Policy H2 - Extensions to residential envelopes and phasing

Objection to Rochford Core Strategy 175 Houses in Hawkwell is Unsound
Attention Mr Shaun Scrutton

Planning Dept

We, the undersigned are writing to register our most urgent protest to the proposed building development of three storey flats on the Hawkwell Christmas tree farm off Rectory Road.

Please consider the colossal effect on the whole village of Hawkwell, environmentally infrastructure, traffic congestion and overall appearance of the countryside.

We trust all protests received by yourself will be taken into account when making your decision.

Objection to Rochford ore Strategy for 175 Houses in Hawkwell is Unsound for the following reasons
Semi rural location unsuitable for large development. Complete loss of character. Loss of green belt. Loss of wild life. No social, economic or environmental benefits whatsoever.

We are not supportive that Land South of London Road has not been included in the potential development areas. Development west of Rayleigh is identified however it does not suggest the inclusion of land South of London Road.

Land South of London Road should be highlighted as a potential area for housing development in Policy H2. This area can be extended to provide a quantity of housing which links into the new development and facilities North of London Road as proposed.

No, I do not wish to participate at the oral examination

We are not supportive that Land North of Rawreth Lane has not been included in the potential development areas. Development west of Rayleigh is identified however it does not suggest the inclusion of land North of Rawreth Lane.

Land North of Rawreth Lane should be highlighted as a potential area for housing development in Policy H2. This area can be extended to provide a quantity of housing which links into the new development and facilities south of Rawreth Lane.

No, I do not wish to participate at the oral examination

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

The reasons why development in this location is unsustainable are as follows:

Travel

Limited public transport - to take just two examples - there is a bus to Southend at 8.03am and the next one isn't until 9.24am - when I used it recently it didn't turn up (apparently a frequent occurrence). The No. 8 bus does not meet the publics needs due to infrequent service, unreliability and does not offer an evening service. Not all buses to into Rayleigh - people will have to change their bus at Hockley and catch a train or another bus. This will mean people have no choice but to use their cars leading to...

Increased car use causing heavy congestion as all transport from this development will enter the B130 at Thorpe Road or from Rectory Road. Already the B130 is recognised as the busiest B road in the UK. An increase in traffic will result in a safety issue with emergency vehicles unable to gain access as roads are narrow in places, particularly Rectory Road.

Inability to improve the highways adequately within Hawkwell West now or in the future does not make this development sustainable.

Distance from shops. From Rectory Road to reach the small parade of shops on Main Road is a 20 minute walk with an incline, 30 minutes to Hockley which one has to walk up White Hart Hill, 30 minutes plus to Golden Cross parade of shops. Impossibility for many elderly people or parents with very young children.

Distance from Rail Stations - Hockley is a 30 minute walk from Rectory Road uphill and 50 minutes to Rochford, impractical for many people.

Environment

The site of the planning application is unsuitable for a large development.

Complete loss of character. To place 330 or even 175 properties in the area will be detrimental to the character of Hawkwell West. At the moment Hawkwell West viewed by air or even by google earth shows quite clearly this area to be a hamlet of existing properties, green belt areas with trees and shrubs, surrounded by agriculture fields. To squeeze this development into this space which is green belt with numerous trees and shrubs will make Hawkwell West into suburbia, it will lose its village, semi rural outlook which is important to local residents.

Part of the site, 9 acres already has a tree preservation order granted when local residents asked RDC woodlands officer to intervene when the owner in recent times started to remove trees. Does this not merit the importance of the character of the area that RDC woodland officer thought part of the site was worth of a tree preservation order and thus retaining the character of the area? Whys is this now being dismissed?

Loss of green belt land. We cannot afford to loose green belt and anywhere in Hawkwell West.

Loss of wildlife. In Spencer's Park you can see all bird species that live and nest in the proposed site, I regularly see wood pigeons, woodpeckers, jays, together with many of our loved songbirds. Badgers and bats are known to live on the site, is it of no consolation to the wildlife that the proposed site developer has taken this into account and left a small park area protecting the wildlife, an area surrounded by properties and human activity. How can wildlife be protected during the noisy building process, simply the cannot.

In addition the Core Strategy is UNSOUND because it does not fulfil the principals that are stated in the document as it relates to the proposal for Hawkwell West. The Core Strategy talks about protecting the character of existing settlements and specifically 'seeks to take advantage of development opportunities that will provide social, economic and environmental benefits'. No such benefits would apply to this location and development would be materially detrimental to the character of the existing settlements 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 effected', 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' and 'reduce the requirement to travel' and accompanying any development with requisite highway infrastructure to 'mitigate their impact on existing network'. It is not possible to do this in Hawkwell West as there is not room for development of highways, especially in rectory Road and any developing in this area would increase the requirement to travel, especially by car.

Moving onto Public Transport it states that. There is just one bus to and from Southend/Rayleigh running hourly but does not offer an evening service, 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.

Therefore for all the reasons given in this letter, I most strongly object to the two proposals outlined at the start of this letter.

I am opposed to the proposals for 550 houses on Rawreth Lane farmland for the following reasons.

1. It is against the green belt principle of safeguarding the countryside from encroachment.
2. Once green belt has started to be used there is no stopping point.
3. The buffer between villages/towns will be eroded and destroy the rural character of Rawreth.
4. Building on outer edges does not encourage any sense of community.
5. Lack of current demand in this area.
6. Large area of proposed development area already defined as a 4th Tier settlement.
7. Roads are already full to capacity.
8. Increased flood risk.

Use all available land within the existing boundaries and do not sprawl onto protected green belt.

I oppose the building plans for additional houses in Rawreth Lane farmland because

1. It is against the green belt principle
2. Once erosion of green belt starts it will not stop.
3. The buffer between villages/towns will be eroded and destroy the rural character of Rawreth.
4. Building on outer edges does not encourage any sense of community.
5. Lack of current demand in this area.
6. Large area of proposed development area already defined as a 4th Tier settlement.
7. Roads are already full to capacity.
8. Increased flood risk.

Use all available land within the existing boundaries and leave the green belt alone.

Objection to Rochford Core Strategy, 175 Houses in Hawkwell

Dear Mr Scrutton,

The proposal in the Rochford Core Strategy for this many houses in the Ward of Hawkwell is unsound since the requirements of PPS12 are not met in terms of sustainability. Therefore the location of Hawkwell West should be removed by the Inspector, and the allocation moved to a sustainable location.

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 is unsuitable for large development
• Complete loss of character
• Loss of Green Belt
• Loss of wildlife
• No social, economic or environmental benefits

In addition, the Core Strategy is unsound as 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 states that it 'seeks to take advantage of development Opportunities that will provide social, economic and environmental
Benefits'

No such benefits can apply to this location, in fact development would be detrimental to the character of the existing settlement in Hawkwell West (in contradiction of the stated aims of the Core Strategy), The Core Strategy also states 'there is a limit to how much infilling and intensification existing settlements can sustain without their character being adversely affected'. 175 new houses in West Hawkwell will far exceed this limit.

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 the development of local roads, particularly in Rectory Road, and any development here would increase the requirement to travel, especially by car.

In respect of Public Transport, the Core Strategy states that 'planning should be well related to existing public transport'. There is just one bus to and from Southend/Rayleigh per hour, with no prospect of Arriva providing and 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 sincerely hope that Rochford District Council considers these matters very carefully, and concludes, with many residents of Hawkwell, that this housing development is unsustainable.

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

As a resident in Hawkwell West together with my family who for the past four generations have also resided in the area enables me to have an in-depth knowledge of the local area and its inhabitants.

