4.19

DAVID WILSON DEVELOPMENT RECTORY RD IS UNSOUND BECAUSE IT FAILS TO MEET THE REQUIREMENTS OF
•The proximity and relationship to existing centres, facilities and services ,all local services shops are not within walking distance and very poor public transport from this area therfore increase in car use leading to increased pollution and congestions
•The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas , no plans to increase infrastructure and restricted by local environment.

•The potential to reduce private car dependency; exact opposite will lead to at least a 10% increase in daily traffic on b1013

•The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered) as above no potential improvements listed and damaging negative impact on highway network.

•The relationship of development locations to the District's areas of employment growth , will be commuter housing so adds little to local emplyment growth

not in keeping with local environment

Developing on land adjacent to Bedloes Avenue would be a 'location on the edge of settlements'. Hambro Nursery and Clovelly Works have been submitted as one site for housing.

Section: H1
Para 4.19. Bullet 9. The avoidance of coalescence with neighbouring settlements.

This Core Strategy submission states: "there is a need to avoid the coalescence with neighbouring settlements". This statement is unsound as it is being ignored in the case of Rawreth and Rayeigh.
The coalescence will occur in the vicinity of Rawreth Lane, which is a busy 2 mile stretch of road with approximately 1 mile in Rayleigh and 1 mile in Rawreth.
In the past 20 years, the Rayleigh section has had a number of new estates linked, by access roads, to it. A total of 665 new dwellings have been built on these estates during this period.
With the submitted proposal for an additional 770 dwellings (550 &220) 'North of London Road' and immediately adjacent the existing Rayleigh housing estates this can only be described as a blatant move to coalescence.

P43 Para 4.19 States that development should have the potential to create a defensible Green belt boundary.The proposal for 550 houses on land "north of London Rd" is unsound in that it creates a boundary that is difficult to defend until the A1245 road is reached. A better alternative would be to locate some proposed brownfield sites in Rawreth. The remainder could be located on smaller sites in Rayleigh which have been ruled out by the preference for this larger area.
.This would meet the guidance in PPG2 "to check the unrestricted sprawl of large built up areas" preventing the eventual coalescence of Rayleigh, Rawreth and Shotgate

4.19 Extensions to residential envelopes and phasing*
* The historical, agricultural and ecological value of land;
* The potential to create a defensible Green Belt boundary;
The proposed site known as 'North of London Road' is approximately 130 hectares of prime Green Belt land. The site is prime agricultural land and already forms a defensible Green Belt boundary.
Allocation of exactly where dwellings are to be erected on this site is not included in the document and the district council flatly refuse to make comment on this stating that at this stage they cannot be "site specific".
Such negativity creates uncertainty as to what part of the 130 hectares will be built on and therefore, as a resident, I find it difficult to make comment due to this lack of information. This in my view highlights yet another example of vagueness and unsound delivery.
This proposal should be made far clearer and identify such aspects as:
* How much of the Green Belt will be retained.
* The area the site will occupy.
* The actual location of dwellings.
* Type of dwellings, ie. houses or flats.
* Provision of road access and where exactly this will be. Will it result in 'rat- runs between Rawreth Lane and London Road?
* How the siting of dwellings will be arranged to avoid the flood areas already identified by the Environment Agency on their web-site
* The plans for dealing with surface water drainage and the direction of flow it will take to the River Crouch. Rawreth village already experiences fluvial flood problems from run-off water from this site.
* Will this development lead to the detriment or decline of the prime farmland it now is?
All of the above points have been raised during the consultation period but none appear to have been addressed or answered in the submission.

Developments should have "The potential to create a defensible Green Belt boundary". The proposal for 'housing north of London Road" creates an unnatural boundary that is not defensible and therefore the proposal is unsound.

Proposal for extra development in the Rawreth area does not comply with the points under consideration. The location is not well served with public transport or cycle routes, and it will encourage car dependancy. General infrastructure is already poor, and no significant improvements have been proposed. Flooding in the area is also an issue that will not be helped by the added development.

In identifying the settlements in which development should be directed, agree that residential development should avoid areas of constraint, including areas of risk of flooding.

Furhtermore, where land is released from the Green Belt to accommodate additional residential development, this should ensure that the resultant development creates a defensible Green Belt boundary, and does not result in the coalescence of neighbouring settlements.

ROCHFORD LOCAL DEVELOPMENT FRAMEWORK
CORE STRATEGY SUBMISSION DOCUMENT

Thank you for your letter dated 21 September 2009 consulting English Heritage on the above document. Our comments are set out below.

CHAPTER 4 HOUSING

Vision and objectives
While we note that character of place is addressed in chapter 5, it is important that this consideration is recognised as relevant within the Housing chapter. Paras 2.33, 2.69 and 2.73 also recognise the importance of character and sense of place in the built environment. We recommend that this consideration should be integrated into the vision and objectives for housing in order to improve the clarity of the plan, and its consistency with advice in PPS1.

Recommendation:
The following amendments are suggested:
- Vision in five years: add 'settlement character' after 'infrastructure'
- Vision by 2025: add 'and places' after 'communities' in bullet 1
- Objectives: In objective 2 amend to '...sustainable locations, enhancing sense of place and having regard to..'
- Para 4.19: Amend bullet 5 to read 'The historical, agricultural and ecological value of land, and settlement character'

CHAPTER 5 CHARACTER OF PLACE

We strongly support this section and policies CP1, CP2 and CP3. In the absence of policy coverage for listed buildings and scheduled monuments we recommend that para 5.9 should refer to PPGs 15 and 16, as well as draft PPS15.

CHAPTER 8 ENVIRONMENTAL ISSUES

We welcome the references the historic environment in the objectives and in policies ENV1 and ENV2.

Policy ENV6 Large Scale Renewable Energy Projects

We consider that this policy should refer to the historic interest of sites to reflect the advice in PPS22 more appropriately.

Recommendation: amend the first bullet in policy ENV6 to read '...it's ecological, historic or landscape value...'

CHAPTER 11 ECONOMIC DEVELOPMENT

Policy ED2 London Southend Airport
We understand that the grade I listed church in the vicinity of the runway will be protected in any proposals for expansion of the airport and the Core Strategy policy does not suggest otherwise. We will respond to the detail of proposals for the airport through responses to consultations on the Joint Area Action Plan and any planning applications.

In the interests of clarity, the above comments where we suggest changes to the Core Strategy should be recorded as objections to the soundness of the plan in terms of consistency with national guidance. However, we hope that it will be possible to agree amendments on these points prior to the public examination.

We would be happy to discuss any of these comments if you would find this useful.