Policy H2 - Extensions to residential envelopes and phasing

The proposed releases of land for development at Hullbridge and Canewdon are considered to be unsustainable and therefore unsound. New housing should be directed to those areas with a close and more sustainable relationship with Southend including the second tier settlement of Great Wakering which is wrongly omitted as a location for expansion prior to 2021. Development to the south-west of Great Wakering would successfully relate to the Star Lane Industrial Estate which is earmarked under Policy H1 for residential use.

In our view, the Core Strategy is unsound because draft Policy H2 is neither justified nor consistent with National Policy.

Whilst our clients, Stolkin and Clements (Southend) LLP, agree that it is sound to designate green belt land for residential development; the areas designated in Policies H2 and H3 are not the most appropriate areas and land at Tithe Park, should be designated within Policy H2/H3 for c. 390 dwellings.

We have previously submitted a masterplan for Tithe Park during the preferred options consultation and this masterplan is provided again for information.

Consistency with National Policy

Policy H2 is unsound because it is not consistent with the following National Policy:-

PPS1 provides the overarching Government planning advice for the delivery of sustainable development through the planning system.

Paragraph 13 sets out the key principles:

(i) "Development plans should ensure that sustainable development is pursued in an integrated manner, in line with the principles for sustainable development set out in the UK strategy. Regional planning bodies and local planning authorities should ensure that development plans promote outcomes in which environmental, economic and social objectives are achieved together over time.

(ii) Regional planning bodies and local planning authorities should ensure that development plans contribute to global sustainability by addressing the causes and potential impacts of climate change - through policies which reduce energy use, reduce emissions (for example, by encouraging patterns of development which reduce the need to travel by private car, or reduce the impact of moving freight), promote the development of renewable energy resources, and take climate change impacts into account in the location and design of development."

Paragraph 16 of PPS1 confirms that development plans should address accessibility (both in terms of location and physical access) for all members of the community to jobs, health, housing, education, shops, leisure and community facilities. Paragraph 27 (v) reiterates this, stating that, in preparing development plan documents, planning authorities should seek to ensure that everyone can access services or facilities on foot, bicycle or public transport rather than having to rely on access by car, whilst recognising that this may be more difficult in rural areas.

Paragraph 20 confirms that development plan policies should take into account the protection of the wider countryside and the impact of the proposed development on landscape quality.

PPS3 sets out the national planning policy framework for delivering the Government's housing objectives. Paragraph 36 states that the Government's policy is to ensure that housing is developed in suitable locations which offer a range of community facilities and with good access to jobs, key services and infrastructure.

PPG13 sets out the Government's planning guidance on transport planning. Paragraph 4 sets out the following objectives:-

1. promote more sustainable transport choices for both people and for moving freight;

2. promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling, and

3. reduce the need to travel, especially by car.


In summary the Core Strategy is not consistent with the following two objectives of national policy:

• Minimising the need to travel
• Protecting the wider countryside and landscape quality

Minimising the need to travel

The Core Strategy Submission Document recognises that a high proportion of the Rochford workforce commutes out of the District, with 30% travelling to work in Southend (Paragraph 2.53).

It states that:-

"the strength of the spheres of influence of the large neighbouring centres of Southend, Basildon and Chelmsford means that traffic is drawn through Rochford District's own centres to them. This not only has an impact on traffic congestion in general, but also engenders concern with regards to air quality within the District's town centres." (Paragraph 2.62)

Paragraph 6.5 of the Core Strategy states that the Council recognises that diverting development and population growth away from rural areas to existing urban areas can assist in achieving sustainability objectives.

Draft Policy H2 proposes various extensions to existing settlements. However, these extensions will inevitably lead to increased car use from a greater number of commuters.

A more sustainable option is to provide a residential extension to Southend on the Tithe Park site.

As detailed in the 'Tithe Park' masterplan (August 2008), the site is within 10 minutes walk of the shopping and associated amenities of the Asda superstore, the local shops situated on the Broadway, Southend, and individual local shops within Shoeburyness. It is within 10 minutes walk of a number of primary and secondary schools. Furthermore, the site is within comfortable cycling distance of Shoeburyness Railway Station with direct links to London Fenchurch Street as well as local stops within Southend including Southend Central Railway Station from where the town centre amenities can easily be accessed. There are also bus stops situated to the south of the site along Eagle Way.

Tithe Park is therefore better connected than some of the other locations set out in Policy H2, for example, South West Hullbridge and South Canewdon, which is not within comfortable cycling distance of a railway station. It will also have no harmful impact on the traffic congestion within Rochford Borough which, some of the other locations suggested in the Core Strategy will as they are likely to be home to commuters to Southend who will travel to Southend everyday by motor car.

Protecting the wider countryside and landscape quality

Draft Policy H2 proposes several extensions to existing settlements. Whilst, the Core Strategy does not allocate specific sites, it is important that the locations set out in Core Strategy Policy H2/ H3 are able to provide sites which are well related to their settlement and do not impact on the surrounding landscape.

Tithe Park abuts the urban area of Southend to the south and west and therefore will have an acceptable impact in terms of the overall openness of the countryside.

Justification

Draft Policy H2 is not sufficiently justified because it is not the most appropriate strategy when considered against reasonable alternatives, as required by paragraphs 4.36 - 4.38 of PPS12 (Justification of Core Strategies). In particular, the proposed location of housing, as an extension to the Southend urban area, is a more sustainable option and therefore a more appropriate strategy.

The Strategic Housing Land Availability Statement (SHLAA) had not been published at the time of the submission version consultation, only a summary table had been produced. It is therefore impossible to understand how Draft Policy H2 is underpinned by this key part of the evidence base.

However, having considered the other documents in the evidence base, including the Strategic Environmental Assessment Baseline Information Profile 2008 - 2009, it is clear that Tithe Park should be considered sequentially preferable to the areas identified in Draft Policy H2. For example:-

• There are a number of local wildlife sites located to the west of Hockley;
• There are areas pf Ancient Woodland situated to the west of Hockley;
• West Great Wakering and South Canewdon is situated within the Crouch and Roach Farmland Landscape Area which has a higher landscape sensitivity than the Tithe Park site which is located within the South Essex Coastal Towns Landscape Area; and
• Depending on the sites chosen, there is a possibility that land south west of Hullbridge and east of Ashington will be in Flood Risk Zone 2 or 3

Given these findings it is clear that the proposed sites are not based on a robust and credible evidence base.

Support

We support the identification of land North of London Road, Rayleigh as one of the allocated growth areas/urban extensions in this policy.

We agree that development should be comprehensively planned, and support the principle of providing a range of other uses and infrastructure to serve any urban extension west of Rayleigh. However, such infrastructure must be reasonably associated with the impacts of the development. The scale and nature of such infrastructure that we could provide will be dependant upon the scale and nature of development accepted on the option land (see further representations below).

General amendments sought

Whilst we appreciate that the Core Strategy is not the vehicle to identify the precise boundaries of these residential growth/development areas, we do however consider that the key diagram is too vague and there should be a clearer identification of growth areas. It is not possible to ascertain the extent/location of likely development areas (not just North of London Road) and therefore their relationship to existing residents/road network etc. Therefore it is difficult to know what impact any such development will have on surrounding residents/the road network etc. The Core Strategy can be fairly specific in identifying sites, even if precise boundaries are not defined.

