Policy H2 - Extensions to residential envelopes and phasing

Objection to Rochford Core Strategy 175 houses in Hawkwell.

This letter is to register our objection to the proposed new development in Hawkwell West, as detailed above and we would expect these objections are taken into account prior to any decisions being made. The objections are as detailed below:

The proposed development would increase pressure on the already limited public transport system and the increased car usage would cause additional heavy conjection on local roads. The distance from both shops and rail stations is again totally unacceptable as is the inability to improve highways.

The impact on the environment is also unacceptable with the obvious loss of green belt and wildlife that depends on it. A large development in our semi rural location can only have an adverse affect on our community and would cause a significant downturn in the local character of the area.

Additionally the development would have no social, economic or environmental benefits whatsoever and in that basis the whole idea should be scrapped. I believe that our objections show the proposed development is in direct conflict with the Rochford Core Strategy.

I am writing to object to the above proposal as so many new houses in the ward of Hawkwell West is UNSOUND because the vital requirements of PPS 12 are not met in terms of sustainability and therefore the location of Hawkwell West should be removed by the Inspector and the allocation moved to a sustainable location. My reasons are as follows:

We have limited public transport with only one bus an hour between Rayleigh and Southend. There is little or no possibility that this situation will change in the long term. The railway station is not within comfortable walking distance of the planned site. The local shops are not close by. Because of these factors, transport by car will be vital and the existing roads are already over congested and will not be able to sustain the extra volumes of traffic generated by such a large number of new houses.

Hawkwell is a beautiful semi-rural area which will be destroyed by the loss of valuable green belt. The population would be greatly increased almost overnight and the character of this village would be destroyed. There is currently an abundance of varied wild life living on the planned site which would be lost forever. To sum up, there are NO social, economic or environmental benefits whatsoever with regard to this plan.

In addition the Core Strategy is UNSOUND because it does not fulfil the principles expressed therein as follows:

The Core Strategy talks about protecting the character of existing settlements and specifically 'seeks to take advantage of development opportunities that will provide social, economic and environmental benefits'. No such benefits would apply to this location and development would be materially detrimental to the character of Hawkwell West. It also states 'there is a limit to how much infilling and intensification existing settlements can sustain without their character being adversely affected'. This limit has already been exceeded in Hawkwell West.

The Core Strategy says 'locate development in areas where alternatives to car use are more viable'. As stated above, this is not possible in Hawkwell West. The Core Strategy also states that 'planning should be well related to existing public transport where possible', 'reduce the requirement to travel' and accompany any development with requisite highway infrastructure to 'mitigate their impact on the existing network'. There is no space in Hawkwell West for the development of local roads. As I have already explained above, there is little likelihood that public transport in this area would be improved. Finally, such a large scale development would lead to an unwelcome accumulation of new build houses disproportionate to the area which is not in line with Council policy.

175 new houses in Hawkwell (Rochford Core Strategy)

We are writing to lodge our objections to the above as we believe these proposals to be unsound.

Under the Governments planning policy the terms of sustainability have not been met.

The Councils strategy provides opportunities for envirnonmental, economic and social benefits but there would be no such benefits for Hawkwell under these schemes.

As regards travel, there is no way to mitigate the use of the car as the railway station is not within walking distance for many people. The public bus service is not an alternative and is not customer friendly and unlikely to be much improved in the future.

To summaries:

1 - loss of green belt and wildlife
2 - no benefits for Hawkwell residents
3 - loss of parish character
4 - large development not required (Hawkwell already has the most populated area in the district)
5 - not possible to improve roads (already heavy congestion)
6 - insufficient public transport
7 - distance from amenities

The proposal in the Rochford Core Strategy for this many houses in the Ward of Hawkwell West is unsound because the vital requirements of PPS12 are not met in terms of sustainability, and therefore, the location of Hawkwell West should be removed by the Inspector and the allocation moved to a sustainable location. In summary the reasons that development in this location is unsustainable under PPS12 are as follows:

TRAVEL

limited public transport
increased car use causing heavy congestion
inability to improve highways
distance from shops
distance from rail stations

ENVIRONMENT

semi rural location unsuitable for large development
complete loss of character
loss of green belt
loss of wildlife
NO social, economic or environmental benefits whatsoever.

