CLT5 Open Space - Preferred Option

But not at the expense of greenbelt land and even more development of an already over developed side of Rayleigh and Rawreth

strongly agree. the more the better

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.

In September 2008, the Government receied the following petition:

"We the undersigned petition the Prime Minister to make it compulsory that local authorities and developers make provision for allotments and community gardens on every new development. Waiting lists are huge we need more allotment sites."

The Government's response is below:

'Allotments are valuable green spaces and community assets. We are entirely committed to allotments for all the benefits they provide communities, including the opportunity to grow fresh produce in line with current thinking on healthy eating, organic food, exercise, fostering community cohesion, enhancing biodiversity, and providing educational opportunities and health benefits.

The provision of allotments is the responsibility of local authorities. Under existing legislation (the Smallholdings and Allotments Act 1908) there is a duty on local authorities (except for inner London boroughs) to provide allotments where they perceive a demand for them in their area. If an allotment authority is of the opinion that there is a demand for allotments in its area, it is required, under Section 23 of the Small Holdings and Allotments Act 1908, to provide a sufficient number of allotments and to let them to persons residing in its area who want them.

Written representations may be made to the local authority on the need for allotments by any 6 resident registered electors or persons liable to pay council tax, and the local authority must take those representations into account (section 23(2) of the Small Holdings and Allotments Act 1908). The Council must assess whether there is a demand for allotments in their area. If the Council then decides that there is a demand for them, they have a statutory duty to provide a sufficient number of plots. In terms of the duty to provide under section 23 of the Small Holdings and Allotments Act 1908 there is no time limit for provision once it has been established that there is a demand.

Furthermore, statutory allotments are protected via Section 8 of the Allotments Act 1925 which requires that local authorities seek the Secretary of State's consent for disposal or appropriation to another use. Consent cannot be given unless the Secretary of State is satisfied that certain criteria are met. Clarified criteria were issued to local authorities in February 2002.

Statutory allotments are only sold off if the Secretary of State (via Government Office) gives consent. Consent is not given unless the Secretary of State is satisfied that:

* the allotment in question is not necessary and is surplus to requirement;
* adequate alternative provision will be made for displaced plot holders;
* the number of people on the waiting list has been taken into account;
* that the authority have actively promoted and publicised the availability of sites and have consulted the National Society of Allotment & Leisure Gardeners; and
* the implications of disposal for other relevant policies, in particular development plan policies, have been taken into account

In addition to the legislation, the planning system through Planning Policy Guidance note 17 Planning for Open Space, Sport & Recreation, 2002 (PPG17) and Planning Policy Statement 3 (PPS3) provides a robust framework for the protection and provision of urban green spaces including allotments. PPG17 requires local authorities to make provision for all types of open space that may be of public value. It also requires local authorities to undertake robust assessments of local needs and audits of existing open space, sports and recreational facilities and to establish standards for new provision. It is expected that by implementing the guidance in PPG17, local authorities should make adequate provision for allotments, which are specifically included in the PPG17 typology. On the basis of these assessments and audits, local authorities should plan to meet future needs of their population (e.g. linked to new housing developments) and can place standards of provision in their development plan.

PPS3 says that local planning authorities should have clear policies for the protection and creation of open space, and new housing developments should incorporate sufficient provision where such spaces are not already adequately provided within easy access of the new housing.

Local planning authorities can also negotiate agreements with developers to provide allotments before granting planning permission under section 106 of the Town and Country Planning Act 1990 ('s106 agreements' or 'planning obligations'). In addition, they may be able to impose conditions, which require developers to provide new allotments in certain cases if this is necessary to make the development acceptable in planning terms, and if it is viewed as reasonable in relation to the development.

Over the past year we have worked closely with the Local Government Association to revise the good practice guidance. The new edition of 'Growing in the Community - a good practice guide for the management of allotments' reflects the major developments in the allotments movement since 2001 and has some examples of current good practice, showing innovative use of allotments benefiting all sections of the community. The guide includes a section on allotment provision and provides an up to date policy framework, and a guide to allotments legislation. A free copy of the Guide was sent to all local authorities in England. This guide will, we hope, help local authorities to make full use of the legislative protection afforded to allotments.

Community empowerment also has a real effect. We are of course interested in empowering communities to take action. This is set out in the Local Government White Paper, the Local Government and Public Involvement in Health Act 2007 and the Community Empowerment White Paper; Communities in Control; Real People, Real Power, published in July 2008. Taken together, these provide communities with a framework to ensure local government prioritise the issues important to them. Community empowerment is already central to protecting allotments under current legislation and we are working to ensure that community empowerment mechanisms can benefit all green spaces, including allotments. Through the Community Empowerment White Paper, we are providing new opportunities for citizens to hold their local providers to account for the quality of services and facilities, and places greater charge for local authorities to be responsive to citizens.

LDF Core Strategy Preferred Options

Response On Behalf Of Rayleigh Town Council

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

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

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

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

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

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

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

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

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

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

This statement must be made more prescriptive.

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

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

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

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

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

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

(7) Page 57 ENV4 Sustainable drainage systems

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

This section needs to be far more robust

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

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

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

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

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

At last the voice of reason and common sense!!

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

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

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

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

CORE STRATEGY PREFERRED OPTIONS

Thank you for consulting Sport England on the above document. Sport England is the Government agency responsible for delivering the Government's sporting objectives. Maximising the investment into sport and recreation through the land use planning system is one of our national and regional priorities. You will also be aware that Sport England is a statutory consultee on planning applications affecting playing fields. In this context, I wish to make comments on the following aspects of the document:


Vision to Reality (p.8)
SUPPORT
Sport England welcome the identification of the role of the Core Strategy in achieving Priority 6 of the LAA: "We are committed to improving access to sporting facilities such as informal open space, playing pitches and leisure facilities where a need has been identified, as reinforced within the Core Strategy".

Option GB2: Rural Diversification and Recreational Uses
SUPPORT
Sport England welcome recognition of the sport and recreation as a legitimate Green Belt use, albeit one which demands careful guidance in terms of siting and design.

CLT5: Open Space (p.93/94)
SUPPORT WITH MODIFICATIONS
The reference to playing pitches as part of the complement of open space is welcomed. However, reference to background documents such as the emerging Playing Pitch Strategy would be helpful, as would be a cross-reference to Preferred Option CLT10 (Playing Pitches).

CLT9: Leisure Facilities (p.97/98)
SUPPORT WITH MODIFICATIONS
The spirit and broad content of this preferred option is welcomed as a robust means of their protection and enhancement throughout the District. However, there should be direct reference to a PPG17-compliant assessment of sport and recreation facilities to justify the protection and enhancement of these facilities. Is this the Retail and Leisure Study 2008? In turn, the study should be the basis for the establishment of local standards of provision and justifying developer contributions towards the provision of these facilities. A PPG17 assessment would also be expected to identify sport and recreation facility needs which may have land use allocations e.g. if the PPG17 assessment showed a need to provide new playing fields or new indoor sports facilities, reference to this should be made in the core strategy, especially if this would have implications for the related site specific allocations DPD.

While reference to Sport England's planning tools and the data used for calculating demand for sports facilities is welcomed, I am surprised that there is no reference in this section to the recently launched Essex Sports Facilities Strategy (2008) which has been prepared by Sport Essex (the county sports partnership) in conjunction with all the local authorities in the county including Rochford District Council through the Chief Leisure Officers group. The strategy builds upon the regional sports facility strategy, Creating Active Places (www.sportengland.org/east_index/east_get_resources/iyr_east-planning/creatingactiveplaces.htm) and provides more detail about strategic sports facility needs in Essex including an overview of issues and priorities in Rochford district e.g. sports hall, swimming pool etc needs and sport specific requirements. The county strategy can be downloaded from Sport Essex's website at (www.sportessex.com/publications.php). As the strategy provides an up-to-date evidence base on strategic sports facility needs in Rochford, the content of the strategy should be used to inform the preparation of the core strategy in terms of planning for the provision of community sports facilities.