Hawkwell West during my lifetime has seen only small scale property development, the largest possibly my own road Hazelwood with 26 houses. Clements Hall Sports Centre was built which together with properties known as Royers and Spencer's, the 'offering' or bargaining between land owners and RDC of 'let me build here and you can have some land for public open space' which gave the area Spencers Park together with the adjacent development. Apart from this Hawkwell West has only seen small developments or small scale infilling a few properties at a time mostly when a property with large garden is demolished and two or three properties built in the place of one. Although I may not always approve of backyard development or intensified infilling we have not seen an application for a proposed development such as envisaged by David Wilson Homes for Hawkwell West of 330 properties or even that has been proposed in the Rochford Core Strategy of 127 properties.

One the building of Clements Hall Sports Centre, the access road was originally planned for Sweyne Avenue, local residents objected and the plan was put forward that a new access road should be built, now called Clements Hall Way. A public inquiry was held at Rayleigh, it was decided by the Inspector that 'she would only allow the access road on the condition that it would form a barrier to prevent any further encroachment of green belt land between the existing remaining properties (one was removed to make space for the road) to the East along Rectory Road and to the West along Rectory Road to Main Road Hawkwell'.

The Inspector saw the importance of retaining the green belt land (now the proposed site for development) and the character of the area when she granted permission for the road but with safeguards in place to protect the green belt. The same should still apply today. Why is the Inspectors decision now being dismissed and ignored by RDC? This is the same area that David Wilson Homes envisages 300 properties and has applied to RDC for outline planning permission and I suspect will be the suggested site for Hawkwell West RDC within the Core Strategy for 127 properties.

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.

The reasons why development in this location is unsustainable are as follows:

Travel

Limited public transport, one bus an hour that does not meet the publics needs due to infrequent service, unreliability and does not offer an evening service.

Increased car use causing heavy congestion as all transport from this development will enter the B130 at Thorpe Road or from Rectory Road. Already the B130 is recognised as the busiest B road in the UK. All access roads leading onto the B130 can be seen now with cars stacking to enter at every road junction and mini roundabouts en route at most times of the day and particularly at rush hours. One accident between Rochford, Hawkwell and Hockley causes gridlock, an increase in traffic will result in a safety issue with emergency vehicles unable to gain access as roads are narrow in places, particularly Rectory Road. The planning application suggests two access points onto Rectory Road and Thorpe Road onto Main Road - all converge onto the B130 a B road at the capacity already of an A road making this an unrealistic proposal with no possibility of improvement other than what has been suggested at the mini-roundabout junction of Rectory Road, Hall Road, Main Road B130. This is an inadequate improvement to solve an excess traffic problem.

Inability to improve the highways adequately within Hawkwell West now or in the future does not make this development sustainable.

Distance from shops. From Rectory Road to reach the small parade of shops on Main Road is a 20 minute walk with an incline, 30 minutes to Hockley which one has to walk up White Hart Hill, 30 minutes plus to Golden Cross parade of shops. Impossibility for many elderly people or parents with very young children with shopping too.

Distance from Rail Stations - Walking Hockley 30 minutes from Rectory Road uphill and 50 minutes to Rochford, impractical for many people without their own transport and an unreliable bus service. Cycling may not be a choice for all or even convenient for the majority.

Environment

The site of the planning application is unsuitable for a large development as it sits in the middle of a semi rural location near agriculture land, green belt areas ith limited existing properties, mostly bungalows and detached properties. The application suggests 'landmark buildings' three stories high amongst detached and semi detached properties, completely out of keeping with the area..

Complete loss of character. To place 330 or even 175 properties in the area will be detrimental to the character of Hawkwell West. At the moment Hawkwell West viewed by air or even by google earth shows quite clearly this area to be a hamlet of existing properties, green belt areas with trees and shrubs, surrounded by agriculture fields. To squeeze this development into this space which is green belt with numerous trees and shrubs will make Hawkwell West into suburbia, it will lose its village, semi rural outlook which is important to local residents.

Part of the site, 9 acres already has a tree preservation order granted when local residents asked RDC woodlands officer to intervene when the owner in recent times started to remove trees. Does this not merit the importance of the character of the area that RDC woodland officer thought part of the site was worth of a tree preservation order and thus retaining the character of the area? Why is this now being dismissed?

Loss of green belt land. We cannot afford to loose green belt and anywhere in Hawkwell West.

In addition there will be far too much green belt land lost if developments go ahead in neighbouring villages which will impact on our area too. I would like to preserve the little we have in Hawkwell West for future generations to enjoy, not for them to wish that we had not been more sensitive to the local environment by allowing such developments to go ahead.

Loss of wildlife. From my address you will be aware that I live on the north side of Spencer's Park, a park that at the moment is enjoyed by all bird species that live and nest in the proposed site, I regularly see wood pigeons, woodpeckers, jays, together with many of our loved songbirds. Badgers and bats are known to live on the site, is it of no consolation to the wildlife that the proposed site developer has taken this into account and left a small park area protecting the wildlife, an area surrounded by properties and human activity. How can wildlife be protected during the noisy building process, simply the cannot.

There are NO social, economical or environmental benefits to be gained with this development of 330 houses and in adition the Core Strategy is UNSOUND because it does not fulfil the principals that are stated in the document as it relates to the proposal for Hawkwell West. The Core Strategy talks about protecting the character of existing settlements and specifically 'seeks to take advantage of development opportunities that will provide social, economic and environmental benefits'. No such benefits would apply to this location and development would be materially detrimental to the character of the existing settlements 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 effected', 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' and 'reduce the requirement to travel' and accompanying any development with requisite highway infrastructure to 'mitigate their impact on existing network'. It is not possible to do this in Hawkwell West as there is not room for development of highways, especially in rectory Road and any developing in this area would increase the requirement to travel, especially by car.

Moving onto Public Transport it states that 'planning should be well related to existing public transport where possible'.. There is just one bus to and from Southend/Rayleigh running hourly but does not offer an evening service, 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.

Therefore for all the reasons given in this letter, I most strongly object to the two proposals outlined at the start of this letter.

Objection to Rochford Core Strategy - 175 Houses in Hawkwell is UNSOUND.

We are writing formally to express our strong objection to the Rochford Core Strategy concerning 175 houses in Hawkwell as UNSOUND.

In brief our objections are based on the following;

The proposed site is on greenbelt/woodland and will impact on wildlife in the area as well as climate change.
A large and highly concentrated housing development is totally out of character with the "open" and semi-rural nature of the area.
The proposals to build a significant number of houses close together including flats and three storey properties would not be in keeping with properties in Hawkwell which are primarily detached or semi detached bungalows or houses.
The local transport or highways will not be able to support the significant increase in demand_- particularly commuting and local car journeys arising from 330 houses in such a concentrated area. The B1013 is already one of the busiest b roads in this part of Essex.
Local bus services are very infrequent and almost non-existent in the late evenings.
Apart from the increase in demand for local doctor and dentist services, local schools are unlikely to be able to accommodate the significant increase in demand for school places.

Overall, we firmly believe that these proposals will adversely affect the social, economic and environmental nature of the area, and we therefore strongly object to Council Members approving this part of the Rochford Core Stratecy application.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

Representations on behalf of Fairview New Homes

1. We are instructed by our client, Fairview New Homes, to submit comments on the published Core Strategy Submission Document. For ease specific reference has been made in accordance with the paragraph and policy numbers as contained in the published document. We would like the opportunity to represent our Client at the forthcoming Examination of the Core Strategy DPD and would be grateful for confirmation that this is possible.

2. Fairview New Homes have an interest in a parcel of land to the South West of Rayleigh Town Centre, as indicated on the attached site location plan. This land was previously identified in the Core Strategy Preferred Options documents to provide an urban extension to the south west of Rayleigh. This option has now been withdrawn in the Core Strategy Submission document and it is on this basis these representations are provided to the Council.