In addition the Core Strategy is UNSOUND because it does not fulfil the principles that are expressly stated in the Core Strategy as it relates to the proposal for Hawkwell. Please see the following:

The Core Strategy talks about protecting the character of existing settlements and specifically 'seeks to take advantage of development opportunities that will provide social, economic and environmental benefits'. No such benefits would apply to this location and development would be materially detrimental to the character of the existing settlement in Hawkwell West. It also states 'there is a limit to how much infilling and intensification existing settlements can sustain without their character being adversely affected'. This limit has already been exceeded in Hawkwell West.

The Core Strategy talks about protecting the character of existing settlements and specifically 'seeks to take advantage of development opportunities that will provide social, economic and environmental benefits'. No such benefits would apply to this location and development would be materially detrimental to the character of the existing settlement in Hawkwell West. It also states 'there is a limit to how much infilling and intensification existing settlements can sustain without their character being adversely affected'. This limit has already been exceeded in Hawkwell West.

The Core Strategy says 'local development in areas where alternatives to car use are more viable reduce the requirement to travel', and accompany any development with requisite highway infrastructure to 'mitigate their impact on the existing network'. It is not possible to do this in Hawkwell West as there is no space for development of local roads, especially in Rectory Road, and any development here would increase the requirement to travel, especially by car. Moving on to Public Transport the Core Strategy states that 'planning should be well related to existing public transport where possible'. There is just one bus to and from Southend/Rayleigh per hour with no prospect of Arriva providing an appropriate service in the long term.

Finally such a large scale development would lead to an unwelcome strip coalescence of built settlements which is not in line with Council policy.

We are writing to object against the above application for planning permission in Hawkwell. The proposal in the Rochford Core Strategy for this many houses in the ward of Hawkwell West is unsound because the vital requirements of PPS12 are not met in terms of sustainability and therefore should hot be under consideration for a housing development and a new SUSTAINABLE site should be sought. Our reasons for objection are as follows:

Traffic issues - A proposal of 150 houses - many households have two cars or more - this at the minimum of 2 cars per household lead to an extra 300+ cars on the road. There is already congestion at peak times at the mini-roundabout junction of Rectory Road and Main Road.

Distance from shops - the main shops at both Hockley and Golden Cross are a half hour walk away - we are encouraged to shop locally and try not to use cars but this development would only mean more use of cars.

Distance from rail stations - again both Hockley and Rochford Station are a distance from proposed development.

There is very limited access to public buses - just one bus per hour to/from Southend/Rayleigh.

The core strategy says 'locate development in areas where alternatives to car use are more viable', 'reduce the requirement to travel', and accompany any development with requisite highway infrastructure to 'mitigate their impact on the existing network'. It is not possible to do this in Hawkwell West as there is no space for development of local roads, especially in Rectory Road and any development would only increase the requirement to travel by road (examples testify to this as per above bullet points).

Environment issues - loss of greenbelt, loss of wildlife habitats, area is characterized by having rural areas - local people appreciate this aspect of living in Hawkwell West - this development gradually erodes the rural element and we end up with a sprawling urban environment which becomes the blight of small parishes across the country. We DO NOT want this to happen in Hawkwell West.

The core strategy talks about protecting the character of existing settlements and specifically 'seeks to take advantage of development opportunities that will provide social, economic and environmental benefits'. We cannot see what such benefits would occur if this development goes ahead. Social benefits? More and more people living on top of one another? Economic benefits? Short-term jobs for builders - a housing development does not generate jobs or income - it is purely a residential dwelling site. Environmental benefits? Destroying existing wildlife habitats and reducing 'green spaces'. People need and enjoy their green and rural spaces. Research has shown the proven psychological health benefits in having access to green spaces and any 'pockets of green space' should be protected accordingly.