The above comments are made in the context of the first examination relating to a submitted core strategy DPD in England, where the Inspector who considered the Lichfield Core Strategy DPD concluded that the document's open space policy was unsound because of a lack of a credible evidence base to support the policy relating to the provision of open space in new development. The lack of a credible evidence base was one of the two reasons why this core strategy was considered to be unsound and the DPD was subsequently withdrawn. Further details can be found in the Inspector's report (paragraphs 2.3 to 2.5 and 2.74-2.80 of the report are particularly relevant), which can be downloaded from www.lichfielddc.gov.uk/downloads/Report_on_the_Examination_into_the_Core_Strategy.pdf. I would advise that a number of other core strategies have been considered to be unsound due to the lack of a credible evidence base

In addition, reference to Sport England's document 'Active Design' would be useful to encourage clearer thinking about the role of good urban design in promoting physical activity. Taking widely accepted principles of good design (character, continuity, quality, legibility etc) as a starting point, the guidance uses three objectives to frame advice on positive design: improving accessibility; enhancing amenity; and increasing awareness. Using the three design objectives, the guidance explores in detail their application to three activity settings:

• Everyday activity destinations (shops, homes, schools workplaces)
• Informal activity and recreation (play areas, parks & gardens)
• Formal sports and leisure activities (sports pitches, swimming pools etc)

Active Design poses a number of questions for consideration by planners. The following table gives a flavour of these.

Theme
Accessibility (21 questions)

Example questions
• Are everyday activity destinations accessible to all travel modes?
• Does the design enable the most direct and safe active travel route between everyday activity destinations?
• Are everyday activity destinations co-located to offer the opportunity for linked trips?
• Are active travel routes to everyday activity destinations prioritised?
• Does the design and layout of everyday activity destinations help to prioritise pedestrian, cycle and public transport access?

Theme
Amenity(12 questions)

Example questions
• Are flexible and durable high-quality public spaces proposed?
• Does the quality, design and layout of open spaces enhance the setting of development?
• Does the design of informal sport and recreation facilities create a high quality environment?

Theme
Awareness (13 questions)

Example questions
• Are everyday activity destinations co-located with sports and leisure facilities in a manner that promotes awareness?
• Are informal sport and recreation facilities located in prominent positions?
• Is appropriate high quality provision made for all age groups within the community?
• Are formal sports and leisure facilities located in prominent positions playing a positive role as landmarks and attractions?
The full guidance is available at: www.sportengland.org/index/get_resources/planning_for_sport_front_page/planning_active_design.htm.

CLT10: Playing Pitches (p.98-100)
SUPPORT WIH MODIFICATIONS
Sport England welcome the attention paid to this aspect of the provision of sport and recreation facilities within the District. Reference to Sport England guidance is helpful, as is the commitment to produce a SPD on playing pitch provision. It is assumed that this document will set out local standards for their provision. The same comments would apply as set out in our response to preferred option CLT9 with respect to the reference to the evidence base i.e. a PPG17 compliant assessment. Sport England would therefore expect such a reference to be included to support the preferred option.

I hope that this response is a helpful contribution to the evolution of the Core Strategy. Please contact me if you have any queries about this response or would like advice on how Sport England can assist the Council to develop its LDF in relation to sport and recreation.

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

1.0 Instructions and Introduction

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

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

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

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

Peter Kneen BSc (Hons) MSc MRTPI
Planner

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

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

2.0 Housing:

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

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

Policy H1 - Distribution

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

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

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

Policy H2 - General Locations and Phasing

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

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

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

Policy H3 - General Locations Post 2021

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

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

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

Policy H4 - Affordable Housing

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

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

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

Policy H5 - Dwelling Types

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

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

Policy H6 - Lifetime Homes

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

3.0 The Green Belt:

Policy GB1 - Green Belt Protection

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

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

Policy GB2 - Rural Diversification and Recreational Uses

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

4.0 Environmental Issues:

Policy ENV3 - Flood Risk

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

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

Policy ENV4 - Sustainable Drainage System (SUDS)

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

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

Policy ENV8 - Code for Sustainable Homes

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

5.0 Transport:

Policy T1 - Highways

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

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

Policy T2 - Public Transport

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

Policy T4 - Travel Plans

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

Policy T5 - Cycling and Walking

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

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

Policy T7 - Parking Standards

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

6.0 Character of Place:

Policy CP1 - Design

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

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

7.0 Community Infrastructure, Leisure and Tourism:

Policy CLT1 - Planning Obligations and Standard Charges

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

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

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

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

Policy CLT6 - Community Facilities

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

8.0 Summary:

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

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

Revised Core Strategy Preferred Options Consultation

Thank you for consulting Natural England on the above, in your letter received by this office by email on 5 November 2008. We refer you to previous comments made in our letter of 27 June 2007 during the initial preferred options consultation. Whilst we are generally supportive of the plan, we would like to make the following comments.

Evidence Base
Natural England is pleased to note that the Essex Landscape Character Assessment (2003) and the Local Wildlife Site Review (2007) has been included under this heading.

Vision
Natural England supports the vision because it sets out the intention to retain the essential landscape characteristics of the district and the distinctiveness of both the natural and built environment. These are aspects which are compatible with our own objectives. We also support the recognition of the District's position within Thames Gateway South Essex to promote the District as the "green part" of the sub region.

Objectives
Whilst Natural England generally supports the objectives we would liked to have seen specific reference to "landscape" within the fourth bullet point. We also consider that there should be a stronger reference to climate change within the objectives, linked particularly to the transport objective (6th bullet point) by referring to the need to reduce carbon emissions. An additional objective should also be included on the issue of renewable energy and climate change, for example "to promote renewable energy and address the causes and potential impacts of climate change"

The Green Belt

GB2 Rural Diversification and Recreational Uses - Preferred Option
Natural England supports the Council's preferred option on this issue. We have recently assessed the case for a review of green belt policy where the role of the green belt is reconsidered. The value of the green belt should be judged on its contribution to quality of life, nature conservation, landscape protection, flood mitigation and the impact of a changing climate. Linked with this is a desire to improve the environmental quality of existing green belt. We would therefore support rural diversification within the green belt such as green tourism and outdoor recreation, provided these activities are linked with environmental enhancements and an increase in biodiversity.



Economic Development

ED1 London Southend Airport - Preferred Option
Natural England reiterate our previous comments on the London Southend Airport, that is we are concerned with the impact of the growth in the airport on air quality and on the disturbance of Natura 2000 sites. We also would actively encourage enhanced North South links including greenways, as envisaged in the Thames Gateway South Essex Greengrid

Environmental issues

Crouch and Roach Estuary Management Plan (Page 52, 4th paragraph)
In this paragraph a list of stakeholders is given who are working with Rochford District Council on the above plan. Natural England should also be actively involved in this project and listed accordingly.

All references to 'English Nature' should be changed to read 'Natural England', e.g. page 52, 1st paragraph.

