CLT9 Leisure Facilities - Preferred Option

Developments will be scatterred across 12 or so sites. No information or costings provided on how these will be paid for. Standard Charges do not provide for cross-parish facilities.

this is not enough. current leisure facilities are too busy. for example, more swimming pools are required.

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))

Could anything be done to improve the external appearance of the Rayleigh Leisure Centre? It is hideous - a real blot on the landscape. From a distance it looks like an ugly industrial warehouse building.

It is to be hoped that if Rochford District Council is responsible for other public buildings in future, it will try to make them look attractive. One of the best ways a local planning authority can persuade developers to aim for excellence in design is by leading by example with public buildings.

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.

Core Strategy Preferred Options


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



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



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



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



RTC1 Retail and Town Centres

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



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



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



RTC3 Rayleigh Town Centre

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



CLT1 Planning Obligations

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



CLT9 Leisure Facilities

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



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



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



CLT11 Tourism

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



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





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