Health Services - local primary health care services ie doctors/dentists already running at full capacity - especially with an increasing older population - this development would only add to the pressure of booking in with these services.

Schools - again pressure is put onto local schools with already large class numbers especially if residents with to exercise their right for their children to be allocated a place within their catchment area.

For all of the above reasons, we strongly object to the application for planning permission for a housing development by David Wilson Homes.

The proposal in the Rochford Core Strategy (this is the RDC Policy for local development) for this many houses in the Ward of Hawkwell West is UNSOUND because the vital requirements of PPS12 (this is the Government's Planning Policy) are not met in terms of sustainability, and therefore, the location of Hawkwell West (South Hawkwell) should be removed by the Inspector and the allocation moved to a sustainable location. In summary the reasons that development in this location is unsustainable under PPS12 are as follows:

TRAVEL

limited public transport (recently depleted bus service)
increased car use causing heavy congestion. Congestion is already being experienced in area at certain times of the day
improved highways would not be possible
distance from shops
distance from rail stations

ENVIRONMENT

semi rural location unsuitable for large development
complete loss of character
loss of green belt quite unacceptable
loss of wildlife
NO social, economic or environmental benefits whatsoever.

In addition the Core Strategy is UNSOUND because it does not fulfil the principles that are expressly stated in the Core Strategy as it relates to the proposal for Hawkwell. Please see the following:

The Core Strategy talks about protecting the character of existing settlements and specifically 'seeks to take advantage of development opportunities that will provide social, economic and environmental benefits'. No such benefits would apply to this location and development would be materially detrimental to the character of the existing settlement in Hawkwell West. It also states 'there is a limit to how much infilling and intensification existing settlements can sustain without their character being adversely affected'. This limit has already been exceeded in Hawkwell West.

The Core Strategy says 'locate development in areas where alternatives to car use are more viable', 'reduce the requirement to travel', and accompany any development with requisite highway infrastructure to 'mitigate their impact on the existing network'. It is not possible to do this in Hawkwell West as there is no space for development of local roads, especially in Rectory Road, and any development here would increase the requirement to travel, especially by car. Moving on to Public Transport the Core Strategy states that 'planning should be well related to existing public transport where possible'. There is just one bus to and from Southend/Rayleigh per hour with no prospect of Arriva providing an appropriate service in the long term.

Finally, such a large scale development would lead to an unwelcome strip coalescence of built settlements which is not in line with Council policy.

Objection to Rochford Core Strategy 175 houses in Hawkwell is UNSOUND.

We strongly object to the building of 175 houses in Hawkwell for the following reasons:

1. There is very limited transport for existing residents already and none for a further 175 houses and their families.

2. We are already at breaking point with congestion on the roads and any increase in car numbers would bring the roads in the area to a stand still.

3. There has been no improvement to our highways for some time.

4. The area designated is some distance away from any shops and impossible on foot.

5. The rail station is also too far to walk to, ...more road congestion. As well as parking nuisance.

The core strategy will ruin the character of the area and would be of no benefit whatsoever to the existing settlement in Hawkwell West. It is already over developed and crowded.

The area is semi rural...we need our green belt. We see the development bringing no social or economic benefit.

RE: OBJECTION TO ROCHFORD CORE STRATEGY, 175 HOUSES IN HAWKWELL IS UNSOUND

We are writing to strongly oppose the above proposed build and insist that development in this location is unsustainable under PPS12 and list our reasons for this below:

Travel

limited public transport
increased car use causing heavy congestion
inability to improve highways
distance from shops
distance from rail stations.

Environment

semi rural location unsuitable for large development
complete loss of character
loss of green belt
loss of wildlife
no social, economical or environment benefits whatsoever.