ENV1 Protection and Enhancement of the Natural Landscape and Habitats - Preferred Option
Natural England supports the overall aims of the preferred option and we are pleased to note that the wording now includes "maintain, restore and enhance" rather than just protect. However we consider that the policy does not fully cover all aspects of the natural environment but concentrates on the protection and enhancement of designated sites. We therefore suggest that the policy is expanded to include the following points:

i. Wildlife Networks- Natural England would like the policy wording to encourage an approach to conservation management which is focussed not solely on individual site protection but which seeks to rebuild the fabric of the landscape in which individual sites sit. Actions such as reducing habitat fragmentation and creating green corridors for wildlife can help to achieve this. PPS9 states specifically at paragraph 12 that "Local authorities should aim to maintain networks by avoiding or repairing the fragmentation and isolation of natural habitats through policies in plans." This policy could link to a wider policy on Green Infrastructure. We would therefore suggest that the following point is added to the policy wording: "The Council will ensure the protection and enhancement of a network of local wildlife sites and wildlife corridors, links and stepping stones between areas of natural green space to avoid fragmentation of habitats".

ii. Designing in Wildlife - We would recommend the inclusion of designing in biodiversity measures within this policy. By incorporating ecologically sensitive design and features for biodiversity early on within a development scheme, significant improvements for biodiversity can be achieved, along with easier integration with wider environmental, design and planning aspects. For example designing for biodiversity can include the retention of sensitive or valuable habitats present, or enhancements for protected species that may be present, whilst integrating other development design requirements such as drainage and engineering. By addressing ecological aspects early on, design aspects such as site layout can be tailored to provide enhancements and improvements for biodiversity that may not be possible later on within the design process. Measures to encourage biodiversity can include green roofs, planting and landscaping using native species, setting up bird and bat boxes and sustainable urban drainage systems. We would suggest that the following point is added to the policy wording: "The Council will ensure development seeks to produce a net gain in biodiversity by designing in wildlife, and ensuring any unavoidable impacts are appropriately mitigated for."

iii. BAP Targets - We would suggest that this policy is linked to the Essex Biodiversity Strategy (1999) which has established targets to boost priority habitats and targets. The policy should therefore include the additional wording: "The Council will promote wildlife enhancements which will contribute to the habitat and species restoration targets set out in the Essex Biodiversity Strategy."

iv. Landscape Character - In addition this policy, although it mentions "natural landscape" in the title does not fully cover the protection and enhancement of landscape character and quality. The Landscape Character Assessment of Essex (2002) should be specifically mentioned in the policy wording. LCAs are a tool to understand the intrinsic character of the landscape and direct appropriate sustainable development and should be used as part of the evidence base to underpin planning and management decisions in the preparation of the LDF. We therefore suggest the insertion of wording which seeks to achieve the following: "The landscape character and local distinctiveness of the District will be protected, conserved and where possible enhanced. Proposals for development will take into account the local distinctiveness and sensitivity to change of distinctive landscape character types. These landscape character types are described in the Essex Landscape Character Assessment"

ENV2 Coastal Protection Belt - Preferred Option
Whilst Natural England generally supports the aims of the preferred option and agrees with the overall approach of protecting the open character of the undeveloped coast and its important wildlife sites, we suggest that this policy should give explicit recognition to the implications of climate change and sea level rise, and the need for necessary adaptation. The current draft appears to defend a 'static' situation. We also draw your attention to policy SS9 of the East of England Plan, which states that LDDs should (inter alia):
• protect important coastal environmental assets, if practicable and sustainable without causing adverse impacts elsewhere. If it is not practicable to protect sites and habitats in situ, including sites of European or international importance for wildlife, shoreline management plans and development plans should include proposals for their long-term replacement and the recording of any lost historic assets;
investigate and pursue opportunities for the creation of new coastal habitats, such as salt marsh and mudflat, in areas identified for managed realignment. New development should not be permitted in such areas.

ENV4 Sustainable Urban Drainage Systems (SUDS) - Preferred Option
Natural England agrees that Sustainable Urban Drainage Systems (SUDs) should be encouraged within new developments as part of sustainable design. SUDS can be used to provide open space and wildlife habitats around areas of vegetation, water channels and storage ponds which are positive steps to increasing biodiversity.

ENV6 Large Scale Renewable Energy Projects - Preferred Option
Natural England agrees that large scale projects should only be considered where there is no significant adverse affect on the landscape or wildlife. We would also recommend that when considering locations for renewable energy installations that the Essex Landscape Character Assessment should be referred to. This will help to ensure that installations are located in places which will cause minimum impact on the surrounding landscape.

Notwithstanding the above, and the current policy wording to protect site integrity, we highlight to the Council the supplement to PPS1: Planning and Climate Change, which requires that: "19. In developing their core strategy and supporting local development documents, planning authorities should provide a framework that promotes and encourages renewable and low carbon energy generation. Policies should be designed to promote and not restrict renewable and low-carbon energy and supporting infrastructure."
And
"20. In particular, planning authorities should:.......
ensure any local approach to protecting landscape and townscape is consistent with PPS22 and does not preclude the supply of any type of renewable energy other than in the most exceptional circumstances"
Natural England therefore comments that an appropriate balance needs to be struck between site protection and the promotion of renewable and low-carbon energy generation projects. We also suggest that a fuller criteria-based policy is included in the Development Control Policies DPD.

ENV7 Small Scale Renewable Energy projects - Preferred Option
We are supportive of small scale energy projects as part of sustainable design and construction.


ENV8 Code for Sustainable Homes - Preferred Option
Natural England supports the preferred option as it is compatible with our own promotion of sustainable design and construction including energy efficiency in homes. We would draw the Council's attention to our project "A New Vernacular for the Countryside" which addresses broad sustainable design and construction principles for the countryside.

Transport

T5 Cycling and Walking - Preferred Option
Natural England supports the preferred option. Footpaths and cycleways should be provided as part of new development layouts which will contribute to sustainable transport and also provide informal recreation opportunities to help improve the health and well-being of residents.

T6 Greenways - Preferred Option
Natural England is supportive of the Thames Gateway Green Grid Strategy and would see the provision of greenways as a contribution to a wider network of green infrastructure. We therefore welcome this commitment to the implementation

Character of Place

CP1 Design - Preferred Option
Natural England supports this preferred option and acknowledges the importance of setting high standards of design in all new development. We would like to ensure that development is "good enough to approve", accessible to all, locally distinctive and makes a positive contribution to the character of the area, utilising the opportunities presented by the location. In particular we are glad to note that Village Design Statements have been included in the policy wording as this is an initiative which Natural England actively promotes.

In our previous comments on this issue we also made the point that opportunities should be sought to promote accessible greenspace provision that meets local requirements and provides functional links for people and wildlife. We recommended that the authority should consider the use of policies to promote the delivery and long-term management and maintenance of greenspace and green linkages.

Community Infrastructure, Leisure and Tourism

CLT1 Planning Obligations and Standard Charges - Preferred Option
Natural England would suggest that countryside recreation projects including the management and maintenance of greenspace, wildlife sites and environmental improvements should be included in the list of activities that planning obligations and charges could contribute to.

CLT5 Opens Space - Preferred Option
Whilst Natural England supports the preferred option we consider that it should be expanded in greater detail. We would like the point emphasised that all development should incorporate sufficient new green space in accordance with Natural England's Natural Green Space Standards of achieving natural greenspace within 300m of every home.

The policy should also emphasise how open spaces and green areas could be improved and enhanced and linked to a wider network of open spaces, footpaths, amenity areas, river corridors i.e. Green Infrastructure. Wherever possible opportunities should be taken to improve the biodiversity and amenity value of these areas by suitable planting with native species or improved management regimes. It may also be possible to introduce footpaths or cycleways through these areas which would increase the provision of informal recreation and contribute to sustainable transport measures.

CT11 Tourism - Preferred Option
Natural England supports the preferred option particularly the proviso that green tourism projects should not adversely impact on character of place or biodiversity. We would reiterate our previous comments that it should be mentioned in the policy wording that this approach is consistent with the objectives of the Thames Gateway South Essex Greengrid. We would also make the point that the conversion of rural buildings could involve damage to protected species such as barn owls and this should be mentioned in the explanatory text.