No appropriate density ranges are given within the Core Strategy, so again it is difficult to ascertain the likely land area required to achieve the number of units required/specified.

We believe that appropriate density ranges should be specified (a separate policy).
Our considerable experience of urban extensions indicate that typical density ranges are from 35 to 45 dwellings per hectare for a whole site, where these schemes also include large percentages of affordable housing.

Unsound: (i) not consistent with national policy (ii) not effective (not deliverable/not flexible) (iii) not justified

(1) We consider it unsound as drafted, on the grounds that it fails to be consistent with policy set out in the East of England Plan. Policy H1 of the RSS expresses housing requirements as minimum levels to be achieved and directs planning authorities to similarly express requirements as minimal. To provide certainty that the RSS housing targets will be met (although see representations below), the housing numbers specified in this policy should be expressed as minimums.

(2) We consider that in addition to the need to state that dwelling numbers are minimums, wording should also be added which states that "the actual amount of development will be determined by environmental and infrastructure capacity considerations, and the detailed consideration of master plans for each site", and that "there may be a possible requirement for greater housing numbers on some sites should other sources of housing, such as that on identified appropriate brownfield sites, not come forward as anticipated". We believe this to be a sensible and flexible approach. This will allow for appropriate flexibility in the plan.

(3) We argue that one or more of the greenfield sites identified for 2015 onwards should be brought forward in this policy, to ensure national/regional targets or annual targets are met. Whilst we recognize that the council "will maintain a flexible approach with regards to the timing of the release of land for residential development to ensure a five year supply" (bottom of Policy H2), we consider that there is enough evidence at this time to bring forward one or more of the Greenfield sites now.

Rather than repeat arguments put forward in our representations to Policy H1, we refer you to them in regard to our belief that required (RSS) 5 year housing targets will not be achieved because of an over reliance upon brownfield sites that we believe will not be delivered in the timescales anticipated by the council.

(4) Bearing in mind our representations regarding housing delivery rates and the over reliance placed upon and constraints associated with the development of identified brownfield sites (see policy H1 reps), we argue that as well as bringing forward one or more of the Greenfield sites identified in Policy H2 as 2015-2021, the number of units for one or more of the Greenfield sites be increased to make up for what we consider will be a shortfall in the delivery of housing on brownfield sites. We particularly recommend that because of the significant delivery constraints to the proposed redevelopment of the Rawreth Lane Industrial Estate, further housing units be identified for the land we promote, north of London Road, Rayleigh, as a replacement for the number of units identified for this industrial estate.

Again, rather than repeat arguments put forward in our representations to Policy H1 (see also Policy ED3 reps), we refer you to them in regard to our belief that required (RSS) housing targets will not be able to be achieved for the plan period because of an over reliance upon brownfield sites that we believe will either not be delivered in the timescales anticipated by the council, or may not come forward at all in the plan period.

(5) We refer to the infrastructure requirements for each site set out in Appendix H1, and referred to in this policy.

It should be made explicit that the level of infrastructure to be provided with a development will be reasonably related to the impact of that development. Circular 5/05 and the emerging/published DCLG guidance on the use of CIL, makes it clear that new developments/contributions from new development can not be used to resolve existing deficiencies (only, proportionally, those deficiencies made worse by new development).

Whilst some infrastructure requirements will be required to adhere to other council policies, it should be made clear that the majority of infrastructure requirements for each development site listed in Appendix H1 will be specified in future master plans/planning permissions when the precise impacts of the development are understood and assessed. It would be inappropriate to specify infrastructure requirements at this time when the precise scale and nature of development is not determined.

With regard to (2) to (4) above, we believe that the site we promote, with the addition of land under other ownership north of London Road (west of Rayleigh), can

A) Be delivered (in part) prior to 2015
B) Accommodate more than the identified 550 units

A) In terms of the land which we promote, there are no on or off-site hindrances to delivery that we are aware of in terms of infrastructure requirements e.g. no highway or service infrastructure constraints. The land we promote is in single ownership (to which we have an option), so there are no land assembly issues. Whilst other land ownerships north of London road could be included within the development of this area e.g. council owned sport pitch area, we are confident that there will not be any significant delay in bringing forward such land as part of a comprehensive development scheme for the area.

The site was in fact identified as being required by 2015 in the Preferred Options version of the Core Strategy, and we have received no justification from the council as to why it is now identified as being required for the period of 2015-2021.

We believe that development of our site could commence as soon as the site has a defined/adopted development allocation and boundary, and planning permission is granted. We are happy to discuss with the council the appropriate timing of submission of any planning application and how this would affect the timing of commencement of development/delivery of units. We are happy to fast track a planning application if the council consider this appropriate and would be required this to meet housing targets/needs.

We had set out a possible delivery timetable for the site we promote in our representations to the SHLAA consultation in April 2009. We suggested that for us to achieve the provision of 450 units (or a range of 400 to 500 units) by 2015 for example, planning permission would need to be granted by, at latest, early to mid 2012 (so an application submitted prior to the end of 2011). With time then required to achieve the submission and sign off of any pre-commencement requirements, and to account for a lead in time prior to commencement of infrastructure works, it is likely that development could then commence by early 2013 (first occupations prior to the end of that year).

We would currently envisage a build rate of between 200 to 250 housing units a year. This is of course dependant upon a number of factors, particularly regarding affordable housing delivery, such as the level of affordable housing grant available and location of such housing/pepper potting.

B) We believe that the land we have under option, on its own or with land north of London Road in other ownerships, can provide for more than 550 units.

In fact, 650 units were identified in the Preferred Options version of the Core Strategy. We have not been informed by the council (there is no explanation in the Core strategy) why the number identified for this area has been reduced. There is no reasoning/justification within the Core Strategy as to why the figure of 550 units has been chosen.

We consider the key factor in limiting the number of units is the issue of defining where the appropriate revised green belt boundary should to be set for the western edge of any development west of Rayleigh. We consider that there are a number of possible options for the green belt boundary, but a boundary could easily be drawn to enable enough land to be developed for a greater number of units, without further detriment to the landscape and character of the area, or without causing any coalescence with properties in Rawreth Village.

We are able, on the land under our option, to provide for a significant strategic gap or buffer between any new development and Rawreth village and the A1245. Significant green infrastructure could be incorporated into this space, and/or the land remain, in part, in agricultural use if considered appropriate. The nature and use of the strategic gap and location of open space will be determined through a master plan for the site.

We will work with the council to bring forward the strategic growth of land north of London Road as early as possible/appropriate to help ensure that the RSS targets are being met.

We consider that of the Greenfield sites identified in the plan, land north of London Road Rayleigh (land under our control) should accommodate greater numbers of dwellings.

The reasons for this is that Rayleigh, by far, is the most sustainable location for growth in Rochford, and land to the west of Rayleigh, north of London Road, the most appropriate, accessible and sustainable location for an urban extension to Rayleigh (as evidenced by its choice as the only urban extension to Rayleigh in the Core Strategy). Other possible sites considered for Rayleigh have serious policy, environmental or access/capacity constraints to delivery.