Another issue is the high rate of new families that would be moving into the area and the repercussions this may cause to the intake levels available at Schools in the surrounding areas because of the extra influx of children to the area.

The proposal for 175 additional homes in South Hawkwell clearly indicates a lack of sensible thought by Rochford Council and is totally UNSOUND.

Increased congestion on Rectory Road, which is already impassable during rush hour periods.
No real public transport available in Hawkwell.
Semi rural location totally unsuitable for developments of this size.
No proven need for new homes in Hawkwell.
Loss of green belt.
No social, economic or environmental benefits whatsoever.
Rectory Road already floods during heavy rain, any developments will only exacerbate this problem.
LDF clearly does not conform to government guideline PPS12 for sustainable development.
Use available brown field sites instead.

The plan is unsound, The farmland should be protected from urban sprawl of West Rayleigh. There will be no natural stopping point until a1245. There are alternate brownfield sites. Plan is meant to protect 'community identity and character'. The building will put unsustainable pressure on Rawreth and rayleighs roads and amenities

We object to this policy as it fails to recognise the ability to accomodate signficant development South of Rayleigh at Eastwood Nurseries. Land is available in this location which can support housing and the necessary infrastructure including a school. This area is closer to existing urban centres than other sites detailed and has strong links with nieghbouring districts where a large proportion of the population commute to for work. Cycle links are already established with employment areas. Green links can be developed with this site and neighbouring Castle Point and Cherry Orchard Jubilee Park open spaces.

The proposal for development in Rectory Road, Hawkwell West (aka Hawkwell South) is unsound due to non-compliance with the District Councils own criteria in 4.19 of section H1 of the Core Strategy. namely,
* proximity & relationship to existing centres, facilities and services - apart from leisure facilities
provided by Clements Hall Leisure centre, there are no other local facilities or services
available, Main shops too distant to walk to as are the railway stations in Hockley and
Rochford. Virtually no bus service (1 bus per hour which is unreliable to time, none in evening)

* availability of infrastructure - the infrastructure is insufficient to support development of the
proposed size in this location. There is traffic congestion now causing delays for people both
travelling from Hawkwell to Southend or Rayleigh and motorists who use these roads
as "through roads" from Southend/Rochford to the A130 to access the A127 and A12. There
is a lack of dentists in the area and the schools cannot support more children. Also, all
the "local" schools are not within walking distance.

* potential to reduce private car dependency - this is not possible due to the location in relation
to the schools, doctors, shops etc. and lack of bus services

*impact on highway network etc - the impact would be horrendous. Queues of traffic exist now
during the morning and evening "rush hours" along Rectory Road, Hall Road and Main Road. If
the traffic travels easterly along Rectory Road to Ashingdon Road, this is already congested
the length of Ashingdon Road, through Rochford to Southend.

A development on this site will not bring social, economical or environmental benefit to the area.

re- North of London Road, Rayleigh

Unsound, farmland should be saved, because:-
prevents unrestricted sprawl from western Rayleigh
safeguards countryside (once building starts no stopping point until A1245)
other 'Brownfield' sites could be used
plan is supposed to protect 'community identity and character', but this plan doubles population of Rawreth.
building here puts UNSUSTAINABLE pressure on Rayleigh's roads and amenities
in last 25 years about 665 extra dwellings have been built on roads off Rawreth Lane

Apart from West Rochford, all other extensions are unsustainable. South Hawkwell extension would result in the coalescence of existing settlements contrary to para 4.19. The chosen locations are not jusitified in sustainablility terms. The infrastructure requirements set out in appendix 1 are vague and therefore provision cannot be monitored. Policy does not conform with national policies and RSS and therefore not sound or legally compliant.

Object to 220 houses on Rawreth Industrial Estate & 550 houses North of London Road Rayleigh.

Building on farmland allows unrestricted urban sprawl of Western Rayleigh with no natural stopping point until the A1245. The plan would not protect the community identity and character of Rawreth, as it would double the population.

