sustainable, in and around Hockley, due to insufficient infrastructure proposals (schools, healthcare,community services and leisure facilities) and particularly related to public transport and highway networks. Roads through Hockley already suffer from major congestions issues, and no plans are evident in the strategy to eliminatge current and future traffic issues.

Surely it is not unreasonable to expect there to be a planned infrastructure
put in place before all these houses are built. Where are all these new
roads going to go, stating the obvious that we do have the sea one side.

Also what about our farm land we need this protected for food supply.

One further comment, most people live in Hockley or come back to Hockley because of what it is now, when this wonderful vision for John Prescott eventually happens, no body will want to come back!

Existing units/area should be renovated. NO FURTHER ADDITIONAL UNITS OR AREAS. southend and out of town retail centres provide additional shopping facilities.

Strongly reject any significant retail development of eldon industrial estate. this should be used for services (youth and health) and housing to existing area.

There is already a lot of traffic through Hockley and with the extra housing planned for the Rochford area and the development of the airport, there will probably be a lot more. Unfortunately most of it is through traffic and does not stop, so the businesses do not benefit.
Additional parking would help, along with better signing indicating the car parks and of course, free parking would make a big difference.
If the industrial area in Eldon Way is to be replanned, perhaps some of it could be used to extend the Somerfield car park for the benefit of all. The residents have asked for a youth centre and leisure facilities so the bowling alley should be preserved and the potential MASSIVE youth centre.
More restaurants would also be popular.

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.

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.