Upper Roach Valley and Wallasea Island

URV1 Upper Roach Valley - Preferred Option
As we said in our previous comments Natural England supports the Council's preferred option for the enhancement and protection of the Upper Roach Valley including the Country Park. This provides an opportunity to link this area with the wider green infrastructure network and improve access to the countryside from surrounding areas. We suggest however that the policy is reworded to refer to 'appropriate management', as 'minimum of interference' as presently set out may not in fact 'permit certain flora and fauna to flourish.'

URV2 Wallasea Island - Preferred Option
Natural England supports the Council's preferred option as it supports the Wallasea Wild Coast Project which will create a variety of wildlife habitats and enhance the biodiversity of the area. We suggest however that the policy is reworded from 'no adverse impacts' to 'provided any adverse ecological impacts are avoided, mitigated, or compensated for.'

Habitat Regulations Assessment

As discussed in our responses to the previous Core Strategy Preferred Options and Strategic Environmental Assessment, dated 27 and 13 June 2007, we remind the Council that the Core Strategy will require assessment against the Habitats Regulations. I provide an extract below from our 27 June 2007 letter:

"Where a plan may affect a European site, the European Court of Justice ruling (October 2005), has concluded Article 6(3) of the Habitats Directive provides that any plan or project not directly connected with or necessary to the management of a European site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, must be subject to appropriate assessment of its implications for the site in view of the site's conservation objectives. In practice, the SEA should aim to be sufficiently detailed in its assessment to address the requirements of The Habitats Directive 92/43/EEC of 21 May 1992.

The Assessment will require an initial screening of all policies alone and in combination with other plans and projects. This aims to establish whether any policies should be regarded as likely to cause/have a significant effect on the interest features of the European Sites, either alone or in combination with other plans or projects. Options should then be considered to establish whether amendments to individual policies, suite of policies or supporting text could effectively address concerns to 'not likely significant effect'.

Those policies that are still regarded as likely to have a significant effect will then require an appropriate assessment in accordance with Regulation 48 of the Habitat Regulations. National Government direction encourages local planning authorities to develop local development documents that clearly demonstrate that they avoid an adverse affect on the integrity of the Natura 2000 sites, either alone or in combination with other plans or projects.

Furthermore, consistent with the cross-border working that is necessary in delivering strategic solutions we recommend you gain a brief appreciation of the assessment from the developing Habitat Regulations Assessment for Southend on Sea Borough Council's Core Strategy (see Topic Papers for Examination in Public www.southend.gov.uk ).

Our initial assessment indicates that the particular elements of the strategic direction could be likely to have a significant effect, either alone or in combination with other plans or projects and these are listed below:

i) Overall growth targets, alone and in combination with relevant Regional growth area targets, will lead to increased population and subsequent increased recreational pressure on Natura 2000 sites.

ii) The aspirations for significant growth in airport movements at Southend Airport, which may result in increased air quality and/or disturbance impacts on Natura 2000 sites.

iii) Development in, or immediately adjacent to, intertidal or coastal areas that either requires land-take through encroachment or exacerbates the effects of coastal squeeze."

I trust these comments are of assistance to you and please do not hesitate to contact me if you wish to discuss any of the above further.

Dear Sir / Madam,

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

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

Vision

The Council's key planning objectives include the following:

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

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

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

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

Housing

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

Distribution

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

Policy H1 - Distribution - Preferred Option

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

General Locations

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

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

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

Policy H2 - General Locations and Phasing - Preferred Option

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Affordable Housing

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

Policy H4 - Affordable Housing - Preferred Option

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

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

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

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

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

Lifetime Homes

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

Policy H6 - Lifetime Homes - Preferred Option

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

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

The Green Belt

Protection of the Green Belt

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

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

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

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

Policy GB1 - Green Belt Protection - Preferred Option

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

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

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

Transport

Parking Standards

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

Policy T7 - Parking Standards - Preferred Option

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

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

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

Open Space

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

Policy CLT5 - Open Space - Preferred Option

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

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

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

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

New forms of the above will be promoted.

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

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

Comments on behalf of Mr & Mrs T Harold in response to the Council's public consultation on the Core Strategy Preferred Options document, dated October 2008, to form part of the Local Development Framework of Rochford District Council.

It is noted some Green Belt land will need to be released and 70% of new housing is to be on greenfield sites, as sustainable extensions to existing settlements within the plan period 2001 - 2021.

Our clients support the Council's preferred option for the distribution of land for new housing, broadly in accordance with the key diagram, so as to avoid the over intensification of existing residential areas, in accordance with H1.

The approach of focusing new housing development on the higher tier settlements, including Rayleigh, Rochford/Ashingdon, and Hockley/Hawkwell is supported, as part of the proposed balanced strategy. Our clients consider preference should be given to brownfield sites already developed.

Our clients support the Council's Preferred Option for the General Location of future housing development, as set out in H1, on the understanding this does not exclude their own site (see call for sites ref number 114) and they feel the West Hockley area has the potential for a greater number of dwellings both during the pre 2015 period and between 2015 and 2021.

Accordingly our clients ask for the tables in H2 and H3 to be amended so as to include a higher allocation for the West Hockley area. This can be achieved without encroachment into the open countryside and will not prejudice the separation between Hockley and the neighbouring settlements of Rayleigh and Hullbridge.

Our clients' above mentioned site has been put forward as a mixed site for both residential and public open space. As such they suggest this represents an opportunity to make a significant contribution in accordance with preferred option CLT5 and to link into the Green Grid Greenway and the recreational potential of the land to the south-west of Hockley, within the Upper Roach Valley.


Comments submitted on behalf of Mr & Mrs T Harold
by Graham Jolley Ltd

INTRODUCTION

We act on behalf of Crowstone Properties Ltd and are instructed to submit Representations on their behalf as part of the Consultation on the emerging Core Strategy.

Whilst we fully appreciate that the current stage is principally concerned with strategic and district-wide issues rather than site-specific aspects, we note that Policy H2 General Locations and Phasing Preferred Option contains a schedule of areas which are indicated on the Key Diagram. We also note that two of the areas, namely West Hockley and West Great Wakering, have capacities of only 50 units. Our clients Representations submitted at an earlier consultation stage on the Core Strategy Preferred Options, (ie July 2007) included a Land Bid relating to developable land on the western side of Ashingdon which extends to approximately 2.5 hectares and would therefore provide an estimated minimum capacity in excess of 50 units. It is therefore of sufficient size to be regarded as "strategic" in terms of the Core Strategy and Policy H2.

Our Representations are in three parts:-

Part A: General Representations
Part B: Strategic Site Representations
Part C: Schedule of Amendments

At various points, however, we will cross-reference to our proposed strategic site, a plan of which can be found at the end of Part B. As noted, the area edged red extends to 2.5 hectares of which 0.5 hectares would be used to provide peripheral landscaping, and if required, a car park to serve the open space to the west and south. Immediately to the north, edged in blue, a woodland area extending to approximately 1.5 hectares would be dedicated for public open space. The strategic 4.0 hectare site would therefore constitute a mixed use comprising housing, a public car park and public open space and amenity land.

It would be of great assistance if future documents have their various sections numbered and each paragraph given a discreet paragraph number. The absence of any form of numbering system poses difficulty in identifying particular quotes from the document which makes the task of the reader and writer more laborious.

PART A: GENERAL REPRESENTATIONS

Listening to your views:

We found the summary of public opinion set out in "Listening To Your Views" to be both interesting and valuable as a basis for formulating the Core Strategy.