Building in this area would put unsustainable pressure on Rayleigh's roads and amenities, the local roads are gridlocked when any minor traffic incidents occur. This part of Rayleigh has had a large number of houses built in the last 20 years.

The parish council hopes that there will be a chance to discuss/consult any proposed sites for housing. The one at the top of Chruch Hill, Canewdon, throws up many problems for the church.

We welcome recognition of the need for a five-year land supply.

Whilst the recognition to release green belt land is supported, the proposals to release significant quantities of development in second and third tier settlements below more sustainable settlements like Hockley are unsound. Furthermore the approach is contrary to the RSS policy framework and the provisions of sustainable locations for housing growth espoused in PPS1 and PPS3. The Council's own evidence and lack of strategic evidence on infrastructure and impact on European Habitats further undermines the effectivness of Policy H2 as drafted to be the most sustainable option.

The proposal for the Ward of Hawkwell West (South Hawkwell) is UNSOUND because the vital requirements of PPS12 are not met in terms of sustainability, and, therefore, the location should be removed by The Inspector and the allocation moved to a sustainable location.

In summary, this location is unsustainable because of travel (limited public transport, increased car use causing heavy congestion, inability to improve highways, distance from shops and distance from rail stations) and environment (semi-rural location, unsuitable for large development, complete loss of character, loss of green-belt, loss of wildlife and NO social, economic or environmental benefits whatsoever).

Whilst the principle of extending the residential envelope is supported, the amount of development identified for land to the north of London Road, Rayleigh, in the period 2015 - 2021, particularly when major new infrastructure is needed, is not supported. PPS3 advocates making the best use of existing resources which should be utilised ahead of making new provision. There is capacity at existing primary schools in other areas of Rayleigh i.e. to the south-east, along with suitable housing land, which subject to a Green Belt review, could provide a sustainable urban extension to the town.

Policies H2 and H3 should deliver growth by extending existing settlements and Council's overall approach should be encouraged. Fundamentally, the detailed locations and quantum of development should be articulated within the Allocations DPD.

We cannot support the key diagram or the detailed descriptions for the locations of future development contained in policies H2 and H3 as the proposed extensions to residential envelopes pre and post 2021 are too site specific. It is considered that the Core Strategy should identify land at Hullbridge as a growth location and not specifically land South-West of Hullbridge.

We agree, WITH THE EXCEPTION of the following:

It is felt that without additional infrastructure the allocation of number of dwellings proposed for settlement in the Rochford vicinity, it is disproportionately higher, compared to that of other major settlements.

The proposal in the Rochford Core Strategy (this is the RDC Policy for local development) for this many houses in the Ward of Hawkwell West is UNSOUND because the vital requirements of PPS12 (this is the Government's Planning Policy) are not met in terms of sustainability, and, therefore, the location of Hawkwell West (South Hawkwell) should be removed by The Inspector and the allocation moved to a sustainable location. In summary the reasons that development in this location is unsustainable under PPS12 are as follows;

Travel
- limited public transport
- increased car use causing heavy congestion
- inability to improve highways
- distance from shops
- distance from rail stations

Environment
- semi rural location unsuitable for large development
- complete loss of character
- loss of green belt
- loss of wildlife
- NO social, economic or environmental benefits whatsoever

In addition the Core Strategy is UNSOUND because it does not fulfil the principles that are expressly stated in the Core Strategy as it relates to the proposal for Hawkwell. Please see the following;


The Core Strategy talks about protecting the character of existing settlements and specifically 'seeks to take advantage of development opportunities that will provide social, economic and environmental benefits'. No such benefits would apply to this location and development would be materially detrimental to the character of the existing settlement in Hawkwell West. It also states 'there is a limit to how much infilling and intensification existing settlements can sustain without their character being adversely affected'. This limit has already been exceeded in Hawkwell West.