Rayleigh has the greatest variety and widest base of retail and other services of any settlement in Rochford. It also benefits from being the most accessible in terms of strategic highway links and capacity (particularly the western side of Rayleigh), and has the largest population and town centre. It has the highest housing waiting list demand and therefore probably the highest demand for affordable housing. With a new employment "park" also being identified for west of Rayleigh, a greater variety of job offers should also be available.

We are surprised that planned housing growth however, as set out in both policies H2 and H3, distribute numbers fairly evenly over first and second tier settlements, even though Rayleigh is clearly the largest and most sustainable town/location for development.

Combined (total) green belt allocations, set out in policies H2 & H3 lead to:

Tier 1
Rayleigh 550 units (2001 population 30,196)
Rochford/Ashingdon 1200 units (combined population 10,775)
Hockley/Hawkwell 225 units (combined population 20,140)

Tier 2
Hullbridge 500 units (pop 6,445)
Great Wakering 250 units (pop 5,512)

When you take into account that some of the larger identified brownfield development sites in Rayleigh are not likely to come forward in the plan period, particularly Rawreth Industrial Estate (220 units), there appears to be very little growth in Rayleigh when considered against other less sustainable towns/locations in Rochford. Whilst Rayleigh has experienced more growth in previous years than other towns, this is not a reason alone to direct larger development quantums to other, less sustainable locations.

Therefore, for the above reasons, we believe that the Core Strategy be amended to identify a larger allocation of dwelling numbers for land North of London Road, Rayleigh.

We agree with the general locations and phasing of residential properties over the plan period, however, in light of the current economic conditions and the need to maintain an adequate five year supply; the policy needs to adopt a flexible approach with regards the timing and release of land for residential development.

In order to ensure flexibility, this policy needs to make reference to Policy H3, in case the locations allocated under Policy H2 do not come forward in the required timeframe or deliver the required number of dwellings.

Fourth Paragraph - amend as follows:

The Council 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. If the locations within Policy H2 do not come forward in the required timeframe or deliver the required number of dwellings, then locations with Policy H3 should be brought forward to address this shortfall.

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 (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.

For all the aforementioned reasons, we have come to the conclusion that we
must strongly object to Rochford District Council's plans to allow 175 new houses to be built in Hawkwell.

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

Further to my previous Emails, your letter dated 14th September and an E-invitation from Kay Tinson, I wish to register, once again, my objections to the proposed development as captioned above.

The Rochford Core Strategy (RCS) proposal for the Ward of Hawkwell West is unsound because the location cannot sustain this many houses under the terms of the Government's Planning Policy PPS12.

The RCS is intended to protect the character of existing settlements and specifically '...seeks to take advantage of development opportunities that will provide social, economic and environmental benefits...'

However, it is difficult to see where any such benefits would arise from this settlement, whereas its detrimental effect on the character of Hawkwell is patently obvious.

The RCS states that '...there is a limit to how much infilling and intensification existing settlements can sustain without their character being adversely affected..' and yet this proposed development screams out as an example of plugging a green gap to complete yet another strip coalescence of built settlements in Hawkwell - using an unsustainable number of dwellings.

The Christmas Tree farm is part and parcel of Hawkwell West and is also a mini eco-system in itself. Building up this area would destroy another green area of Hawkwell with the resultant loss of character and wildlife, for the sake of an unsustainable and unbeneficial development.

The RCS intends to:

'..reduce the requirement to travel...'
have planning '...well related to existing public transport where possible...'
'..locate development in areas where alternatives to car use are more viable...' and
'...mitigate the impact on the existing network...'

However, the proposed development doesn't tick any of these boxes.

The requirement to travel, whether from 175 or 330 houses, will occur and remain because the site is near neither the shops, nor the railway station, nor any local amenities - with the exception of the leisure centre, which usually has a busy car park!

The planning for this site clearly doesn't relate to existing public transport since it is not within reasonable walking distance of Hockley or Rochford railway stations and Hawkwell is served by but one bus per hour, from Rayleigh and Southend h no immediate prospect for change).

Given the above, new residents will use their cars out of necessity and this will add to the horrendous congestion problem that altready exists on the B1013 Main Road in Hawkwell and Rectory Road. Such has been the increase in volume of traffic using the B1013 over the last few years - at all times of the day; not only during the rush hour and not only during the week - that it is becoming a question of if rather than when you can cross the road (on foot) or join the main highway from a side road (by car). I encounter both problems on a daily basis and I know that any additional traffic would inevitably exacerbate this problem.

Furthermore, there is no prospect of mitigating the impact of additional traffic because there is no room to develop the highway infrastructure on either of the aforementioned roads (B1013 and Rectory Road) which surround the proposed development.

In short, there is a piece of land in Hawkwell which could accommodate a number of new houses...but even the most basic research shows that in terms of location, environment, character and infrastrucutre, any development of that site would be unsustainable.

Therefore I suggest that the proposed development is UNSOUND.

Objection to Rochford Core Strategy 175 houses in Hawkwell is UNSOUND

I object to the above on the grounds of:

Limited public transport
Increased car use causing heavy congestion
Inability to improve highways
Distance from shops
Distance from rail stations

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

Further to our recent correspondence on this subject in September and to your letter dated 21 September 2009, concerning the Core Strategy Pre-Submission Consultation, my wife and I wish to re-affirm that 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 (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:

The public transport system in the Rectory Road area is totally inadequate, with buses to Rayleigh or Southend on an hourly schedule, in spite of repeated appeals to the bus company to considerably improve all services around this area, there is little response.

As nearly all of the schools, shops and railway stations are a considerable walking distance from the village, this means that the car is the regular means of transport to all of these places, which at certain times of the day already causes heavy congestion at the main junctions in Rectory Road. The proposal to build such a large number of houses in the middle of Hawkwell village, would increase the number of vehicle movements by possibly another 1500 per day, which would bring Rectory Road to a complete stanstill as there is no real possibility to widen or improve the other highways in the area. The increase in air pollution on people living along this road would be totally unacceptable.

Environment:

Our village of Hawkwell is in a semi rural location, which is unsuitalbe for a large development such as this. The proposal for a housing estate in the middle of the village, would be totally out of character within a lovely green belt area that has sustained the village for hundreds of years in different forms. The proposed area is a haven for all kinds of wildlife and to concrete over this area would be irresponsible and would surely cause untold flooding in the area, with only a small brook to accommodate the water which would naturally be absorbed in the woodland areas. Clearly there are no social, economic or environmental benefits whatsoever, to be gained by such a development in this area of natural beauty.

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 the existing settlements and specifically 'seeks to take advantage of development oportunities 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 Hawkll 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 requirements to travel' and accompany any development with requisite highway infrastrucutre 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.

In consideration of the aforementioned points, we trust that the council will reject any future development in the village of Hawkwell.

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

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 PPS12 are not met in terms of sustainability and therefore the location of Hawkwell West should be removed by the Inspection 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.

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

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 PPS12 are not met in terms of sustainability and therefore the location of Hawkwell West should be removed by the Inspection 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.

2. Objection to Planning Application of 330 houses by David Wilson Homes.

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

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 PPS12 are not met in terms of sustainability and therefore the location of Hawkwell West should be removed by the Inspection 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.

Re: Objection to the Core Strategy, 175 houses in Hawkwell is unsound.