3. The Submission Core Strategy has been considered against the requirements set out at Paragraph 4.36 of PPS12 requiring core strategies to be justifiable and effective in order to be found sound, as follows:

Justified:
i. Founded on a robust and credible evidence base
ii. The most appropriate strategy when considered against the reasonable alternatives

Effective:
i. Deliverable - the Core Strategy should show how the vision, objectives and strategy for the area will be delivered and by whom, and when, including who is responsible for implementing different elements of the strategy and when
ii. Flexible - a strategy is unlikely to be effective if it cannot deal with changing circumstances. Plans should show how they will handle contingencies.
iii. Able to be monitored - monitoring is essential for an effective strategy and will provide the basis on which the contingency plans within the strategy would be triggered.

4. To summarise our comments, Fairview New Homes strongly object to the Core Strategy as is currently presented on the basis the document is currently unsound for a number of reasons:

• The lack of robust and credible evidence base
• Failure to clearly discount reasonable alternatives
• The effectiveness of the plan is also considered to be flawed and the Council's approach to deliverability and flexibility is questioned.

5. Fundamentally, we question the soundness of the Core Strategy due to the lack of available evidence to support the choices made by the Council. In particular, there is a strong reliance on the findings of the 2009 Strategic Housing Land Availability Assessment (SHLAA) although it is understood this document is not due to be published for consideration alongside the Core Strategy. We, therefore, reserve the right to submit additional comments to the Core Strategy consultation following the publication of the SHLAA.

6. The 2009 SHLAA is clearly listed at Paragraph 1.29 of the submission Core Strategy as one of the evidence base documents the Council have drawn upon when drafting the Core Strategy. The documents listed are all considered to have played an important role in informing the Core Strategy. PPS12 also recognises at Paragraph 4.37 the importance of demonstrating how choices made in the plan are backed up by factual evidence identified in evidence base documents.

7. As a starting point it is important to state it is Fairview New Homes greatest concern there is no background provided within the Core Strategy document, or indeed any of the available evidence base documents, identifying why the Local Planning Authority has chosen to remove some of the sites previously proposed for housing development. In addition, there is also no justification as to why the retained urban extension sites are more suitable than those removed from the draft plan.

8. The following provides specific comments in response to the relevant areas of the Core Strategy.

Housing

9. It is stated at Paragraphs 4.10-4.12 that the Council have adopted a balanced approach when locating new housing between higher tier settlements and lower tier settlements. Although there is no detail provided as to how the Council intend on implementing this balanced approach or how the strategic allocation of housing contributes to the balance required. Our Client cannot support this approach until further detail is understood as to the proportion of housing being allocated to each settlement tier.
10. The proposed distribution of housing development during the plan period does not appear to be proportionately allocated between the various settlement tiers. We would argue that development should be distributed proportionately in line with the size of the settlement in order to benefit for available services and facilities. Rayleigh recognised as having best access to services within the district at Paragraph 2.68 of the Core Strategy. On this basis it is considered the development should primarily be directed to Rayleigh with a proportionate level of housing to the remaining settlements in the District.

Policy H1 - The efficient use of land for housing

11. In general the use of residential extensions to meet the remaining housing requirement that cannot be delivered through the redevelopment of appropriate previously developed land is supported by Fairview New Homes.

12. It is understood there is a need to prioritise use of brownfield land in line with national policy requirements but this needs to be a carefully balanced and realistic approach in identifying appropriate urban extensions to accommodate the majority of the District's housing, as identified in the table at Paragraph 4.6 and later at Paragraph 4.15.

13. Policy H1 sets out that the Council will seek the redevelopment of Rawreth Lane Industrial Estate, Foundry Industrial Estate, Stambridge Mills and Star Lane Industrial Estate. Without sight of the 2009 SHLAA it is not possible to understand whether the Council's choice to release employment land for housing is appropriate and Fairview New Homes cannot, therefore, support this element of Policy H1. This objection is further amplified by the fact additional employment land is required but is yet to be identified.

Policy H2 - Extensions to residential envelopes and phasing

14. The Council's intention to provide a balanced strategy for housing provision is mentioned again at Paragraph 4.18. The comments made at Paragraphs 9 and 10 above are also relevant in this respect.

15. In comparing the Preferred Options Core Strategy Document and Submission Core Strategy Document there is a significant reduction in the number of housing units being provided in urban extensions pre 2015, from 1450 dwellings to 775. From discussions with the Local Planning Authority it is understood the Council are seeking to provide the District's housing requirements by increased development densities. From the evidence available in the Submission Core Strategy and summary of SHLAA sites a number of the sites identified as urban extensions have in fact been allocated a reduced number of dwellings, including the land to the north of London Road, Rayleigh. We would, therefore, consider the approach taken by the Local Planning Authority to provide the required level of housing is untenable and unjustified.

16. In discounting preferred options PPS12 makes clear at Paragraph 4.38 the requirement for Local Planning Authorities to consider and evaluate reasonable alternatives. As set out above, the choices the Council have pursued have not been substantiated and without the consideration of reasonable alternatives the Core Strategy cannot be considered justified and therefore unsound.

17. However, this is our opinion based only on discussions with the Local Planning Authority rather than a thorough evidence base and we will consider the evidence in detail when it become available and provide further comment.

18. Paragraph 4.19 of the draft Core Strategy details the Council's primary factors in determining the location of future urban extensions. It is presumed the Council have assessed each of the proposed urban extension sites against the following criteria and that this information is contained within the SHLAA, although we have not been provided with any evidence of this to assess. It can be demonstrated that the land identified on the attached site location plan meets all of the requirements set out below.

• The proximity and relationship to existing centres, facilities, services
• The availability of infrastructure and/or the potential for additional infrastructure to be provided for development in such areas
• The potential to reduce private car dependency
• The potential to avoid areas of constraint (such as areas at risk of flooding, sites of ecological importance, public safety zone etc)
• The historical, agricultural and ecological value of land
• The impact on highway network (including availability and impact on existing network, as well as potential for improvements to be delivered)
• The relationship of development locations to the District's area of employment growth
• The potential to create a defensible Green Belt boundary
• The avoidance of coalescence with neighbouring settlements

19. In summary, Fairview's land is sustainably located in particularly close proximity to Rayleigh Town Centre and train station. In addition, the location of the land provides a natural extension and rounding of settlement boundary. An extension to Rayleigh in this location offers no opportunity for coalescence with neighbouring settlements nor does it constitute urban sprawl.

Policy H2 - Extensions to residential envelopes and phasing

20. Although it is stated a flexible approach to the timings of the release of land will be maintain no explanation is provided as to why some sites are considered suitable for development pre 2015 and others post 2015. Paragraph 4.22 elaborates further to state a number of factors have been considered when determining the phasing of strategic housing sites although this information is not clearly available to assess.

21. As stated above the principle of releasing certain areas of greenbelt land is considered the best approach to meeting the Council's housing provision requirements. However, Fairview New Homes object to the omission of the land to the South West of Rayleigh for housing development as previously identified in the Core Strategy Preferred Options document. The site identified on the attached site location plan has been assessed against the Council's criteria, as set out at Paragraph 18 above and each requirement can be met. Without any clear explanation as to why this site has been discounted and the only other strategic housing site indentified in Rayleigh is located further away from Rayleigh Town Centre and the associated services and facilities including the train station, Fairview New Homes object to Policy H2.

22. As considered at the outset of these representations the draft Core Strategy cannot be considered robust, and therefore sound, without clear justification and evidence base.

Policy H3 - Extension to residential envelopes post-2021

23. Policy H3 is supported on the basis that the release of greenbelt land is required for housing and this is the most appropriate approach to meet the Council's housing requirements, as set out at Paragraph 21 above.