Clearly, one of the key points of public concern relates to the question of whether some Green Belt land should be used for future development. Much depends on how the question is put; if one asks: should Green Belt land be developed? - it is to be expected that most people's first reaction is that it should not. It is widely recognised and appreciated that undeveloped land in Rochford District performs many functions - it provides the setting for the settlements, gaps which prevent the coalescence of settlements, areas for informal and formal recreation, and pleasant countryside. Any encroachment of the Green Belt must be at a cost and should be avoided if humanly possible. If, however, the question is put another way, namely - should we safeguard the Green Belt rather than make provision for the various types of housing to meet the needs of our existing and future residents? - then a different response might be forthcoming. The prospect of housing shortages, with house shortages, with house prices driven up by scarcity value, and younger sections of the population finding it even more difficult to reach the first rung on the housing ladder, might be sufficiently unattractive a proposition to lead people to support a justified and carefully controlled release of parts of the Green Belt. We therefore welcome the fact that after many years of assiduous protection of Green Belt land, the Council has "grasped the nettle" and has clearly identified sound reasons why it is a Preferred Option to identify some Green Belt land for development.

Characteristics, Issue and Opportunities

We also found the section headed "Characteristics, Issues and Opportunities" to be a useful summary which painted an accurate picture of the current character and contemporary issues in Rochford District.

Economy

We do not consider the document sufficiently recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable. We note the paragraph which states "A high proportion of the Rochford workforce commutes out of the District. 30% travel to work in Southend, 14% to London, 9% to Basildon and about 15% travel elsewhere outside the District." In other words, 68% of the working population commute out of the District and only 32% work within the District. Even allowing for the high proportion that commute the relatively short distance to Southend, this represents a very heavy reliance on employment beyond the District's boundaries. The District is therefore highly unsustainable in this particular respect.

We note the references to Thames Gateway South Essex and to initiatives at Southend Airport, but consider that such employment growth will needs to be supplemented by a myriad of smaller and localized initiatives which are more likely to reduce the lengths of journey to work. At the same time, if well located, small business parks and enterprise areas would help counterbalance the lack of local employment which makes the District so heavily reliant on other areas. It would also reinforce the District's track record for thriving small businesses.

Settlements

We broadly support the four tiers of settlement with the first tier comprising Rayleigh, Rochford and Hockley as set out on page 20. We note, however, in "General Locations" on page 26, the first tier settlements are listed as Rayleigh; Rochford/Ashingdon; Hockley/Hawkwell. We have no difficulty with this but consider there should be consistency as to how settlements are addressed. For the avoidance of doubt, we prefer the approach adopted on page 26.

Vision

Again we register our support for the overarching vision and the key planning objectives. Without detracting from the high ideals expressed here, we would perhaps hope to see a much fuller explanation of how the vision is to be realised. Some reference to the types of measures or policy and proposals that will be introduced to implement the key planning objectives might be appropriate at this stage.

Housing

We consider the remaining balance of 2,489 units for the period 2001-2021 together with the further 1,000 units for the period 2021-2025 represents a substantial commitment requiring careful decisions in relation to its future distribution. We fully acknowledge the concern that can arise from town cramming and the difficulty posed by the rapidly dwindling supply of other brownfield land. We consider the Council can be justifiably proud of its record in directing a high proportion of recent growth to brownfield sites. However, this is a finite resource and it was inevitable that at some point it would be necessary to increase the Greenfield contribution. In the Council's view, that point has now been reached, and we agree with that. We note that the 30% of development that will still be targeted to brownfield sites is only half that advised in the East of England Plan, but that this lower level is probably realistic and hence deliverable. In any event, it is also important not to rely on regular reviews of the Green Belt boundary and this points to the need for long term land reserves needed for development being taken out of the Green Belt as part of the Core Strategy.

In moving towards the Preferred Distribution, we note the following on page 26.

"The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District."

We believe that is exactly the right approach but at this stage we have not seen the evidence to support this important claim. Indeed, the Preferred Options move rapidly into the topic of "Housing" without any clear demonstration of a comprehensive and holistic approach in terms of the distribution of the wider development needs of the District. In other words, we would expect to see a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles. We do not believe that general locations for new housing, for example, can be selected in isolation but that such decisions must reflect a pre-agreed framework of sustainability principles taking account of existing and all forms of new development requirements.

In turning to H2 General Locations and Phasing - Preferred Option, it is unclear what process of selection was undertaken to alight on this particular choice of area. No doubt each of the areas identified have their own particular merits and advantages, and some may be highly sustainable and other less so. It is difficult to pass judgement without any pre-stated basis for the inclusion of these particular areas. By the same token, the reasoning behind the split before and after 2015 is equally unclear. We do not oppose the principle of staging development - indeed we support it if this assists in ensuring land allocations are more evenly spread and hence available throughout the plan period. Again, however, we expect to see the reasoning for this split and this does not seem to be apparent. We raise these points because they are fundamental and there needs to be a clearly understood basis for the choice of general locations and for phasing. We have given careful consideration to the general locations set out in H2 and the alternative options set out giving reasons why these further locations were not preferred. Having regard to the earlier representations submitted on behalf of Crowstone Development Ltd relating to an area on the western side of Ashingdon, we can find no reference to this as a possible option.

Turning to H3 General Location Post-2021 Preferred Option, we consider there is a similar duty to justify the general locations and capacity for the areas identified. Whilst we note that: "The detailed location and development will be articulated within the Allocations Development Plan document and, where appropriate, Area Action Plans," this in no way reduces the need to ensure that the location itself is sustainable and can be justified as a Preferred Option. The information and analysis to support the general locations both pre and post 2015 and post 2021 is lacking and we consider this must go to the soundness of the Plan.

Affordable Housing

We take the view that much greater emphasis must be given in future to the delivery of affordable units, especially having regard to the high house values which preclude so many entering the housing market. We recognise that Exceptions Policies are necessary but deliver very little in terms of numbers. We also recognise that it is the larger sites that have the viability which enables a significant proportion of affordable units to be provided or cross-subsidised by free market housing. A judgement is needed as to the level of affordable provision that should be required from new sites. On balance we consider the suggestion that at least 35% of dwellings on all developments of 15 or more units, or on sites greater than 0.5 ha, should be affordable - gets the balance about right. We therefore support the wording of H4 Affordable Housing - Preferred Option in this respect and favour this to the Alternative Options in H4.

With regard, however, to the requirement to spread (pepper-pot) affordable dwellings throughout larger developments, we express certain concerns. We agree that large blocs of affordable housing should be avoided if possible but pepper-potting can give rise to design and management problems. As usual, these matters can normally be overcome through compromise having regard to the circumstances relating to each particular site. We would therefore prefer to see a more general reference to the need to avoid large blocs of affordable housing and the need to integrate affordable and free market housing in a harmonious way.

The Green Belt

As indicated above, we support the conclusion that the time has now come when the current boundaries of the Green Belt need to be reviewed to enable development required to be provided in Rochford District by the East of England Plan can be met in an environmentally acceptable way. Given the long-term nature of the plan period, the opportunity arises to adjust the Green Belt boundaries to facilitate growth over a long period and this should avoid the need for repetitive short term reviews which could undermine the confidence in the Green Belt. We note the wording of GB1 Green Belt Protection - Preferred Option and in particular the commitment to prioritise the protection of Green Belt land based on how well the land helps achieve the purposes of the Green Belt. Whilst this seems entirely clear and logical, we would expect this exercise to be conducted to inform the general locations identified in H2 and H3. Further uncertainty arises from the reference to "strategic buffers that are particularly worthy of mention" which appear not to be mentioned or featured on the Key Diagram. We consider any reference to "strategic buffers" should be deleted from the text as this function will continue to be achieved by means of the Green Belt.

The approach being adopted towards the release of Green Belt land for development may be sound as a general principle but we would expect to see clear evidence to support the general locations for growth in terms of their relative impact on the purposes of the Green Belt. There would appear to be a lack of joined up thinking between the Preferred Options in H1 and H2 and that in GB1.