I am writing to object to the proposed housing development in Hawkwell. I believe it to be unsound because of the requirements of PPS12 are not met in terms of sustainability. Therefore the proposal should be removed by the inspector and moved to a sustainable location.

It is unsustainable because of the following:

1. There is a very limited, and deteriorating, public transport service here.
2. There are already serious bottlenecks at the Rectory Road railway bridge and at Nursery Corner, ie either side of the proposed development site.
3. There are no alternatives for the increased numbers of vehicular movements and no prospect of road improvements.
4. There are no shops or railway stations within walking distance, therefore there will be even more vehicle movements. See 2 above.
5. We are in a semi rural loction here. It is not suitable for a large development. We have lost a large part of the identity and character of Hawkwell over the years because of the so-called Ribbon development and all the in-fill building that has been allowed and seemingly encouraged by RDC.
6. The loss of more Green Belt land is not acceptable.
7. There will be significant loss of wildlife and habitat. If not immediately then surely in the future. Learn the previous lessons from around the world that when we interfere with nature it always comes back to bite in one way or another.
8. I am unable to see any social or economic benefits within the proposed development. There is only one business close by that will gain, that being Clements Hall. Surely that gain will only be marginal.
9. This whole proposal is not in keeping with the existing core strategy. It does not benefit Hawkwell socially, economically or environmentally. It will intensify the housing density, affecting the character of Hawkwell. It is not related to existing public transport availability. It certainly will not reduce the requirement to travel or be any help to people already living in Hawkwell that travel on a daily basis.

Objection to Rochford Core Strategy, 175 houses in Hawkwell UNSOUND

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:

1. Travel

1. Rectory Road has always been busy and since the development of Cherry Orchard Way this has been exacerbated by a constant stream of traffic with queues forming at the Nursery Corner/B1013 junction throughout the day but especially during the morning and evening rush hours. It cannot take any more feeder roads.
2. The proposal for 330 new dwellings will mean more cars. As most households now have at least two cars the number of journeys per day could increase by 1500, there would also be the extra traffic caused by tradesmen, the services eg gas, electric etc and visitors to the new residents.
3. Rectory Road is also used by very heavy lorries serving, among other places the sports centre and a local farm at Windsor Road, these vehicles have great difficulty negotiating the nursery corner junction and regularly mount the grass verges.
4. For pedestrians, crossing the roads to get to the bus stop at this very busy junction is extremely dangerous because of the speed of traffic and the very limited vision.
5. The area has one bus an hour to Southend or Rayleigh, there is NO BUS SERVICE AFTER 6.30pm. ACCORDING TO THE LATEST TIME TABLE ISSUED BY ARRIVA! (Except on Saturday 7.30pm.) This makes a mockery of the intention to limit car usage!
6. There are no schools within safe walking distance.
7. There are no safe cycle tracks. The road is far too dangerous for any but the most competent cyclist.
8. The walk to Hockley rail station takes 25 minutes, to Rochford rail station it takes 40 minutes.
9. The one lane, traffic light controlled section of Rectory Road at the railway bridge causes a bottleneck and discourages drivers from using the eastern end of the road.

2. Environment

1. The development proposed would completely ruin the character of the area. The site proposed consists of mature shrub-land and woodland that has remained undisturbed for decades. It supports a great variety of wild life and is a natural appendage to the more open habitat provided by the adjacent Spencer's Park. The consequent loss of wildlife can not be justified.
2. The area absorbs a great amount of rain water and is a natural defence against flooding in the area. The brook and pond bordering Spencer's Park is only adequate to contain present rain water levels and could hardly cope with the extra pressure put on it from this development.
3. The density of the proposed development is three times greater than that of surrounding properties. Currently this is mainly a low level building area consisting mainly of bungalows, the proposed two and three storey buildings will be totally out of character.
4. There seems to be little provision for the influx of younger people, particularly teenagers who will require social facilities that are easily and cheaply available. The provisional figure of 30 school age children by David Wilson Homes is grossly underestimated.
5. The traffic movement implications have been dealt with under 'travel' above but the provision of a few footpaths and cycle tracks will in no way be adequate. These youngsters will not even have a safe walk to their various schools owing to the density and speed of the traffic using Rectory Road and/or the B1013.
6. Depending on the size and nature of the businesses in the proposed retail area, there is concern that outlets comprising market leaders will attract shoppers from outside the immediate area thus adding to the congestion on our roads.

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 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 the 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 UNSOUND

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:

1. Travel

1. Rectory Road has always been busy and since the development of Cherry Orchard Way this has been exacerbated by a constant stream of traffic with queues forming at the Nursery Corner/B1013 junction throughout the day but especially during the morning and evening rush hours. It cannot take any more feeder roads.
2. The proposal for 330 new dwellings will mean more cars. As most households now have at least two cars the number of journeys per day could increase by 1500, there would also be the extra traffic caused by tradesmen, the services eg gas, electric etc and visitors to the new residents.
3. Rectory Road is also used by very heavy lorries serving, among other places the sports centre and a local farm at Windsor Road, these vehicles have great difficulty negotiating the nursery corner junction and regularly mount the grass verges.
4. For pedestrians, crossing the roads to get to the bus stop at this very busy junction is extremely dangerous because of the speed of traffic and the very limited vision.
5. The area has one bus an hour to Southend or Rayleigh, there is NO BUS SERVICE AFTER 6.30pm. ACCORDING TO THE LATEST TIME TABLE ISSUED BY ARRIVA! (Except on Saturday 7.30pm.) This makes a mockery of the intention to limit car usage!
6. There are no schools within safe walking distance.
7. There are no safe cycle tracks. The road is far too dangerous for any but the most competent cyclist.
8. The walk to Hockley rail station takes 25 minutes, to Rochford rail station it takes 40 minutes.
9. The one lane, traffic light controlled section of Rectory Road at the railway bridge causes a bottleneck and discourages drivers from using the eastern end of the road.

2. Environment

1. The development proposed would completely ruin the character of the area. The site proposed consists of mature shrub-land and woodland that has remained undisturbed for decades. It supports a great variety of wild life and is a natural appendage to the more open habitat provided by the adjacent Spencer's Park. The consequent loss of wildlife can not be justified.
2. The area absorbs a great amount of rain water and is a natural defence against flooding in the area. The brook and pond bordering Spencer's Park is only adequate to contain present rain water levels and could hardly cope with the extra pressure put on it from this development.
3. The density of the proposed development is three times greater than that of surrounding properties. Currently this is mainly a low level building area consisting mainly of bungalows, the proposed two and three storey buildings will be totally out of character.
4. There seems to be little provision for the influx of younger people, particularly teenagers who will require social facilities that are easily and cheaply available. The provisional figure of 30 school age children by David Wilson Homes is grossly underestimated.
5. The traffic movement implications have been dealt with under 'travel' above but the provision of a few footpaths and cycle tracks will in no way be adequate. These youngsters will not even have a safe walk to their various schools owing to the density and speed of the traffic using Rectory Road and/or the B1013.
6. Depending on the size and nature of the businesses in the proposed retail area, there is concern that outlets comprising market leaders will attract shoppers from outside the immediate area thus adding to the congestion on our roads.