The Core Strategy says 'locate development in areas where alternatives to car use are more viable', 'reduce the requirement to travel', and accompany any development with requisite highway infrastructure to 'mitigate their impact on the existing network'. It is not possible to do this in Hawkwell West as there is not space for development of local roads, especially in Rectory Road, and any development here would increase the requirement to travel, especially by car. Moving on to Public Transport the Core Strategy states that 'planning should be well related to existing public transport where possible'. There is just one bus to and from Southend/Rayleigh per hour with no prospect of Arriva providing an appropriate service in the long term.

Finally, such a large scale development would lead to an unwelcome strip coalescence of built settlements which is not in line with Council policy.

- the proposal for 550 houses on 'land north of London Road" is UNSOUND.

As stated in paragraph 6.1 , The national "Planning Policy Guidance Note 2 - Green Belts" ("PPG2") states that the five purposes of including land within the Green Belt are as follows:
* To check the unrestricted sprawl of large built-up areas;
* To prevent neighbouring towns from merging into one another;
* To assist in safeguarding the countryside from encroachment;
* To preserve the setting and special character of historic towns; and
* To assist in urban regeneration, by encouraging the recycling of derelict and other urban land
The Green Belt land "north of London Road " is needed for all five purposes:
* It prevents the unrestricted sprawl of western Rayleigh
* It provides a barrier to prevent the ultimate merging of Rayleigh , Rawreth and Wickford.
* It safeguards countryside from encroachment by providing a defensible Green Belt boundary
* It enables an attractive setting of the historic centre of Rayleigh to be seen from the west.
* It should indeed be retained, in order to encourage the use of other 'brownfield sites' which are available but excluded from the plan.

So this land should therefore be RETAINED as Green Belt and the plan as proposed is unsound and contrary to national policy. The proposed use of the adjoining Rawreth Industrial estate for 220 homes (policy ED3) provides a suitable number of new dwellings for this location.

We believe it to be unsound; the chosen green belt in the north of Rayleigh is not the best location for hundreds of homes. The impact of housing within the green belt could be reduced if more suitable small green belt sites are included. There is a suitable site to the south of Rayleigh adjoining the residential area of Weir Farm Road, Hollytree gardens, Kingswood Crescent and Western Road, where a number of homes could be built. No coalescence with a neighbouring community would exist and it could provide positive community benefits including a primary school as in CLT2.

Much of the land "north of london road" is within the parish of Rawreth which is shown as tier 4 in the settlement hierachy on page 33 but is assumed to be an extension of the settlement of Rayleigh .This is untruthfull and therefore onsound .

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This submission is made on behalf of the West Rochford Action Group and its members. Further details sent under separate cover: email and by hand.
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H2 Extensions to residential envelopes and phasing.

1. Loss of Green Belt
West Rochford has been identified as bearing the largest extension to the current residential envelope with the proposed loss of greenbelt land to accommodate a total of 600 homes by 2021. This cannot be said to be a balanced strategy (para 4.18) when considering the population statistics (para 2.21) which places the settlement tier of Rochford/Ashingdon 3rd in terms of size behind Rayleigh and Hawkwell/Hockley.

The proposal to reallocate Green Belt land for housing on such a large scale (more than 50% of the housing proposed to be on land currently Green Belt) cannot be viewed as having a minimal impact. The Town and Country Planning (Green Belt) Directive 2005 final regulatory impact statement when considering the size of development that would be potentially harmful to the green belt and should require referral to the Secretary of State states (para 21) that a site which roughly equates to ten new, average-size dwellings broadly represents the scale of development around which there is the potential for significant impact on the openness of the Green Belt.

PPG2 provides the Governments policy on Green Belts and the intentions of the policy are set out in para 1.4:-
The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the most important attribute of Green Belts is their openness. Green Belts can shape patterns of urban development at sub-regional and regional scale, and help to ensure that development occurs in locations allocated in development plans. They help to protect the countryside, be it in agricultural, forestry or other use.