Dwelling Types

Whilst we support the wish to ensure a mix of dwelling types to reflect a wide spectrum of housing needs and budgets, much will depend of the size of the particular development, the character of the area, and any other local constraints or factors. We therefore have certain reservations about a blanket policy requiring a housing mix. Such a mix may in any event be triggered by the requirement to provide affordable housing over and above the thresholds in H4. Our reservations might be overcome quite simply by inserting the words "Where appropriate," at the beginning of the text H5.

Rural Diversification, Green Tourism and Recreational Uses

We support the Council's aims to promote and secure a vibrant and prosperous countryside and one that encourages recreational uses. In fringe urban areas and particularly where development abuts the Green Belt boundary, opportunities should be explored to supplement formal and informal recreational provision as part and parcel of mixed use development sites. The opportunities for such provision should be one of the determining factors in the selection of locations for growth and subsequently at the Site Allocations DPD stage.

Future Employment Allocations

We generally welcome the initiatives set out to deliver increased employment provision to meet the needs of the District and its growing population over the plan period. We nevertheless have similar reservations to those expressed in relation to housing in terms of the proposals put forward. It is vital that housing and employment are considered jointly to ensure the best possible "fit" which would encourage new and more accessible employment opportunities. We would like to see evidence of the co-ordinated provision for housing and employment promoted through the growth locations put forward as Preferred Options. Again, this potentially calls into question the soundness of the plan.

Environmental Issues

We support the continuing protection of the District's natural landscape and habitats and hence we endorse the Preferred Options in ENV1 and ENV2. We consider some of the protective notations are sufficiently important to be denoted on the Key Diagram.

Flood Risk

Clearly the avoidance of areas prone to or at risk of flooding will be a key consideration in the choice of growth locations and later individual sites at the Site Allocations DPD stage. We mention in passing that the inclusion of the western side of Ashingdon as a General Location would not pose any problems associated with flood risk as it lies entirely outside any area so defined by the Environment Agency (see Part C).

Transport

We fully endorse the Preferred Options in T1 Highways and T2 Public Transport. With regard to the Preferred Option T5 Cycling and Walking, we draw attention to the particular opportunities in this respect associated with the inclusion of the western side of Ashingdon (see Part C).

Community Infrastructure, Leisure and Tourism

With regard to CLT5 Open Space - Preferred Option, we have already indicated we see opportunities for providing Open Space for both formal and informal recreation in association with General Locations especially on the edge or within the Green Belt. There are particular opportunities on the western side of Ashingdon which we refer to in Part C.

CONCLUSION

Whilst it will be seen that we have identified much to support within the text of the consultation document, we have expressed concerns in relation to the justification of many of the Preferred Options - particularly where these have Lane Use implications. Whilst not necessarily opposing any particular proposal, we have been unable to establish a paper trail which would convince us that such proposals are indeed justified in themselves or sufficiently tested. In some respects, the danger is that unless there is a clear testing of options against agreed criteria leading through a sieving process to establish the most appropriate locations for growth, then the process is not very different from the old style Local Plan system. It is this introduction of "better assessment" which is critical in terms of determining 'soundness'. An example of this crucial defect is the identification of General Locations requiring the loss of Green Belt land without any reference to the evaluation of the relative effects of that encroachment in relation to the purposes of the Green Belt. We believe these fundamental concerns need to be addressed in order to achieve reasonable confidence in the Core Strategy.

PART B: STRATEGIC SITE REPRESENTATIONS

In the above submission, we indicated that we considered the Land Bid put forward at an earlier stage in relation to Land on the Western Side of Ashingdon qualifies as a General Location because of its capacity to deliver more than 50 units - the lowest capacity threshold in H2. A plan identifying theland in question is found at the end of this section. As noted in the introduction, the site extends to 4.0 hectares of which 1.5 hectares is existing woodland. The remaining 2.5 hectares re envisaged to provide 2.0 hectares of housing and 0.5 hectares for landscaping and a public car park serving the Open Space to the west. Based on minimum densities required in PPS3: Housing, it is therefore envisaged that the location would provide a minimum of 60 units.

The main justification for the inclusion of the western side of Ashingdon as a General Location is as follows.

The location directly abuts established development off Rectory Avenue with estate road access up to its boundary along Hogarth Way. It therefore forms a natural adjunct to the existing built up area.
The location has very clearly demarcated and defensible boundaries in the form of a boundary with a flood park to the south, a footpath/cycleway to the west, and mature woodland and bridleway to the north.
There are important opportunities to contribute to the recreational use and potential of the land to the west as well as to upgrade the woodland for public access.
There are additional opportunities to provide a landscaped recreational car park for use by ramblers and dog walkers on the western side of the development served via Hogarth Way.
The interface between the development and open land to the west can be provided with a landscape buffer to help integrate the General Location into its landscape setting.
The site lies outside any Flood Risk zone identified by the Environment Agency (see plan at end of this section).

It is considered that a General Location identified on the western side of Ashingdon compares well with other locations on the edge of Rochford/Ashingdon in terms of its sustainability, its effect on the Green Belt, and on the setting of the settlement. As noted in Part A, this general location is not included in the list of General Locations or in the alternatives that have been considered and rejected.

We have advanced the view in Part A that particular regard should be had to the contribution General Locations might make to recreational facilities and amenities. We attach sufficient importance to this by suggesting that it could be a determining factor in the choice of General Locations. The associated Open Space and woodland management that would be achieved as part of the development of this proposed General Location would be very substantial indeed and would reinforce the existing neighbouring Open Space provision which is heavily used by both the local resident population and by visitors. There are no Rights of Way across this General Location at present. However, we envisage that there would be new footpath and cycleway routes through the development area to link with the existing Rights of Way.

Having regard to the above, we put forward land on the western side of Ashingdon as a General Location that should be included in H2 as a Preferred Option.

PART C: SCHEDULE OF AMENDMENTS

We set out below the main amendments we are seeking and suggesting to the Core Strategy Preferred Options some of which we believe to be necessary in order to make the document 'sound'.

1. Insert text which recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable.

2. Supplement the main employment growth proposals with complementary proposals relating to smaller and localised employment initiatives likely to reduce the lengths of journey to work.

3. Refer consistently to Rochford/Ashingdon and Hockley/Hawkwell rather than just Rochford and Hockley.

4. Provide a fuller explanation of how the 'Vision' is to be realised through the implementation of the key planning objectives.

5. Provide evidence to support the claim that "The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District".

6. Set out a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles.

7. Demonstrate how the coherent strategy referred to in (6) above has informed the General Locations for new housing and other forms of development.

8. Provide supporting evidence to justify the locations and capacity for the release of land pre- and post-2015 and post 2021.

9. Amend text to delete reference to pepper-potting affordable housing and refer instead to the need to avoid large blocks of affordable housing and the need to integrate affordable and free-market housing in a harmonious way.

10. Explain the relative effects of the General Locations identified in H2 and H3 on the Green Belt.

11. Delete reference to "strategic buffers" as their purpose will continue to be achieved by the Green Belt.

12. Insert the words "Where appropriate," at the beginning of H5.

13. Make explicit that opportunities should be explored for the provision of recreational and amenity land within or adjoining General Locations.

14. Provide clearer evidence to show a coordinated approach to the provision for housing and employment in order to meet the tests of soundness.

15. Consider including the more important rural and natural resource notations on the Key Diagram.

16. Include Land on the western side of Ashingdon (Part B of this submission) as a General Location in H2.

INTRODUCTION

We act on behalf of Mr Dudley Ball - a resident of Church Road, Hockley and are instructed to submit Representations on their behalf as part of the Consultation on the emerging Core Strategy.

Our Representations are in two parts:-

Part A: General Representations
Part B: Schedule of Requested Amendments

PART A: GENERAL REPRESENTATIONS

Listening to your views:

We found the summary of public opinion set out in "Listening To Your Views" to be both interesting and valuable as a basis for formulating the Core Strategy.