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 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 the 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 write this letter with regards to the 175 houses that you wish to build in our community. We strongly object to the building of these houses on our green belt land. This is a semi rural area with a village like feel and this will be lost if building goes ahead. This location just cannot benefit from this development at all. You/they may say they will build extra doctors/health surgeries, schools etc but what about the things that will be lost such as:

loss of green belt
loss of wildlife
a complete loss of character
the fact that the location is unsuitable for large development

The roads just cannot take any extra traffic and there is no space for development on the local roads, especially Rectory Road. We are some distance from the shops and the train station. There is just one bus to and from Southend/Rayleigh per hour and Arriva have no intention of providing an appropriate service in the long term. This means all these extra people will need to travel by car, hence cloggin gup the roads!

We would just like to point out that when we brought our property, we did so because of its location. It was sold to us as semi rural and we thought it an ideal area to raise our family. If we wanted to live and raise our family in the middle of a housing estate, that is what we would have brought!

We strongly urge you to take our points on board and put a stop to this development. Please listen to your community!

I would like to record my objections to the Rochford Core Strategy. 175 additional houses in Hawkwell is for the following reasons a completely unsound strategy.

1. The increase in car use caused by the proposed housing increase will cause even heavier congestion at the Spa junction (Hockley), railway bridge junction (Rochford) and along Rectory Road itself.

2. There is no way the highways can be improved to ease the congestion already in existance and due to the increase should this proposal be implemented can only get worse. Rectory Road is already built up to such an extent the highway cannot be improved enough to cope with the additional traffic envisaged.

3. Shops from Rectory Road area are accessible only by car. Car parking facility at the Main ROad and Golden Cross shopping centres are already inadequate during most of the day.

4. Public transport from Hawkwell is almost non existant. A car ride to the nearest railway station (more road congestion) or one bus per hour to Rayleigh/Southend with no prospect of improved service from Arriva.

The environmental issue is also a very serious issue. Hawkwell is a semi rural location with Green Belt land and wild life as part of its character. Should this strategy be implemented these characteristics will be lost and the whole character of Hawkwell dramatically changed. I find no social, economic or environmental benefits from the Strategy whatsoever.

The whole strategy is unsound because it fails to follow the Government Planning Policy PPS12 on all the points listed above.

Hawkwell therefore should be exempt from this development and moved to a more sustainable location!

Local Development Framework Core Strategy Submission

I understand that RDC was under government instruction to come up with a Core Strategy proposal, and I believe that it has done a reasonable job in trying to satisfy each parish. However, I have 2 objections with regard to the soundness of the latest proposal in the Hockley area.

Objection
There is currently a traffic flow issue on the Hockley Road at peak times. With the additional proposed housing allocations in Rochford, Hawkwell and Hockley, and the associated increase in number of vehicles, the Spa roundabout in Hockley will become gridlocked. There is no satisfactory solution provided in the Core Strategy submission to overcome the problem of road networks. There is no inexpensive solution to the growing problem. Also, no account has been taken of the further increased traffic related to the proposed airport expansion.

Objection
The latest version of the Core Strategy proposes to relocate existing businesses from Eldon Way and Foundry Industrial Estates in Hockley to greenbelt land in the vicinity of Southend Airport, and to redevelop the estates for commercial, retail, leisure, community, and residential purposes. The number of proposed residential units is not stated independently in the proposal (although it is shown in the Hockley Town Centre Development Plan), but is reported to be 150 - 200 dwellings. The previous version of the Core Strategy did not show any additional housing in the centre of Hockley.
The Hockley Parish Plan (published October 2007) states that there should be no new large housing estates in Hockley due to insufficient infrastructure in terms of schools, healthcare, leisure facilities and road networks. It also states that there should be no loss of greenbelt or open spaces due to housing development. Both of these conditions are broken by the Eldon Way proposal.
The Parish Plan also discusses the traffic flow issues in the centre of Hockley and the approach roads from Rayleigh, Rochford and Ashingdon. The local roads are narrow and could not cope with the additional vehicles generated by 150 - 200 new dwellings in the centre of Hockley, and would be unbearable during the development period with a constant flow of construction lorries.
In a recent Resident Survey in Hockley, completed in October 2009, with reference to Hockley Centre Redevelopment, 87% of responses were against moving businesses out of Eldon Way to make way for major redevelopment, and if redevelopment was enforced, the least favoured type of development was shown to be residential units with just over 1% of response support.

Objection to Rochford Core Strategy, 175 houses in Hawkwell IS UNSOUND

The proposal in the Rochford Core Strategy (the RDC Policy for local development) for this many houses in the Ward of Hawkwell West is UNSOUND because the vital requirements of PPS12 (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:
1) Travel
- limited public transport;
- increased car use causing heavy congestion;
- inability to improve highways;
- distance from shops; and
- distance from rail stations.

2) 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.

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.

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.

We are objecting to the proposed building of 175 houses on Green Belt Land in Hawkwell. the main reasons for our objection are:

TRAVEL
-We have very limited public transport
-Which will add to the already congested roads ( try getting out of our road at peak times)
-inability to improve highways
-distance from shops causing more people to use their cars and clog up the roads
-distance from railway stations

ENVIRONMENT
-our beautiful semi-rural location should be left as just that it is not suitable for large development
-the character of the area would be lost for ever bigger is not better
-the loss of our very important Green Belt which should remain to fulfill the job it was intended to do
-where will the wildlife go? It is already under extreme pressure we don't need hunting or culling just count the fox and badger corpses on our roads
-We can see NO social, economic or environmental benefits that these plans would bring.

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.

I am writing to express my objection to the Rochford Core Strategy which proposes to add 175 houses to the ward of West Hawkwell. My understanding is that the strategy is intended to take advantage of development opportunities which provide social, economic and environmental benefits to the community. In fact there are no such benefits. However there are considerable disbenefits.

The roads in the area are already extremely busy in particular the B1013 and Rectory Road with a particular bottleneck at their junction. There is no ability to improve them particularly as each is accessed via a low and narrow railway bridge. Additional house will add yet more traffic compounded by the extremely limited public transport available to travel tot eh natural shopping areas to the east in Rochford and the west in Hockley. I fail to see how this squares within the strategy's aim of locating development where alternatives to car use are more viable.

There will be a loss of green belt land and an adverse effect on wild life. This will lead to a loss of the semi rural characters of the area. Indeed the strategy notes that there is a limit to the how much infilling and intensification existing settlements can sustain without their character being adversely affected. This limit has been reached in West Hawkwell. An increase in housing of the size envisaged is likely to lead to a continuous strip of urban development stretching from Rochford to Hawkwell destroying the separate identity of both.

For the above reasons I contend that the part of the core strategy related to Hawkwell West is unsound because it is not justified and should be deleted.

I am writing to express my objection to the Rochford Core Strategy which proposes to add 75 houses to the ward to West Hawkwell. My understanding is that the strategy is intended to take advantage of development opportunities which provide social, economic and environmental benefits to the community. In fact there are no such benefits. However there are considerable disbenefits.

The roads in the area are already extremely busy in particular the B1013 and Rectory Road with a particular bottleneck at their junction. There is no ability to improve them particularly as each is accessed via a low and narrow railway bridge. Additional houses will add yet more traffic compounded by the extremely limited public transport available to travel to the natural shopping areas to the east in Rochford and the west in Hockley. I fail to se how this squares with the strategy's aim of locating development where alternatives to car use are more viable.