24. However, it is unclear why some of the sites previously identified for housing development pre 2015 up until 2021 in the Preferred Options Core Strategy document have now been allocated for development post 2021, such as South East Ashingdon. It is stated at Paragraph 4.24 of the Submission Core Strategy document those areas identified for post 2021 development may not be immediately deliverable. However, there is no information available to understand why these sites are now no longer considered suitable for pre 2015 development as they were in December 2008. As a result, Fairview New Homes consider Policy H3 to be unjustified and therefore unsound.

Affordable Housing

25. The acute need for additional affordable housing is recognised at Paragraph 4.30. It is unclear from the draft Core Strategy document
exactly how much affordable housing is required in the District in the plan period.

26. However, taking the starting point as set out at Paragraph 4.30 that the Thames Gateway South Essex Strategic Housing Market Assessment requires 131 net additional affordable dwellings per year which constitutes 52% of the District's overall annual housing target. In order to achieve this target using the Council's proposed policy requirement that new housing developments are to provide 35% affordable housing, 375 new dwellings would need to be developed each year. This calculation does not account for those developments with fewer than 15 dwellings which have no requirement to provide affordable housing or developments which cannot viably afford to provide non-market housing.

27. An annual requirement of 250 dwellings is identified at Paragraph 4.2 of the Core Strategy which would leave a significant short fall of affordable housing and act to compound the current situation. The approach taken by the Council ultimately accepts there will always be a shortfall in affordable housing provision and does not seek to redress this. We do not, therefore, consider this to be a robust or justified approach to achieving affordable housing in the District.

28. It is, therefore, considered in order to meet the District's affordable housing requirement additional housing land should be identified in order to ensure a wholesale increase in housing provision to address the Council's shortfall in affordable housing and meet the targets set for the plan period. The most appropriate and effective method by which to secure affordable housing provision is through developing large sites that are viably able to offer affordable housing units.

29. During the consultation of the submission Core Strategy the Council's Housing Strategy (2009) was not available and we reserve the right to make further comment on this document following the publication of this evidence.

The Green Belt

30. It is fully accepted by the Council that the Green Belt boundary is currently too tightly drawn and the release of some Green Belt land is necessary to meet the District's development requirements. However, it needs to be demonstrated that the areas of Green Belt land to be lost are justified and located in the most appropriate area and that areas of release land do not undermine the principle of the Green Belt.

31. It is understood from Paragraph 6.7 of the Submission Core Strategy the Council will seek to examine the degree to which current Green Belt land is helping to achieve the purposes of the Green Belt when considering reallocating land. However, areas of Green Belt are proposed to be reallocated for urban extensions prior to this research being undertaken.

32. Fairview New Homes fully support the justified retention of the areas of Green Belt where appropriate and the release of Green Belt land where needed. However, at present the proposed Housing policies and Green Belt policies are not coherent and the reallocation of certain areas of Green Belt is not based on a credible evidence base.

Environmental Issues

Policy ENV4 - Sustainable Drainage Systems (SUDS)

33. Fairview New Homes would like to support the flexibility contained within Policy ENV4 which recognises it is not always viably possible to incorporate SUDS in all developments.
Policy ENV8 - On Site Renewable and Low Carbon Energy Generation

34. We would also like to support Policy ENV8 on the same basis as Policy ENV4 in that it is important that the production of energy from renewable or low carbon sources is only required where it is viably possible so as not to resulting in developments not coming forward.

Transport

Policy T8 - Parking Standards

35. Fairview New Homes object to Policy T8 as it is currently contrary to National Policy requirements as set out in PPG13 which contains maximum parking standards. Indeed, this is recognised at Paragraph 10.27 of the Submission Core Strategy document. Enforcing minimum parking standards is not consistent with local or national sustainability aims and should not be an approach pursued by the Council.

We are supportive that the council have identified housing provision within Hawkwell. It is considered that this location is sustainable due to its close proximity to existing town centres. The provision of development in this location will enable highway infrastructure improvements which will ease current congestion. Existing previously developed sites existing within Hawkwell, (e.g. Magees Nurseries) offer opportunities for redevelopment of Brownfield land in line with government objections. Furthermore there is sufficient adjacent land in this location to provide comprehensive development.

The change we would like to see is that policy H2 is altered to refer to North Hawkwell or generally Hawkwell. It is considered development can be better constrained by the existing railway in the north of Hawkwell and will prevent sprawl to the south however this will be further considered in the Allocations Document. The reference to Hawkwell within the Core Strategy should be less site specific within this general strategy.

The proposal to use the green belt agricultural land "North of London Road" for 550 dwellings is contrary to National policy PPG2. PPG2 give 5 purposes for the Green Belt and the land in question satisfies them all. Therefore the document is unsound in national policy terms and should be changed.

There are other brownfield sites that could be used for the 550 dwellings (some of which have been identified by Rawreth Parish Council).

Core Strategy Submission Development Plan Document (DPD) Proposal for Additional Housing in Rawreth/West of Rayleigh (North of London Road)

I am objecting to the proposal to build an additional 770 dwellings between London Road and Rawreth Lane, 220 on the Rawreth Industrial Estate site behind Makro (this extra amount curiously not mentioned!) and 550 on farmland (classed as green belt/green field) land. Whilst there may be some merit in a development on the Rawreth Industrial Estate, where units are rather old and could perhaps be moved to a more modern site, the proposal for the farmland is really a step too far for the reasons below:

The Government & Politicians of all parties keep banging on about climate change, carbon footprints and the possibility of not being able to grow enough food for everyone and YET here, a proposal to concrete over farmland which could be used to grow more local produce rather than flying products over thousands of miles; thereby not exactly helping the so called carbon footprint. This farmland should be saved to help safeguard the countryside from encroachment, instead of crating a vast housing estate, which seems utterly ridiculous. Derelict and other urban land should be considered as a first priority to assist in regeneration.

My fear and concern is that once the plan gets the green light, there will be no stopping the limitless sprawl of western Rayleigh and Rawreth, since there are similar green field sites along other parts of Rawreth Lane, which could ultimately fall prey to the chipping away of the remaining green belt/green field land. If this happened there would be nothing to prevent neighbouring towns merging into one another, which would totally take away this part of Rayleigh's distinctive character and pleasant community feeling (something which the Core Strategy Plan states it wants to safeguard!). It also greatly reduces habitats for birds and other wildlife, which is very important to many of us.

The development would put a massive pressure on the roads and amenities around Rayleigh, which would have a very detrimental effect. This is not a case of nimbyism as this part of Rayleigh & Rawreth has already seen extensive development in recent years. There really needs to be a balance of green areas and housing not the total saturation and erosion of the countryside that would take place if this proposal were allowed to happen.

Objection to Rochford Core Strategy, 175 Houses in Hawkwell is UNSOUND
The above proposal is totally and without any doubt UNSOUND for the following reasons.

Limited choice of public transport.
The ultimate increase in car use which could cause heavy congestion along with more traffic noise. As we live on the main road in Hawkwell, which would carry most of the extra traffic, I can assure you that the level of noise etc. which already exists is problematic enough already.

The area in question simply does NOT have the ability to improve the highways.

Because of the distance to shopping facilities it would necessitate the majority of new residents having to shop by car.

There are no local rail stations in the proposed area thus, once again causing nay new residents having to get to and from Hockley/Rochford rail stations by car.

On the environment issue:

This is a semi rural location which is totally unsuitable for further development. In actual fact we are of the strong opinion that the area has already well and truly reached its limit.

If the proposal did go ahead the area would take on a complete change of character. Once green belt is built on it is lost forever.

Wildlife is suffering enough and any more new homes would cause further loss.

We cannot see any benefits whatsoever arising socially, economically nor environmentally. If anything they have already decreased.

If we had had any inkling that the proposals would be put forward we would never have moved here in the first place. It was the area that we liked but it had already changed with enough new homes having been built.

WE DO NOT NEED NOR WANT ANY MORE.