Clearly, one of the key points of public concern relates to the question of whether some Green Belt land should be used for future development. Much depends on how the question is put; if one asks: should Green Belt land be developed? - it is to be expected that most people's first reaction is that it should not. It is widely recognised and appreciated that undeveloped land in Rochford District performs many functions - it provides the setting for the settlements, gaps which prevent the coalescence of settlements, areas for informal and formal recreation, and pleasant countryside. Any encroachment of the Green Belt must be at a cost and should be avoided if humanly possible. If, however, the question is put another way, namely - should we safeguard the Green Belt rather than make provision for the various types of housing to meet the needs of our existing and future residents? - then a different response might be forthcoming. The prospect of housing shortages, with house shortages, with house prices driven up by scarcity value, and younger sections of the population finding it even more difficult to reach the first rung on the housing ladder, might be sufficiently unattractive a proposition to lead people to support a justified and carefully controlled release of parts of the Green Belt. We therefore welcome the fact that after many years of assiduous protection of Green Belt land, the Council has "grasped the nettle" and has clearly identified sound reasons why it is a Preferred Option to identify some Green Belt land for development.

Characteristics, Issue and Opportunities

We also found the section headed "Characteristics, Issues and Opportunities" to be a useful summary which painted an accurate picture of the current character and contemporary issues in Rochford District.

Economy

We do not consider the document sufficiently recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable. We note the paragraph which states "A high proportion of the Rochford workforce commutes out of the District. 30% travel to work in Southend, 14% to London, 9% to Basildon and about 15% travel elsewhere outside the District." In other words, 68% of the working population commute out of the District and only 32% work within the District. Even allowing for the high proportion that commute the relatively short distance to Southend, this represents a very heavy reliance on employment beyond the District's boundaries. The District is therefore highly unsustainable in this particular respect.

We note the references to Thames Gateway South Essex and to initiatives at Southend Airport, but consider that such employment growth will needs to be supplemented by a myriad of smaller and localized initiatives which are more likely to reduce the lengths of journey to work. At the same time, if well located, small business parks and enterprise areas would help counterbalance the lack of local employment which makes the District so heavily reliant on other areas. It would also reinforce the District's track record for thriving small businesses.

Settlements

We broadly support the four tiers of settlement with the first tier comprising Rayleigh, Rochford and Hockley as set out on page 20. We note, however, in "General Locations" on page 26, the first tier settlements are listed as Rayleigh; Rochford/Ashingdon; Hockley/Hawkwell. We have no difficulty with this but consider there should be consistency as to how settlements are addressed. For the avoidance of doubt, we prefer the approach adopted on page 26.

Vision

Again we register our support for the overarching vision and the key planning objectives. Without detracting from the high ideals expressed here, we would perhaps hope to see a much fuller explanation of how the vision is to be realised. Some reference to the types of measures or policy and proposals that will be introduced to implement the key planning objectives might be appropriate at this stage.

Housing

We consider the remaining balance of 2,489 units for the period 2001-2021 together with the further 1,000 units for the period 2021-2025 represents a substantial commitment requiring careful decisions in relation to its future distribution. We fully acknowledge the concern that can arise from town cramming and the difficulty posed by the rapidly dwindling supply of other brownfield land. We consider the Council can be justifiably proud of its record in directing a high proportion of recent growth to brownfield sites. However, this is a finite resource and it was inevitable that at some point it would be necessary to increase the Greenfield contribution. In the Council's view, that point has now been reached, and we agree with that. We note that the 30% of development that will still be targeted to brownfield sites is only half that advised in the East of England Plan, but that this lower level is probably realistic and hence deliverable. In any event, it is also important not to rely on regular reviews of the Green Belt boundary and this points to the need for long term land reserves needed for development being taken out of the Green Belt as part of the Core Strategy.

In moving towards the Preferred Distribution, we note the following on page 26.

"The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District."

We believe that is exactly the right approach but at this stage we have not seen the evidence to support this important claim. Indeed, the Preferred Options move rapidly into the topic of "Housing" without any clear demonstration of a comprehensive and holistic approach in terms of the distribution of the wider development needs of the District. In other words, we would expect to see a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles. We do not believe that general locations for new housing, for example, can be selected in isolation but that such decisions must reflect a pre-agreed framework of sustainability principles taking account of existing and all forms of new development requirements.

In turning to H2 General Locations and Phasing - Preferred Option, it is unclear what process of selection was undertaken to alight on this particular choice of area. No doubt each of the areas identified have their own particular merits and advantages, and some may be highly sustainable and other less so. It is difficult to pass judgement without any pre-stated basis for the inclusion of these particular areas. By the same token, the reasoning behind the split before and after 2015 is equally unclear. We do not oppose the principle of staging development - indeed we support it if this assists in ensuring land allocations are more evenly spread and hence available throughout the plan period. Again, however, we expect to see the reasoning for this split and this does not seem to be apparent. We raise these points because they are fundamental and there needs to be a clearly understood basis for the choice of general locations and for phasing. We have given careful consideration to the general locations set out in H2 and the alternative options set out giving reasons why these further locations were not preferred.

In particular, we note the inclusion in H2 of a location at West Hockley with a projected capacity of 50 units in the period to 2015. It would appear possible that this relates to potential capacity that might become available on land known as Pond Chase Nurseries. We have no specific objection to the inclusion of this site - but this would strengthen the case for a careful review of the Green Belt boundary in the general vicinity of Pond Chase Nurseries and Church Road, Hockley. The existing Green Belt boundary in this part of the settlement is highly arbitrary and has been blurred by development that has taken place on the edge of the town over a number of years. We refer to this matter again shortly in relation to the Green Belt.

Turning to H3 General Location Post-2021 Preferred Option, we consider there is a similar duty to justify the general locations and capacity for the areas identified. Whilst we note that: "The detailed location and development will be articulated within the Allocations Development Plan document and, where appropriate, Area Action Plans," this in no way reduces the need to ensure that the location itself is sustainable and can be justified as a Preferred Option. The information and analysis to support the general locations both pre and post 2015 and post 2021 is lacking and we consider this must go to the soundness of the Plan.

Affordable Housing

We take the view that much greater emphasis must be given in future to the delivery of affordable units, especially having regard to the high house values which preclude so many entering the housing market. We recognise that Exceptions Policies are necessary but deliver very little in terms of numbers. We also recognise that it is the larger sites that have the viability which enables a significant proportion of affordable units to be provided or cross-subsidised by free market housing. A judgement is needed as to the level of affordable provision that should be required from new sites. On balance we consider the suggestion that at least 35% of dwellings on all developments of 15 or more units, or on sites greater than 0.5 ha, should be affordable - gets the balance about right. We therefore support the wording of H4 Affordable Housing - Preferred Option in this respect and favour this to the Alternative Options in H4.

With regard, however, to the requirement to spread (pepper-pot) affordable dwellings throughout larger developments, we express certain concerns. We agree that large blocs of affordable housing should be avoided if possible but pepper-potting can give rise to design and management problems. As usual, these matters can normally be overcome through compromise having regard to the circumstances relating to each particular site. We would therefore prefer to see a more general reference to the need to avoid large blocs of affordable housing and the need to integrate affordable and free market housing in a harmonious way.