There will be a loss of green belt land and an adverse effect on wild life. This will lead to a loss of the semi-rural character of the area. Indeed the strategy notes that there is a limit to the how much infilling and intensification existing settlements can sustain without their character being adversely affected. This limit has been reached in West Hawkwell. An increase in housing of the size envisaged is likely to lead to a continuous strip of urban development stretching from Rochford to Hawkwell destroying the separate identify of both.

For the above reasons I contend that the part of the core strategy related to Hawkwell West is unsound because it is not justified and should be deleted.

We consider the DPD is potentially unsound depending on the final selection of specific sites or site in South West Hullbridge.

Please see attached statements 1, 2, 3 and 4 evidential statement.

The precise wording should correlate to the proposal of the attached statements, although the issue may be resolved by publication of the allocations development plan document.

Oral participation will depend on whether the proposed site is included in the allocation development plan document for specific sites for future development, if the proposed site is included oral participation will not be required or necessary.

LDF - Preferred Options - Rayleigh conurbation.
On behalf of Rawreth Parish Council I confirm that this letter is a formal response of objection to the final draft of Rochford District Councils Core Strategy Preferred Options document.
Firstly, at no time has the Parish of Rawreth been included or mentioned in any "Tier" on page 33 of the document, the criteria for allocation of houses - within the Core Strategy. If it had been included it should have been in Tier 4 and this is, therefore, UNSOUND.
The Parish Council believes that to develop 550 houses in one place within area no: 144, land to the north of London Road and then to add a further 220 to the Rawreth Industrial Estate area will totally destroy the character and rural outlook of Rawreth and surrounding areas. It will destroy the residents' "strong sense of identity within their own settlement" and is, therefore, UNSOUND.
The huge development of 550 houses is totally unacceptable. The land north of London Road is good quality agricultural land which is protected by the Green Belt -GB1 - fulfils all purposes under PPG2 and should be retained as such. Once used for development this land can never be returned to agricultural use, and if you continue to erode into our Green Belt and farmland it will be lost forever.

The Parish Council believe a proportion of the houses required to be built in our area should compliment and enhance Rawreth, cause as little extra congestion to our already heavily overcrowded roads as possible and provide a pleasant environment for those people wishing to move to the area. This particular area is part of the "Gateway to Rochford" and is the "strategic buffer" between Rayleigh and Wickford. Reference is made in the Core Strategy document to "avoiding coalescence" of villages/towns, however a development of this size immediately erodes the buffer between Rayleigh, Rawreth and Wickford, starts coalescence, destroys the rural character of Rawreth and, therefore, is UNSOUND.

The Core Strategy Document details Rochford District Councils priorities and objectives and details how the role of the Core Strategy features in achieving these. In support of the Parish Councils observations and alternative proposals they comment as follows.
Page 5 "Fostering greater community cohesion"
Development of land between Rawreth Lane and north of London Road will not give any community cohesion at all, it will simply be an extension to the west of Rayleigh giving residents no real sense of belonging, they will live within the Parish of Rawreth, yet they will be considered as living in Rayleigh as has been proved with other developments along Rawreth Lane such as Laburnum Way.
Page 12 "Priority 5 Essex roads are safer less congested and everyone has access to essential services"

The roads and infrastructure in the Rawreth area are completely full to capacity. The A127, A1245, A129 London Road, Rawreth Lane and Watery Lane just cannot take any more traffic and the proposed development on land to the north of London Road will increase traffic to a completely unsustainable level. On numerous occasions this year incidents within and on the outskirts of the Parish have brought traffic to a standstill for hours along London Road, Rawreth Lane, Watery Lane/Beeches Road and the Hullbridge Road. It took some residents 1 ¼ hours to proceed along Rawreth Lane and into Hullbridge - a distance of 1 1/2 miles.

The proposed development at the western edge of Hullbridge, which is, in fact, largely in Rawreth would also greatly increase the traffic problems in the area. Rawreth Parish Council understand there would be a proposal to "widen/straighten" Watery Lane/Beeches Road, with a roundabout at the junction with the Hullbridge Road. This is an extremely dangerous junction even at the present time and would become increasingly so. There is also the question of where the traffic would go when it reaches Battlesbridge at the Western end, it cannot possibly cross the Bridge as this is "restricted" and in a Conservation Area, therefore, it would have to turn left and proceed to the A1245 - a very dangerous junction.

Beeches Road/Watery Lane is also shown in the document as a new cyclist route. Surely this is a conflict of interest, a road widening/straightening proposal coupled with a cycle route.
Page 33 "Tier Settlements"
Nowhere in the Core Strategy Document is Rawreth Parish actually mentioned, it features in the "all other settlements tier 4" and is referred to as "land north of London Road Rayleigh" or "West Rayleigh" yet, the housing allocation of 550 dwellings between 2015 and 2021 and the 220 planned for the Rawreth Industrial Estate is the largest that any area is taking. Rawreth Parish currently has 380 dwellings and an electorate of 812, yet the proposed housing figures are set to increase the overall number of dwellings in the Parish by 203%.
Pages 34 to 36 "The efficient use of land for housing" and "Extensions to residential envelopes and phasing"
The Core Strategy Document states that "the Council recognises the importance of making best use of brownfield land" and "whilst the Council acknowledge that the housing requirement stipulated in the East of England Plan is a minimum, it must also be mindful of the need to maintain Green Belt as far as possible" yet the proposed 550 houses on the land north of London Road will all be built on Green Belt land of high agricultural value. The document states that "the Council will direct development to the most sustainable locations on the edge of settlements having regard to:"
"The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance"
"The historical, agricultural and ecological value of land"
"The potential to create a defensible Green Belt Boundary and
"The avoidance of coalescence with neighbouring settlements"
Yet these key factors all seem to have been ignored when choosing the site to the north of London Road and, therefore, the proposal is UNSOUND. The Parish of Rawreth has a history of flooding, the land in Rawreth Lane will drain into the already overloaded brook system and the Services in the area would be unable to cope with this increase in housing - drains and sewers are already working to capacity. Heavy rain earlier in the year resulted in flooding in Watery Lane and the Rawreth Brook system has been very close to flooding twice already this year. During a meeting between the Parish Council and the Environment Agency we were advised that this situation will worsen with increased housing.

Page 42 "Gypsy and Traveller Accommodation"
This section details the need for an allocation of 15 pitches by 2011, it also states that they "will examine the potential of current unauthorised sites to meet this need" and that "sites will be allocated in the west of the District" The west of the District is in fact Rawreth, but yet again the Parish name has not been detailed. The Parish already has an unauthorised site which is the subject of an enforcement case and although well kept is on the brow of a hill on a main highway with restricted access which Essex County Council have already raised concerns about, this is not a site that should be considered as part of the requirement due to its location, but also, why is the allocation of all 15 pitches being detailed to one area?

Page 43 to 44 "Appendix 1"

Details of all the infrastructure to accompany residential development is listed, yet there are no detailed costs, have these been done? And are these achievable? Large numbers of housing in one area, as stated in the infrastructure requirements, will necessitate a new primary school. County figures suggest that there will be surplus places in Rayleigh schools even with new housing. Obviously these will be in the wrong parts of the town so increasing the risk that an existing school could close .It makes sense to spread the development in smaller sites around the town, avoiding closure and preventing unnecessary provision of a new school.