Policy H2 - Extensions to residential envelopes and planning

Summary: The Respondent finds the document to be unsound in its present form, however were the amendments set out in these representations to be incorporated then it is considered that the document will be sound. The general locations identified in the Core Strategy (CS) are supported. However, the respondent has prepared an indicative master plan illustrating an option for the broad locations in Ashingdon. This demonstrates that the site known as East Ashingdon could accommodate more than 150 dwellings and it must be recognised that to deliver enhancements to King Edmund School and remain viable, these sites will need to deliver this quantum of development. There is no justification for the phasing of the residential site and therefore policies H2 and H3 should be combined. In addition, the means by which the sites are identified are too vague and the general locations are not consistent with the key diagram.

Full text: The purpose of providing the Illustrative Master plan (drawing ref: 97069/07) is to demonstrate that there is sufficient land available within the locations to accommodate the growth; in fact, the area could take more. The master plan is designed to be illustrative to show what could be achieved and is by no means the only layout option. In addition, the master plan illustrates a workable and tested improvement to the access to King Edmund School and shows a possible location for the 3.0 hectare expansion of the school, required by policy CLT 3. It is understood that it may be more viable to build a new school either on the existing site or on adjacent land. The master plan option caters for such an eventuality as well as providing options for the layout of housing and public open space. The respondent has commissioned a Highway Access Strategy, which considers the optimum location of access points to serve the land parcels.
The land parcel in the broad location identified in the Core Strategy as East Ashingdon is largely free of constraint and both developable and deliverable in the first five years of the plan period. Sufficient housing land is available to exceed the allocations set out in Policies H2 and there are many advantages to the location, which would allow for additional growth. The respondent owns approximately 28 hectares of land in the general vicinity of the broad locations of "East" and "South-East" Ashingdon abutting the urban area, which would accommodate up to 1000 residential units at 40 dwellings per hectare, as well as providing an additional 3.0 hectares for expansion of the school. The land is available and developable in the short term. It has the following advantages in terms of developability:

* the site contains a main sewer complete with existing manholes;
* un-contaminated land in arable use;
* falls within flood zone 1;
* abuts the urban area;
* is accessible and within walking distance of a secondary and three primary schools, shops, services and public transport;
* accessible to main drainage facilities and utilities;
* within agricultural land classification 3;
* located in an area free of special or important landscape or biodiversity designations; and
* does not contain any important ecological or sensitive habitat areas.

In relation to the Green Belt and the five purposes of including land within the Green Belt:
* the land parcels would round off or infill the urban edge;
* there is no possibility of coalescence, the nearest settlement is several miles to the east;
* the urban extensions will not encroach into the countryside, much beyond the existing urban edge; and
* the location does not interfere or impact on the setting or special character of a historic town or settlement.

The land parcels are capable of exceeding the allocations set out in the Core Strategy whilst enhancing the access and size of King Edmund School, a vital component in the District's infrastructure. The development will result in only limited harm to the character and appearance of the countryside and as such, the Council should give greater consideration to the production of more detailed assessment through the Site Allocations DPD and an early planning application.

1. Land at East Ashingdon is capable of accommodating a higher level of development
As identified above, and demonstrated by the accompanying masterplan, land at East Ashingdon is actually capable of accommodating approximately around 150 dwellings and this should be reflected in Policy H2.

The allocations in Policy H2 should also allow for flexibility in the number of units possible on any given allocation. A clear statement should be included in the policy, which identifies that the allocations assigned to each location are minimum requirements reflecting advice in KSS14 and would be reliant on the developability of individual sites. Whilst the Council has been reluctant to be specific on the land parcels involved, it has chosen to be specific on the number of units it expects from each of the broad locations. On further analysis, it could be quite possible that a lack of constraints in a particular area might prompt the possibility, or even the desirability, of providing additional units in any given location. The policy does not appear to allow for this and should be amended to explain that the numbers assigned to any given area are not fixed and that further consideration will be given to the eventual number of units on a site by site basis, through the Allocations DPD. If land such as the site at Stambridge Mill does not come forward, the policy as currently drafted provides no flexibility to ensure that alternative sites come forward.

2. There is no justification for the phasing of development

The Council's limited reasoning for phasing set out in the Core Strategy is not justified. It is also contradicted by the statement found in policies H2 and H3 which states;

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

The phasing is either necessary for a material reason set out in the document or the allocation of land will be flexible to ensure a continuous five year supply is maintained. If the phasing is to remain, more detailed explanation is required. In the absence of any reasoned justification, it appears that the main reason for the phasing is to stagger the release of land over the plan period. Staggering development in this way is not necessary if the authority is maintaining a constant 5 year supply. RSS14 advocates that the allocations it provides the districts are minimums and that authorities should not see them as ceilings. The CS is presented in such a way as to imply that the Council could suspend development, if demand exceeds any particular phase. Such an approach, of applying the brakes to keep in line with the phasing of the plan, would be completely at odds with RSS14 and the Government's approach to housing delivery. The Core Strategy does not provide for the possibility of the market delivering more than the RSS minimum allocation or at a faster rate than the phasing allows; this is inflexible and contrary to PPS3, paragraph 52 which recognises the importance of a flexible supply of land for housing. This comment is made without prejudice to our client's land at East Ashingdon as this land can be delivered in the early part of the plan period in accordance with the policy.

3. The means by which the sites are identified is too vague.

Whilst the respondent supports the general locations identified in the CS, the means by which the land is identified is considered too vague. The respondent does not agree with the Council's opening statement in this section of the Strategy, which states:

"It is not the purpose of the Core Strategy to set out precise locations for new development - this is done through the Allocations Development Plan Document".

Whilst it may not be necessary in Rochford to identify the exact boundaries of strategic sites, the information that is given is too vague. The advice in Planning Policy Statement 12, Local Spatial Strategy (PPS 17, 2008) is that:
"Core Strategies may allocate strategic sites for development. The Core Strategy looks to the long term. It may be beneficial to delivery of its objectives for details of key sites to be included in it, where these sites are central to the achievement of the strategy and where investment requires a long lead-in"
Further, at paragraph 4.3, it states:
"it is essential that the core strategy makes clear spatial choices about where developments should go in broad terms. This strong direction will mean that the work involved in the preparation of any subsequent DPDs is reduced. It also means that decisions on planning applications can be given a clear steer immediately."

There can be little dispute, that the greenfield locations identified in the Core Strategy are essential to the delivery of the spatial strategy. At present, the district cannot demonstrate a 5 year supply of housing land, as required by PPS3. The lack of a 5 year supply may result in a rash of early planning applications coming forward on greenfield land, which could undermine the Council's spatial strategy and the preparation of the Allocations DPD. To guard against this and to channel development towards the most appropriate locations, the Council has the option of being more site specific in its Core Strategy. This option would in principle be supported by PPS12 and could apply to the delivery of one or more of the Ashingdon locations identified in Policy H2 and thus assist the Council in demonstrating a five year supply of housing land.

It is acknowledged in Policy H2 that the Council will be flexible with regard to the timing of the release of land to ensure a five year supply of land. Therefore, there is no reason not to be site specific on sufficient land that will bring forward development to meet the Council's current 5 year shortfall. The respondent feels that the land north and south of Brays Lane would be one such location, which could be specifically allocated in the Core Strategy. The land has been broadly identified by the Core Strategy and its early release would ensure a continuous five year supply, assist in the delivery of public open space, a long held aspiration of the Local Plan and more importantly, resolve a long standing and the pressing need to improve access to King Edmund School.

4. The names of the allocations are misleading and are not consistent with the Key Diagram
Whilst the respondent supports the allocations described as East and South-East Ashingdon and the locations indicated on the Key Diagram, the names given to the allocations causes' unnecessary confusion.