The purpose of including land in Green Belts is set out at 1.5 :-
* to check the unrestricted sprawl of large built-up areas;
* to prevent neighbouring towns from merging into one another;
* to assist in safeguarding the countryside from encroachment;
* to preserve the setting and special character of historic towns; and
* to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

PPG2 para1.6 states:-
Once Green Belts have been defined, the use of land in them has a positive role to play in fulfilling the following objectives:
— to provide opportunities for access to the open countryside for the urban population;
— to provide opportunities for outdoor sport and outdoor recreation near urban areas;
— to retain attractive landscapes, and enhance landscapes, near to where people live;
— to improve damaged and derelict land around towns;
— to secure nature conservation interest; and
— to retain land in agricultural, forestry and related uses.

The proposals in the Core Strategy in relation to Green Belt land do not comply with these objectives and will lead to urban sprawl particularly in the area of West Rochford.

Although not site specific the Key Diagram attached to the Core Strategy shows a triangle of land immediately west of Oak Road as proposed for development and further research has demonstrated this to be the case.

This area has a particular character which will clearly be lost if large scale development is permitted. PPG2 states at para 2.6 that once the general extent of a Green Belt has been approved it should be altered only in exceptional circumstances. If such an alteration is proposed the Secretary of State will wish to be satisfied that the authority has considered opportunities for development within the urban areas contained by and beyond the Green Belt. Similarly, detailed Green Belt boundaries defined in adopted local plans or earlier approved development plans should be altered only exceptionally. Detailed boundaries should not be altered or development allowed merely because the land has become derelict.

A need for such a large number of homes has not been demonstrated and in April 2001 there were 761 empty dwellings in Rochford and the trend has shown an increase in vacant dwellings as by April 2006 there were 996 empty homes which indicates that demand has plateaued. Furthermore two developments designed and built especially for the elderly in Rochford prior to the economic problems still have units unsold.

2. Agricultural Land
In so far as any development proposals include agricultural land the need has to be observed of the future requirements of feeding the country in view of the serious concerns for world food shortages and the estimated large increase in the population of the world and particularly this country. It will not be environmentally acceptable to pursue a policy of importing food which could be grown in this country. Sent under separate cover (email), is an article from the business edition of the Daily Telegraph dated 13th October 2009 and stressed in that article is the second paragraph which refers to the shortage of quality farmland as the global population expands. The agricultural land on the north side of Hall Road is top quality (Grade one) and is a prime example of land which will be needed in the future.

3. Social Housing
The Housing Waiting list statistics shown at para 2.38 of the consultation document shows 44.4% of the demand for social housing to be located in Rayleigh against 29% for Rochford. There is therefore a greater need for social housing in Rayleigh and the Core Strategy does not indicate that a greater proportion of social housing will be provided in Rayleigh. Furthermore no statistics have been provided in respect of the Housing Waiting List so it is unclear as to the exact extent of the need for social housing in the district

PPG2 para 3.2 states:-
Inappropriate development is, by definition, harmful to the Green Belt. It is for the applicant to show why permission should be granted. Very special circumstances to justify inappropriate development will not exist unless the harm by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations. In view of the presumption against inappropriate development, the Secretary of State will attach substantial weight to the harm to the Green Belt when considering any planning application or appeal concerning such development.
3.4 The construction of new buildings inside a Green Belt is inappropriate unless it is for the following purposes:
— agriculture and forestry (unless permitted development rights have been withdrawn;
— essential facilities for outdoor sport and outdoor recreation, for cemeteries, and for other uses of land which preserve the openness of the Green Belt and which do not conflict with
the purposes of including land in it;
— limited extension, alteration or replacement of existing dwellings;
— limited infilling in existing villages, and limited affordable housing for local community needs under development plan policies according with PPG3,
— limited infilling or redevelopment of major existing developed sites identified in adopted local plans, which meets the criteria in paragraph C3 or C4 of Annex C1.
As land proposed to be developed is in the Green Belt these policies should apply to the proposals for reallocation.