Page 57 "Strategies, Activities and Actions - The Green Belt"
The document states that "The Council will continue to support the principals of restricting development in the Green Belt, as set out in PPG2 and will preserve the character and openness of the Green Belt" it further states that "a small proportion of the District's Green Belt will have to have its designation reviewed to allow development" The entire development of 550 houses planned for land north of London Road is all on Green Belt land as is the land at Hullbridge, how does this equate to a "small proportion"?
The Councils own Policy GB1- Green Belt Protection states "The Council will allocate the minimum amount of Green Belt land necessary to meet the District's housing and employment needs" and that they will "direct development away from the Green Belt as far as is practicable and will prioritise the protection of the Green Belt land based on how well the land helps achieve the purposes of the Green Belt".
This area of land confirms all 5 purposes of the national PPG2 - Green Belt:-
It prevents the unrestricted sprawl of western Rayleigh
It provides a barrier to prevent the ultimate merging of Rayleigh, Rawreth and Wickford
It assists in safeguarding the countryside from encroachment
It preserves the setting and special character of historic towns
Assists in urban regeneration, by encouraging the recycling of derelict and other urban land
Rawreth Parish Council have observed that there are a number of sites that were put forward in the "Call for Sites" that are pre-used brownfield land in the Green Belt land, and as such would prove beneficial and in their opinion should have been considered for development. Their non-inclusion as "brownfield" sites makes the current proposals UNSOUND:
Site No; 73 Hambro Nursery a site of approximately 3.93 hectares, coupled with the adjacent site Clovelly, would provide between 200 and 250 houses in an area of approximately 4.85 hectares this area would have good access directly from the A1245 and if expanded north westward to include land up to and around the Village Hall, approximately another 2.08 hectares could produce between 50 and 80 further houses. This area could be accessed either from the slip road (Chelmsford Road) to the south of the Nevendon Garage or from Church Road.
Both of these sites would remove the need for extra traffic along the A129 and Rawreth Lane which are both already operating well over maximum capacity. This development would require a footbridge for pedestrians, cyclists and horses over the A1245.
Rawreth Parish Council believe these proposals would be sensible infill of these areas and would be on "Brownfield" sites where current businesses are not particularly progressive and would not result in the loss of many jobs. Our figures are quite conservative and we believe that if these sites were chosen a much reduced number of houses would need to be built "North of London Road" on Green Belt land.
Phase 2 - With regard to the houses that are proposed for the Northeast corner of Rawreth/Hullbridge, the Parish Council are concerned that any development would cause considerable extra congestion to the immediate roads. We understand that the thoughts are to "straighten" and improve parts of Watery Lane and Beeches Road to provide access to and through Battlesbridge - a conservation area. Recent experience of deep flooding in Watery Lane with the road closed for several days on 3 occasions in the early part of 2009 proves that this proposal is completely unsustainable. The local drainage systems simply cannot take the amount of run-off experienced now and with further development this would increase the problem.
If this development is to go ahead, the Parish Council believe that a relief road should be built, from the end of Watery Lane, skirting to the west of the Rayleigh Park Estate, crossing Rawreth Lane at a mini-roundabout and entering a vastly improved A129 at approximately Lower Barn Farm. This would take any necessary traffic in and out of the area efficiently.
The Parish Council further believe that the Michelins Farm site No: 49 would be an ideal site for the Rawreth Industrial Estate. This would adjoin proposed industrial sites within the Basildon District and would provide excellent road and transport links. Rawreth Parish Council also proposed that the land opposite Michelins Farm could be used to re-site the illegal Gypsy/Traveller site that is currently situated on the busy A1245. The land opposite Michelins Farm would not only be a much safer site for Gypsy/Traveller pitches, but the correct use of the land would also ensure the environmental improvement of the site as a whole.
All of the above proposals were submitted to Rochford District Council, but they were not taken into consideration in the final draft resulting in the predominant use of Green Belt land for development, bounded by already congested roads and, therefore, the proposals are UNSOUND.

I wish to object on the grounds of unsoundness or legally non compliant due to the following points:

- Producing a heavy weight document that prevented printing and general distribution was an unfair method of consultation.
- This document does not fully take into consideration the impact of the JAAP report and the reports for the proposed redevelopment of Hockley, Rochford and Rayleigh.
- The stated government policy of using 60% brown field sites first before green field seems to have been reversed, with many potential sites for building being of a green field nature.
- If the 175 homes were to be located in one place it will change the nature of the village. We believe it would be better to spread them throughout the Hawkwell area. Consideration should be given to the proximity of shops and schools as due to the lack of public transport additional car usage would result.
- That comprehensive consultation has not taken place with ECC, other district councils, local parish / town councils, residents associations and other interested parties in and around our district.
- The additional homes will put an enormous strain on the infrastructure of our area, particularly the road system, which has not been addressed in the document.
- Loss of Green Belt in our area, which would change our village into a town.
- Additional vehicles on the roads from the building of the new homes, the additional residents, their delivery services and visitors and the proposed airport expansion traffic.
- Additional demand on our doctors and dentists.
- Additional demand on schools and social services.
- The number 7 and 8 bus has now been reduced to mainly one bus an hour and there is now no evening number 8 service.
- Additional demand on gas, electric, telephone, water, sewers and surface / storm water drainage.
- Moving Eldon Way and the Foundry Estate to a green belt site at the airport area will increase mileage for employees and the lack of public transport will limit employment to car users. We believe cycling would be a poor and unrealistic substitute.
- ECC have stated that the B1013 is now running at 72% capacity. The Core Strategy proposal would bring the traffic to an unbearable level. No details and estimated costs are given of the many road improvement we believe would be necessary as listed below.
- This area is enclosed by the River Crouch, the sea and the Thames and is only properly accessed from the west. For this reason we believe the sensible place to locate additional homes would be in the western part of Rochford district.
- We believe that no major infrastructure improvements have been carried out in the Hawkwell area for more than 30 years. We also believe that the following infrastructure improvements in the Hawkwell / Hockley area, that are not included in the Core Strategy document, should be addressed before any additional homes are built:

1. Replacement of Rectory Road Railway Bridge for two-way traffic.
2. Computer controlled traffic lights at the Rectory Road / Hall Road junction.
3. Upgrade Rectory Road and widen road and footpath at the Christmas Tree Farm area.
4. Upgrade the B1013 Hall Road and provide missing and upgrade existing pavements.
5. Proper main road street lighting for the B1013 Hall Road and B1013 Rayleigh Road.
6. A cycle path route from Rochford through Hockley to Rayleigh.
7. A new pelican crossing in B1013 Main Road near Tudor Way.
8. Return to two buses an hour in both directions for the 7 and 8 services between Southend and Rayleigh and the return of the 8 evening bus service.
9. Improvements to all services including gas, electric, telephone, water, sewers and surface / storm water drainage.
10. Increase capacity at all the local Schools in the area.
11. Increase capacity at all the local Doctors and Dentists and hospital services in the area.
12. Increase ambulance, fire and police emergency services.
13. Provide and run a youth club in the Hawkwell area.
14. To provide and run allotments in the Hawkwell area.
15. To extend the existing Cherry Orchard Park to Mount Bovers Lane and Hockley Woods.
16. Replace the existing Hockley Spa roundabout with a wider traffic light junction complete with pedestrian cross lights.
17. Install a double mini roundabout at Station Road and Station Approach junction with Spa Road for Hockley Station.
18. Install a mini roundabout on the B1013 at Folly Lane.
19. Make up / Upgrade Plumberow Avenue through to Lower Road in Hockley complete with pavements, main road street lighting and a mini roundabout at the Lower Road junction.
20. Upgrade Watery Lane / Beeches Road in Hullbridge from Lower Road complete with pavements, main road street lighting and a mini roundabout at the Lower Road junction.