The Key Diagram does not have symbols identifying the extensions to the residential envelope at geographical locations, which correspond with land that would be understood as East and South-East Ashingdon. The Ashingdon parish boundary terminates along Brays Lane. The land south of Oxford Road is thus fully within Rochford. We submit that the allocation under policy H2 covering land north and south of Brays Lane should be described as South Ashingdon. The land south of Oxford Road should be described as North East Rochford.

The infrastructure requirements set out in Appendix H1 appear to be linked to the individual greenfield release of land and therefore the provision of site specific contributions, not district wide off-site provision. The infrastructure required for each release set out in Appendix H1 can be adequately secured through Planning Obligations attached to the planning consents relating to the individual releases of land. The obligations would then ensure that the infrastructure for the site took place ahead of occupation.
Proposed Amendment to Policy H2: In order to maximise the development potential and delivery of sites and make the policy sound, the following changes should be made to the policy:
* Combine policies H2 and H3 and delete reference to the different time periods;
* Amend "East Ashingdon" to read "South Ashingdon" and "South-East Ashingdon" to read "North-East Rochford"; and
* Amend the capacity of the site identified as East Ashingdon (i.e. north and south of Brays Lane) to 150 dwellings.

Masterplan/Facilities plan Council ref AE22

ROCHFORD CORE STRATEGY SUBMISSION DOCUMENT, SEPTEMBER 2009
RESPONSE OF ESSEX COUNTY COUNCIL


1. General Comment

Essex County Council welcomes and broadly supports the Core Strategy prepared by Rochford District Council. The Strategy contains policies and proposals that address the spatial characteristics, issues and opportunities facing the District whilst respecting the distinctive qualities of the different settlements and parts of the District.

The County Council fully supports the maintenance of a strong policy approach to protection of the Green Belt and of the quality of environmental assets in the District whilst making adequate housing and employment provision within the District. The Core Strategy presents an approach that emphasises a balance of opportunity through the District and recognition of emerging economic prospects in the District and neighbouring areas. The intended preparation of more detailed Action Area Plans for London Southend Airport and its environs and for each of the three town centres of Rayleigh, Rochford and Hockley will further enhance the approach of the Core Strategy. The emphasis on the three town centres is particularly welcomed as offering a stimulus to improvement in the services and facilities available locally within the District whilst also affording possibilities of increased community focus.

2. Housing Distribution and Locations

The East of England Plan requires Rochford to provide a minimum of 3,790 additional dwellings between 2006 and 2021. In addition, provision for a further 1,000 dwellings should be made between 2021 and 2025 to ensure delivery of housing for at least 15 years from adoption of the Core Strategy (expected in 2010). Of this total requirement the District Council has identified a capacity of 2,000 dwellings through a Strategic Housing Land Availability Assessment. This means that the Core Strategy has to identify locations for about 1,750 dwellings to be delivered before 2021 and a further 1,000 dwellings between 2021 and 2025.

Policy H1 (The efficient use of land for housing) is supported. However, prioritisation of the reuse of previously developed land within settlements for additional housing is unlikely to provide a sufficient source of provision due to the generally residential nature of existing settlements in the district and the absence of potentially large sites of previously developed land. The assessment of potential for additional housing provision within settlements already includes the proposed re-allocation to substantially residential use of 4 existing employment areas.

Within Policy H2 (Extensions to residential envelopes and phasing) and Policy H3 (Extension to residential envelopes post-2021) the District Council has adopted a balanced approach to the distribution of additional housing locations, which is based on identification of tiers of settlements defined by reference to their accessibility to jobs, services and facilities (some of which lie outside the District) and the need to protect the valued environments within the District. This approach is generally supported, although implementation and delivery of individual schemes should give further thought to securing sustainable functional relationships between proposed development locations and availability of jobs, services and facilities.

The proposed scale and phasing of development at each of the identified locations in Policy H2 and Policy H3 should be capable of being supported by County Council service groups, provided that adequate and timely funding is available. The County Council would wish to work with the District Council to ensure that future infrastructure and facilities would serve and give benefit to the existing adjoining community as well as to the new development. In this respect it is noted that the Core Strategy proposes preparation by the District Council of a Planning Obligations and Standard Charges document (Policy CLT1). The District Council's document should fully reflect the County Council's own approach to this matter as set out in the County Council's 'Developer's Guide to Infrastructure Contributions'.

3. Economic Development

The approach to Employment Growth (Policy ED1) is supported. Given the economic structure of Rochford District the support to be given to protection and enhancement of the role of small and medium sized businesses; enhancement of the District's commercial centres; and development of a skills training academy is particularly welcome. These measures will assist in building on the existing economic resource of the District.

Proposals for the comprehensive development of London Southend Airport and its environs (Policy ED2) are supported. The further elaboration of proposals through an Area Action Plan will provide a firm foundation to realise the economic regeneration and growth opportunities presented by effective use of the Airport. The recognition of the potential environmental impact of the Airport and the commitment to work to mitigate any adverse impacts on the environment and local amenities is fully supported.

The location of the proposed Eco-Enterprise Centre to the North of London Southend Airport (Policy ED4) is supported. Creation of the Centre would assist reduction of the rate of business start-up failure in the district. Further the proposed location for the Centre would afford a clear offer to businesses within an area of varied business activity.

The continued protection and enhancement of existing employment land (Policy ED3) is supported, as is the identification of 4 existing employment sites for appropriate alternative, substantially residential, uses. Each of the 4 sites affords particular issues and opportunities whereby their redevelopment for other uses and relocation of existing occupiers would confer advantage for the immediately neighbouring areas and for the District as a whole.

4. Town Centres

The town centres of Rayleigh, Rochford and Hockley, and future plans for them, are closely linked to the economic development of the District but also present the opportunity to offer greater community focus within the District. The varied approach being taken to each of these town centres is supported (Policy RTC4, RTC5 and RTC6), notably the recognition of the role and purpose of the town centres beyond retail uses.

The contribution that the County Library service could make to plans for the town centres should not be overlooked. The 5 libraries in the District are substantial footfall draws in their localities and act as a 'community anchor store'. This has knock-on effects in encouraging use of neighbouring retail and service facilities. Further the Library service is currently looking at co-location opportunities for other services within the libraries which would enable them to act as a community focus.

5. Transport

The transport aspects of the Core Strategy are well balanced in identifying potential measures that would meet the needs of existing residents and businesses in the District as well as needs arising from future development. The approach reflects and makes good reference to the transportation aspirations of the County Council. The policy emphasis on close working between the District Council and the County Council to advance the transport aspirations is welcomed and fully supported.

In relation to parking standards (Policy T8 and Paragraph 10.30) the review undertaken by Essex County Council in conjunction with the Essex Planning Officers Association has now been completed. Revised parking standards have been agreed and signed off as County Supplementary Guidance, in accordance with PPS12, and is being applied by the County Council as Local Highways Authority.

6. Coastal Protection Belt

Policy ENV2 (Coastal Protection Belt) is not supported because in its current form it is not a suitable or effective replacement policy for Policy CC1 of the Replacement Structure Plan. Structure Plan Policy CC1 (The Undeveloped Coast - Coastal Protection Belt) currently remains a 'saved' policy of the Essex and Southend-on-Sea Replacement Structure Plan, April 2001 (following a direction of the Secretary of State, dated 27th September 2007, under paragraph 1(3) of Schedule 8 to the Planning and Compulsory Purchase Act 2004). The existing Policy CC1 reads,
'Within the Coastal Protection Belt defined in adopted local plans there shall be the most stringent restrictions on development within the rural and undeveloped coastline situated outside existing built-up areas, and any development which is exceptionally permitted within this Belt shall not adversely affect the open and rural character, historic features or wildlife.'

Core Strategy Policy ENV2 should be revised to include specific reference to,
* Definition of the boundary of the Coastal Protection Belt in another Development Plan Document;
* the application of the most stringent restrictions on development within the rural and undeveloped coastline;
* any development exceptionally permitted not adversely affecting the open and rural character, historic features or wildlife.