4.Roads and Transport
Traffic congestion in Hall Road and on the outskirts of Rochford town is a frequent occurrence particularly at peak times. Additional development in west Rochford on the scale proposed will force additional traffic on to both Hall Road and Cherry Orchard Way and thence on to the A127 or via Warners Bridge towards Southend Town Centre - both routes are regularly congested. The junction improvements proposed will not solve the issue because it was acknowledged in the East of England Plan paras 4.57 and 4.58 that in the morning peak period traffic flows on the A127 already exceed capacity in the westbound direction which is expected to become worse by 2031. It is also acknowledged that traffic flows already exceed capacity on several sections of the A13 and are forecast to increase further. There is currently no bus service serving Hall Road or Cherry Orchard Way. It was also acknowledged in the Core Strategy document that 84% of households have cars.

If the employment proposals north of Aviation Way which have been included as part of the airport expansion and development scheme proceed the traffic impact would be even worse. Furthermore the pedestrian access under the bridge at Rochford station already poses dangers to pedestrians particularly for those in wheelchairs and prams with no potential for access improvements. The increased traffic flow generated by development proposals will exacerbate the dangers.

Emergency services must be able to gain access to incidents and a significant further increase in traffic flows that will result from these proposals will jeopardise their effective operation.

A full transport assessment is required to ensure the provisions of PPG13 para 23 can be met before reallocating green belt land and ensure achievement of the key planning objective set out in para 19 of PPG13 to ensure that developments are accessible by public transport walking and cycling to promote social inclusion particularly for those who do not have regular use of a car. The emphasis in the Core Strategy on social housing provision makes this requirement particularly important. Para 40 of PPG13 requires that this same policy should be applied in rural areas where public transport is less available.

5.Water supply
Para 4.70 of the East of England Plan showed a deficit of -50 -20 mega litres per day and further acknowledges that unless the supply of water and related infrastructure is improved it will be a barrier to development from 2015. Any reallocation of sites should therefore be contingent upon the necessary infrastructure provision being secured. There are serious doubts as to whether this development can responsibly be pursued.

See supporting document, Council ref AE28

Policy H2 - Extensions to residential envelopes and phasing and Appendix H1

We acknowledge that this policy for the Core Strategy appropriately sets out the broad areas for extensions to residential envelopes and phasing. However it does not clearly identify the release of green field land and does not identify specific areas, although it is implied that this would involve redefining the Green Belt Boundary.

The identification to extend the existing settlement of Hockley is wholly supported. However the justification for the proposal to extend the envelope and phasing for only West Hockley is unclear. There is no objection to the principle of extending West Hockley; however the LDF should ensure that land allocations are evenly spread both throughout the plan period and throughout Hockley.

We support the proposed extensions to residential envelopes.

The Council intend to maintain a flexible approach on phasing of housing. We would suggest the policy would be made more sound if the indicative housing provision for each settlement were regarded as a approximate figure and that the final housing provision be established through the Allocations development plan document.

For consistency with other policies, including the Regional Spatial Strategy where the housing provision is identified as a minimum figure, Policy H2 should expressly state that the housing provision for each settlement represents the minimum housing provision.

Object to 220 houses on Rawreth Industrial Estate & 550 houses North of London Road Rayleigh.

This part of Rayleigh has been extensively developed over the last 1-15 years with the character of the area now changed dramatically. The area is now one big hpusing development and the roads are now very busy.

Since the development and construction of the additional houses on the old Reads Nursery sight, traffic in Downhall Park Way (especially from the junction with Rawreth Lane to Sweyne Park) is very busy and dangerous with cars parked all along the road and near junctions.

Additional traffic along Rawreth Lane will create further delays when using this area.

Any new housing should be developed in other parts of Rochford as rayleigh has now been overdeveloped.