As explained in other representations submitted on behalf of the Aston Unit Trust and Mr J Needs, the Core Strategy fails to set out a long term, robust and flexible strategy for development as required under PPS12. Policy H2 compounds these concerns by being inflexible and distributing greenfield allocations in a manner which is contrary to the Council's objectives and will not deliver a pattern of sustainable development.

The main deficiencies of Policy H2 are

(a) there is no reason to split the housing provision between H2 (pre 2021) and Policy H3 (post 2021). The Core Strategy should contain a single allocations policy dealing with the full plan period of at least 15 years. By separating the sites into two periods, there is no clear mechanism to (for example) accelerate H3 sites if there is a shortfall in the H2 sites
(b) there is no contingency strategy if any of the H2 sites fail to come forward or guidance on what sites should be additionally allocated if other parts of the land supply fail
(c) the number of dwellings allocated to each settlement in Policy H2 does not represent a distribution which will maximise the chances of achieving a more sustainable pattern of development. In particular, it is unclear why, as the largest town in the District (30,196 people, para 2.21), Rayleigh is allocated no greenfield dwellings prior to 2015, only 500 dwellings between 2015 and 2021 and no dwellings after 2021 (Policy H3). In contrast, Rochford / Ashingdon (population 10,775) is proposed to accommodate 1,200 dwellings during the full plan period (H2 and H3), and Hullbridge (population 6445) has the same allocation as Rayleigh of 500 dwellings, despite being one fifth of its size.

Whilst it is accepted that the size of a settlement does not automatically mean it is the most sustainable settlement for further development, the Core Strategy makes the following factual statements about Rayleigh which suggest it is the most sustainable settlement in the District
(i) it is the largest settlement in the District (2.21)
(ii) it has the best access to services in the District (2.68)
(iii) Rayleigh has the highest percentage of demand (44.4%) in terms of the Housing Waiting List (2.35)
(iv) Rayleigh provides the most comprehensive range of town centre facilities (12.13)
(v) Rayleigh is the principal centre in the District and maintains a much greater share of its convenience and comparison shopping
than any other area of the District (12.18).

Paragraph 2.39 encapsulates what is (correctly) the distribution strategy for additional housing

"As well as directing housing growth to areas of need / demand, and away from unsustainable locations subject to constraints, the Council must consider the relationship of housing growth to areas of employment growth".

It is difficult to reconcile this comment with (for example) the proposal to identify the same number of greenfield allocations (500 in H2 and H3) in both Rayleigh and Hullbridge. Hullbridge is a second tier settlement and the plan comments on the less sustainable nature of these settlements as follows

"The second tier comprises Hullbridge and Great Wakering. These settlements have a more limited range of services and access to public transport is relatively poor".

It is noted that the first of the 'Transport' objectives (p102) is

"deliver developments that will reduce reliance on the private car, and that are well related to the public transport network".

This is also reflected in Policy T1 which starts by stating

"Developments will be required to be located and designed in such a way as to reduce reliance on the private car ....".

It therefore appears that the objective of the Core Strategy to deliver the most sustainable pattern of development is not reflected in
the proposed greenfield housing distribution in Policies H2 and H3.

The decision not to locate more greenfield development in Rayleigh does not reflect an absence of available and sustainable sites.
For example, the Aston Unit Trust and Mr J Needs have land at Wellington Road, north east of Rayleigh and south of the B1013
which is capable of accommodating up to 200 dwellings. This land (see plan) is outside the Upper Roach Valley Policy Area and is
well located to the wide range of facilities provided in the town. It could, therefore, represent a sustainable eastern extension to the
largest town in the District with the highest level of housing need. It is also a location where many trips could be made without requiring the use of a private car.

The logical conclusion of this representation is that the balance of H2 and H3 sites should be adjusted to give a higher level of development in Rayleigh and less in the second and third tier settlements. Rayleigh should also be the priority area of search for additional greenfield allocations if further sites are required. This would accord with the new spatial strategy Policy H*.

The plan could be made sound by amalgamating Policies H2 and H3 into a single policy covering the whole plan period.

"Extensions to residential envelopes to 2025

The residential envelopes of existing settlements will be extended in the broad areas set out below and indicated on the Key Diagram to contribute to land supply in the period to 2025.

Area
Rayleigh North of London Road - 550 Dwellings by 2025
North East Rayleigh, south of the B1013 - 200 Dwellings by 2025
Other sites at Rayleigh - 320 Dwellings by 2025
West Rochford - 600 Dwellings by 2025
West Hockley - 50 Dwellings by 2025
South Hawkwell - 175 Dwellings by 2025
Ashingdon - 400 Dwellings by 2025
Hullbridge - 200 Dwellings by 2025
Great Wakering - 250 Dwellings by 2025
Canewdon - 40 Dwellings by 2025

Total Dwellings by 2025 - 2785

The detalied location and quantum of development will be articulated within the Allocations DPD (rest of policy unchanged)

It is considered that our participation at the oral part of the public examination would assist the Inspector for two main reasons

- Sellwood Planning has a detailed knowledge of the Rochford area, appeared at the last Local Plan Inquiry and was a participant at the RSS public examination. This direct knowledge of the local area and the statutory Development Plan may be of assistance to the Inspector

- Sellwood Planning has experience in promoting major schemes through Core Strategies (eg. 7,000 dwellings in Ashford, 5,750 dwellings in Dover, 2,500 dwellings in Horsham and 1,200 dwellings in Newmarket) and the emerging
body of evidence of what constitutes a sound Core Strategy and what is unsound. Our experience indicates that, in a number of respects, the submitted Core Strategy is unsound in its present form.

REF: Rochford Core Strategy - 175 Houses in Hawkwell

I feel I must write to you objecting to the above number of houses in Hawkwell West as being unsound. This location is not sustainable in that it will cause an increase in car usage to a point of heavy congestion. At present it takes me quite a while to drive onto the B1013 whether turning right to head for Southend or left towards Hockley and Rayleigh.

The development is situated between Hockley and Rochford railway stations and necessitates the use of a car to reach either of these locations. There is limited public transport in this area and I cannot see any improvement in the near future. A similar reasoning exists for the shops which can only be accessed by car.

Unless the highways can be improved in the area mentioned we can only look forward to gridlock in this region.

I feel that the requirements of PPS12 are not being met in the manner they are in tended. From an environmental point of view this development creates a loss of character and I cannot see any social, economic or environmental benefits for the existing settlements.