7. Historic Environment

The importance of the historic environment in Rochford District is clearly identified within the Core Strategy document. Nevertheless, the policy guidance could be usefully enhanced to promote consideration and enhancement of the historic environment and use of the historic environment to shape place. This would be achieved by the following amendments to the Core Strategy,

* Policy ENV1 (Protection and Enhancement of the Natural Landscape and Habitats and the Protection of Historical and Archaeological Sites) should be amended by deletion of the final sentence and its replacement with,
The Council is committed to the protection, promotion and enhancement of the diverse historic landscape and extensive surviving archaeological deposits of the District.

* Paragraph 8.15 of the supporting text should be amended to better support the suggested amendment to Policy ENV1. The existing text of Paragraph 8.15 should be deleted in its entirety and replaced by,
The historic environment of Rochford District has developed through a history of human activity that spans over 450,000 years. Much of the resource lies hidden beneath the ground in the form of archaeological deposits. Other elements such as the historic landscape, the pattern of field, farms, woods and grazing marsh which characterise the District, are a highly visible record of millennia of agriculture, industry and commerce. Of particular significance are the coastal, island and estuarine areas where multi-period landscapes reflecting the exploitation of coastal and marshland resource survive. The District also includes the important historic medieval market towns of Rochford and Rayleigh.

* Page 16 (Sustainable Community Strategy Priority: Promoting a Greener District) should be amended to further support the approach to the Historic Environment. The fourth bullet of the Key Section/Policies of the Core Strategy should be amended to include the word 'historic', so that the first sentence of the bullet would read,
The Environment chapter seeks to protect and enhance the biodiversity, historic and natural environment of the District by protecting sites of local, national and international importance.

8. Community Infrastructure

The approach to Community Infrastructure is supported. The County Council would wish to work with the District Council to ensure that future community infrastructure and facilities would serve and give benefit to the existing adjoining community as well as to the new development. In this respect it is noted that the Core Strategy proposes preparation by the District Council of a Planning Obligations and Standard Charges document (Policy CLT1). The District Council's document should fully reflect the County Council's own approach to this matter as set out in the County Council's 'Developer's Guide to Infrastructure Contributions'.

In addition, it should be noted that,
* Some County Council services are not highly visible despite being regarded as highly desirable community services by local residents. The need to ensure adequate funding and contributions to enable these services to meet community expectations should be recognised and acknowledged in consideration of planning obligations and standard charges.
* The Adult Community Learning Centre at Rocheway, Rochford could be better located with regard to the wider Rochford/Castle Point area of service. Relocation of the Centre could provide opportunities both at the new location and for the current site.
* The Core Strategy should make specific reference to,
o Appendix H1, Location at South Canewdon: new Early Years and Childcare facilities;
o Policy CLT2, final sentence: insert after the words 'primary schools' the words 'and Early Years and Childcare facilities;
o Appendix CLT1, Other issues/comment: for Early years and childcare facilities add 'Land to be allocated within new residential areas, as appropriate'.

9. Implementation, Delivery and Monitoring

The inclusion in the Core Strategy of a section considering Implementation, Delivery and Monitoring is welcomed and supported. Nevertheless, the District Council, in moving towards implementation and delivery of the individual elements of the Core Strategy, should highlight those schemes and projects that are critical to achievement of other aspects of the Strategy.

Further, the monitoring proposal for Policy H6 (Lifetime Homes) and for Policy CP1 (Design) should be amended,
* Policy H6 (Lifetime Homes) - the identified monitoring tool is Core Indicator H6 Housing Quality Building for Life Assessments. The Building for Life Assessment methodology was devised to measure the overall design/layout quality of housing developments. It was not devised to measure compliance with Lifetime Homes, which is largely, but not exclusively, concerned with internal space standards and the provision of internal arrangements within dwellings to meet needs of all residents.
* Policy CP1 (Design) - the monitoring indicator proposed by the Core Strategy is not supported because it is unclear what the indicator would actually be measuring. The proposed indicator should be replaced by the Core Indicator, Housing Quality - Building for Life Assessments, as suggested by the County Council in its response to the Core Strategy Preferred Options, October 2008. A better approach would be to base evaluation and monitoring of Policy CP1 on the Commission for Architecture and the Built Environment's (CABE) 20 Building for Life principles, particularly as Government has endorsed these principles and is urging local authorities to use them to assess design quality. It is suggested that the monitoring arrangements for Preferred Option CP1 be deleted and replaced by the following text,
'The success of the implementation of this policy will be monitored by assessing schemes, or an appropriate sample of schemes, against the Commission for Architecture and the Built Environment's (CABE) Building for Life principles.'

10. Access to Housing

The Core Strategy notes the higher prevalence of older people in Rochford District and the need to support them. However, a more broadly based approach to access to housing should be adopted by Policies H4, H5 and H6. It should recognise the presence of other vulnerable adults in the community, for example, those with learning or mental health disability, and the range of possible forms of accommodation, including supported, sheltered and extra care accommodation. The high level of owner occupation in the District further emphasises the need for a broader approach. The emphasis on Lifetime Homes would not address the variety of future needs, whilst the potential exemptions to the Lifetime Homes policy standard in Policy H6 are likely to act against demographic trends.

Re: Objection to Rochford Core Strategy 175 Houses in Hawkwell is Unsound

The proposal in the Rochford Core Strategy for this many houses in the Ward of Hawkwell West in UNSOUND because the vital requirements of the Government's Planning Policy are not met n 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 the Planning Policy are as follows:

Travel
Limited public transport - one bus an hour
Increase car us causing heavy congestion - main road through Hawkwell is almost at its full capacity
Inability to improve highways - attended recent meeting involving Highways Department, there is no improvements to local roads in the foreseeable future
Distance from the shops
Distance from rail stations

Environment
Semi rural location unsuitable for large development
Complete loss of character - Hawkwell is a village, let's keep it a village.
Loss of green belt - green areas should be maintained so that the next generation can enjoy it as we have
Loss of wildlife - an area frequented by badgers, foxes and hawks
No social, economic or environmental benefits whatsoever

Further development in Hawkwell West does not comply to the Core Strategy because the criteria is that a development is located in an area where alternatives to car use are more viable, reducing the requirement to travel. 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.

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

Re: Objection to Rochford Core Strategy 175 Houses in Hawkwell is Unsound
The proposal in the Rochford Core Strategy for this many houses in the Ward of Hawkwell West in UNSOUND because the vital requirements of the Government's Planning Policy are not met n 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 the Planning Policy are as follows:

Travel
¬Limited public transport - one bus an hour
Increase car us causing heavy congestion - main road through Hawkwell is almost at its full capacity
Inability to improve highways - attended recent meeting involving Highways Department, there is no improvements to local roads in the foreseeable future
Distance from the shops
Distance from rail stations

Environment
Semi rural location unsuitable for large development
Complete loss of character - Hawkwell is a village, let's keep it a village.
Loss of green belt - green areas should be maintained so that the next generation can enjoy it as we have
Loss of wildlife - an area frequented by badgers, foxes and hawks
No social, economic or environmental benefits whatsoever

Further development in Hawkwell West does not comply to the Core Strategy because the criteria is that a development is located in an area where alternatives to car use are more viable, reducing the requirement to travel. 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.

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

Re: Public Consultation - LDF Core Strategy

I wish to register my objections to the proposal to build 175 houses in South Hawkwell (which does not exist and is in fact Hawkwell West), on the grounds that it is unsound and legally incompliant with the Council's own Core Strategy and the Government's PPS12 Policy for the following reasons:

Travel

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

I am told Essex County Council has already acknowledge concern with regard to the bottleneck at the railway bridge at St Mary's Church where additional traffic from other proposed developments in the District will 'rate run' to and from the B1013.