The Green Belt

As indicated above, we support the conclusion that the time has now come when the current boundaries of the Green Belt need to be reviewed to enable development required to be provided in Rochford District by the East of England Plan can be met in an environmentally acceptable way. Given the long-term nature of the plan period, the opportunity arises to adjust the Green Belt boundaries to facilitate growth over a long period and this should avoid the need for repetitive short term reviews which could undermine the confidence in the Green Belt. We note the wording of GB1 Green Belt Protection - Preferred Option and in particular the commitment to prioritise the protection of Green Belt land based on how well the land helps achieve the purposes of the Green Belt. Whilst this seems entirely clear and logical, we would expect this exercise to be conducted to inform the general locations identified in H2 and H3. Further uncertainty arises from the reference to "strategic buffers that are particularly worthy of mention" which appear not to be mentioned or featured on the Key Diagram. We consider any reference to "strategic buffers" should be deleted from the text as this function will continue to be achieved by means of the Green Belt.

The approach being adopted towards the release of Green Belt land for development may be sound as a general principle but we would expect to see clear evidence to support the general locations for growth in terms of their relative impact on the purposes of the Green Belt. There would appear to be a lack of joined up thinking between the Preferred Options in H1 and H2 and that in GB1.

In addition to the need to amend the Green Belt boundary to facilitate the selected General Locations, it is considered that a wider review of Green Belt boundaries should also be undertaken. There are many small scale opportunities to adjust and rationalise the Green Belt boundary which would enable various small sites to come forward without material conflict with the purposes of the Green Belt. We have already referred to one such general area, namely Church Road, Hockley, where a more appropriate urban edge could be defined. We believe it is important that both larger and smaller adjustments should be agreed to avoid regular nibbling at the Green Belt boundary which would undermine confidence in Green Belt policy.

Dwelling Types

Whilst we support the wish to ensure a mix of dwelling types to reflect a wide spectrum of housing needs and budgets, much will depend of the size of the particular development, the character of the area, and any other local constraints or factors. We therefore have certain reservations about a blanket policy requiring a housing mix. Such a mix may in any event be triggered by the requirement to provide affordable housing over and above the thresholds in H4. Our reservations might be overcome quite simply by inserting the words "Where appropriate," at the beginning of the text H5.

Rural Diversification, Green Tourism and Recreational Uses

We support the Council's aims to promote and secure a vibrant and prosperous countryside and one that encourages recreational uses. In fringe urban areas and particularly where development abuts the Green Belt boundary, opportunities should be explored to supplement formal and informal recreational provision as part and parcel of mixed use development sites. The opportunities for such provision should be one of the determining factors in the selection of locations for growth and subsequently at the Site Allocations DPD stage.

Future Employment Allocations

We generally welcome the initiatives set out to deliver increased employment provision to meet the needs of the District and its growing population over the plan period. We nevertheless have similar reservations to those expressed in relation to housing in terms of the proposals put forward. It is vital that housing and employment are considered jointly to ensure the best possible "fit" which would encourage new and more accessible employment opportunities. We would like to see evidence of the co-ordinated provision for housing and employment promoted through the growth locations put forward as Preferred Options. Again, this potentially calls into question the soundness of the plan.

Environmental Issues

We support the continuing protection of the District's natural landscape and habitats and hence we endorse the Preferred Options in ENV1 and ENV2. We consider some of the protective notations are sufficiently important to be denoted on the Key Diagram.

Flood Risk

Clearly the avoidance of areas prone to or at risk of flooding will be a key consideration in the choice of growth locations and later individual sites at the Site Allocations DPD stage. Any changes to the Green Belt boundary on the western side of Hockley, and particularly in the vicinity of Church Road, will not raise any flood risk issues.

Transport

We fully endorse the Preferred Options in T1 Highways and T2 Public Transport.

Community Infrastructure, Leisure and Tourism

With regard to CLT5 Open Space - Preferred Option, we have already indicated we see opportunities for providing Open Space for both formal and informal recreation in association with General Locations especially on the edge or within the Green Belt.

CONCLUSION

Whilst it will be seen that we have identified much to support within the text of the consultation document, we have expressed concerns in relation to the justification of many of the Preferred Options - particularly where these have Lane Use implications. Whilst not necessarily opposing any particular proposal, we have been unable to establish a paper trail which would convince us that such proposals are indeed justified in themselves or sufficiently tested. In some respects, the danger is that unless there is a clear testing of options against agreed criteria leading through a sieving process to establish the most appropriate locations for growth, then the process is not very different from the old style Local Plan system. It is this introduction of "better assessment" which is critical in terms of determining 'soundness'. An example of this crucial defect is the identification of General Locations requiring the loss of Green Belt land without any reference to the evaluation of the relative effects of that encroachment in relation to the purposes of the Green Belt. We believe these fundamental concerns need to be addressed in order to achieve reasonable confidence in the Core Strategy.

PART B: SCHEDULE OF REQUESTED AMENDMENTS

We set out below the main amendments we are seeking and suggesting to the Core Strategy Preferred Options some of which we believe to be necessary in order to make the document 'sound'.

1. Insert text which recognises the need to adopt a strategy which seeks to make the District more self-contained and hence more sustainable.

2. Supplement the main employment growth proposals with complementary proposals relating to smaller and localised employment initiatives likely to reduce the lengths of journey to work.

3. Refer consistently to Rochford/Ashingdon and Hockley/Hawkwell rather than just Rochford and Hockley.

4. Provide a fuller explanation of how the 'Vision' is to be realised through the implementation of the key planning objectives.

5. Provide evidence to support the claim that "The preferred distribution is based not simply on which areas are the most sustainable at present, but also on how residential development can contribute to, and marry with, other strategies - particularly in relation to town centre vitality, environmental issues and employment - to ensure long term sustainable development within the District".

6. Set out a coherent strategy which closely and geographically associates housing needs, employment and community facilities based on sound sustainability principles.

7. Demonstrate how the coherent strategy referred to in (6) above has informed the General Locations for new housing and other forms of development.

8. Provide supporting evidence to justify the locations and capacity for the release of land pre- and post-2015 and post 2021.

9. Amend text to delete reference to pepper-potting affordable housing and refer instead to the need to avoid large blocks of affordable housing and the need to integrate affordable and free-market housing in a harmonious way.

10. Explain the relative effects of the General Locations identified in H2 and H3 on the Green Belt.

11. Commit to undertake a comprehensive review of the Green Belt boundary to enable small sites to come forward for development at the Site Allocations DPD stage where this would not harm the purposes of the Green Belt, sepecially where a rationalisation of the boundary is justified.

12. Delete reference to "strategic buffers" as their purpose will continue to be achieved by the Green Belt.

13. Insert the words "Where-appropriate," at the beginning of H5.

14. Make explicit that opportunities should be explored for the provision of recreational and amenity land within or adjoining General Locations.

15. Provide clearer evidence to show a coordinated approach to the provision for housing and employment in order to meet the tests of soundness.

16. Consider including the more important rural and natural resource notations on the Key Diagram.

I have been instructed to forward representations of behalf of my clients Robinson and H R Philpot & Sons (Barleylands) Ltd.

Attached are responses to the Rochford LDF Core Strategy Preferred Options October 2008 concerning:

H2 General Locations and Phasing - Preferred Options
H3 General Locations Post 2021 - Preferred Options
H Appendix 1
ENV2 Coastal Protection Belt - Preferred Options
ED2 Employment Growth - Preferred Options
CLT5 Open Space - Preferred Options
Hullbridge Expansion drawing B.9006/a

I look forward to confirmation of receipt for these representations from the Council which have not been submitted online.

Preserving existing public open spaces, and other green spaces is essential in retaining the character of local areas.

Rayleigh Town Centre is seeking to identify land in the town for the possible provision of an additional allotment site. There may be scope for working with a developer to achieve this aim.

There is very little playspace provision in south west Rayleigh at present. Even though the proposed location of new housing development is not ideal for providing a play area in a central location in this part of Rayleigh, which could be easily accessed by residents of existing dwellings as well as the proposed new development, any play space provision would nonetheless be of value.

There is scope to link new public open space provision in west Rayleigh/Rawreth with existing public open space, to create a larger more valuable amenity.