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

Environment

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. This development, if it is to be off Rectory Road, will cause the urban coalescence of Hockley to Ashingdon via Hawkwell, surely this is not in line with spatial planning.

In Short:
Semi rural location unsuitable for large development
Complete loss of character
Loss of green belt
Loss of wildlife (I note the Environmental Report does not mention Muntjack deer located on the site)
NO social, economic or environmental benefits whatsoever

I believe locations for development are based on the 'Call for Sites'. Surely locations should be based on the sustainability criteria within PPS12 and not on something that suits landowners? 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.

We are supportive that the council have identified housing provision with Canewdon. It is considered that this location is sustainable due to its location adjacent to the existing village. The provision of development in this location will enable existing village facilities to be supported and retained. Furthermore there is sufficient adjacent to the village to provide comprehensive development.

The change we would like to see is that policy H2 is altered to refer to North West Canewdon or simply Canewdon. It is considered development can be better located on Brownfield site of the farm yard and waste ground rather than Greenfield sites. Development in this location will be constrained by the existing contours of the land. The allocation of land will be further considered in the Allocations Document following the SHLAA and as such the reference to Canewdon within the Core Strategy should be less site specific within this general strategy.

I submit herewith my objections to this Council's core strategy concerning future development of 175 houses in Hawkwell West.
In response to the proposal to build 175 (core strategy) or 30 (planning request Wilson homes) new homes off of Rectory Road Hawkwell. I find the proposal absolutely horrifying, totally insensitive to, out of keeping with, and a blot on the landscape for, the area proposed.

This proposed development is totally UNSOUND in my opinion for the following reasons. The infrastructure of the area will not sustain the influx of 1200+ people, our schools are already full and desperately short of teachers, there is only one NHS dentist with a huge waiting list and since the death of Dr Sen his Rochford and Hawkwell surgeries have been manned by locums as no full time Doctor can be found, in fact the Hawkwell surgery is to be closed for this reason. Our water pressure is limp to say the least, and there are on average 2 power cuts a year, after any kind of heavy rain the junction of Rectory Road and main road floods as the drain cannot take the flow. As for Rectory Road it is already struggling with the extra demand of traffic from Ashingdon cutting through to Cherry Orchard way and the A127. The approach from Rayleigh down Main Road past the Spa PH is a nightmare already and very often backs up from the Spa PH to Bullwood Hall. Ashingdon Road is a no go zone at school drop off/pick up times as are the roads around greensward academy/Hockley station area. These roads cannot cope with an additional 500+ cars and as far as I can see the only pathetic suggested remedy, is to widen the junction of Rectory Road and Main Road to allow 2 exits lanes, as this widening of the junction only goes a few metres it will do absolutely nothing to alleviate congestion at this junction, and what of return journeys into Rectory Road?

There is also a question of employment, we have a gross lack of local employment, and it therefore follows that the majority of the people moving into these homes will have to commute.

As for the land itself, much of it is green belt, so designated to stop exactly this kind of urban sprawl proposed. There is an area of trees to the rear of my property covered by a preservation order; I was told by one of "WILSON HOMES" representatives that some of the main substantive ones will be kept.

They "ALL" have a preservation order and they "ALL" must be kept.

I was told if they have an order they would be. However, I know darn well that if they are in the way, and they will be, they will just cut them down one dark night and pay the fine accepting it as a mild irritation.

And without a care for the environment or the wildlife these wooded areas support.

To summarise:
We have limited public transport
There will be increased car use causing heavy congestion
An inability to improve highways
An unwalkable distance from shops and railway
This is a semi rural area unsuitable for large development which will suffer complete loss of character
There will be a loss of wild life and habitat
A loss of green belt
No social, economic or environmental benefit
There is also a limit to the infilling and intensification an existing settlement can sustain, a limit already exceeded n Hawkwell west
All of these items are key to the core strategy

Finally
This proposal will completely change the environment in which I live and love. I do not want to live bordered on 3 sides by a huge housing estate and

On the fourth side by a really busy road with all the noise and pollution it will produce. I do not want to live through years of construction noise, and vehicles thundering past my house covering the road with mud and my house and garden in dust.

I ask you to reject this proposal

The Hawkwell Residents Association has discussed the RDC Core Strategy Submission document and wishes 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/Hal 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.

We are supportive that the council have identified housing provision with Hawkwell. It is considered that this location is sustainable due to its close proximity to existing town centres. The provision of development in this location will enable highway infrastructure improvements which will ease current congestion. Existing previously developed sites existing within Hawkwell, (e.g. Magees Nurseries) offer opportunities for redevelopment of Brownfield land in line with government objectives. Furthermore there is sufficient adjacent land in this location to provide comprehensive development.

The change we would like to see is that policy H2 is altered to refer to North Hawkwell or generally to Hawkwell. It is considered development can be better constrained by the existing railway in the north of Hawkwell and will prevent sprawl to the south however this will be further considered in the Allocations Document. The reference to Hawkwell within the Core Strategy should be less site specific within this general strategy.

Using green belt land north of London Road is contrary to the National Policy PPG62 Core Strategy Preferred Options page 42 GB1 Green Belt Protection page 55 Flood Risk Planning Policy Station 25 requires that flood risk is taken into account at all stages of the planning process page 56 managing risk.

Other brown field sites should be used instead.

Flooding has happened due to local Council and development now the environment has the problem PPS25 risk assessment should be assessed by an independent company on the problem that we take without directing more water into Zone 3 where we live.

Core Strategy Submission Document - Rawreth

The local development framework which includes building 770 houses between London Road and Rawreth Lane. This plan is totally unsound for the following reasons:-

i) We are a rural community, this development would double our population of Rawreth.

ii) Productive farmland should not be allowed to be developed on. Food is going to be in serious short supply in the near future.

iii) There are other Brownfield sites that can be used instead.

iv) Building on this land will put unsustainable pressure on our B roads and amenities.

v) We are unfortunate to have an Asda supermarket on our housing estate. We already suffer with noise from the lorries and refrigerated lorries, car alarms ringing in the car park. This development would double the amount of lorries into Asda and cars into the car park.

vi) Please think how this will affect our lives.

vii) Please put the existing residents health and welfare first.

I am writing to object to Rochford's Core Strategy for 175 houses in Hawkwell which I believe is unsound.

The proposal in the Rocford Core Strategy for this many houses in the Ward of Hawkwell West is unsound because the vital requirements of the Governments planning policy are not met in terms of sustainability, and therefore the Hawkwell West (South Hawkwell) should be removed by the inspector and the allocation moved to a sustainable location.

In summary I object to this application for the following reasons.

1. Increased congestion on roads. The B1013 and surrounding feeder roads are already nearing their safe maximum capacity.
2. Inability to improve highways. The current road ways cannot accommodate the increased traffic without significant widening and improvements.
3. Distance from shops. There are no shops located within walking distance of this development.
4. Limited public transport. The current bus service is poor and Arriva have no plans to improve it.
5. Distance from railway station. Distance to the railway station and the lack of public transport will only encourage the use of private cars.
6. Semi-rural location unsuitable for large scale development. Any large scale development would mean a continuous coalescence of development between Hockley and Ashingdon via Hawkwell with the subsequent loss of community identity.
7. Loss of green belt. It is the council's duty to protect Green Belt from development at all cost. Brown field sites should always be preferable.
8. Loss of wild life. Wildlife diversity in the area will be reduced and the loss of habitat will almost certainly see the extermination of Muntjac deer in the area.
9. Loss of character. Rochford District Council has a duty to promote healthy communities and maintain the character of the area.
10. No social economic or environmental benefits.
11. Drainage system is not built for more housing.

See attached sheet

Council reference AE01

See statement

Council ref AE02

See statement

Council ref AE03