Policy ENV1 - Protection and Enhancement of the Natural Landscape and Habitats and the Protection of Historical and Archaeological Sites

ROCHFORD DISTRICT COUNCIL - LOCAL DEVELOPMENT FRAMEWORK CORE STRATEGY SUBMISSION SEPTEMBER 2009

Iceni Projects Ltd (Iceni) has been instructed by Colonnade Land LLP (Colonnade) to submit representations to the Rochford Local Development Framework Core Strategy Submission (CSS).

a) Overview

It is our conclusion that the CSS is not justified, effective or consistent with national policy, as required by Planning Policy Statement 12: Creating Strong Safe and Prosperous Communities through Local Spatial Planning (PPS12) and is therefore vulnerable to being found unsound by an Inspector through the Examination in Public.

b) Background and Summary

These representations follow those made by Iceni on behalf of Colonnade to the Preferred Options Core Strategy, submitted via letter dated 17 December 2008. In this regard, we would request that the Council confirms that the representations made to the Preferred Options Core Strategy will be taken into account alongside the current representations, particularly as there are a number of cross references between the two sets of representations.

It is not considered necessary to reiterate the content of the previous representations, as they were made at the appropriate stage and will be considered by the Planning Inspectorate in due course, but it is inevitable that certain elements will require restating where it is not clear that they have been taken into account in the production of the CSS. For clarity, therefore, Colonnade feel that it is appropriate to clarify the 'in-principle' issues that were raised in the representations to the Preferred Options Core Strategy, recognising that these issues were raised in the context of a wider and more coherent justification made within the representations:

• Further cross-referencing of the recommendations made within the evidence base is required;
• Greater focus should be placed on promoting Rochford as the principal settlement within the District;
• Coombes Farm is the most logical location for residential development abutting the urban area of Rochford and as such warrants recognition as a general location for residential development;
• The allocation of Three Ashes Farm for employment generating uses will be pursued;
• Recognition that it is not realistic to expect residential allocations to be met mainly on Brownfield sites, nor should the intensification of smaller sites in residential areas be pursued;
• Many of the sites identified as suitable for residential development will not be viable and will not come forward for development within the timescales anticipated;
• The failure to provide the necessary justification for the proposed infrastructure improvements sought in Appendix H1;
• The inclusion of an affordable housing exception policy was sought; and
• The need to identify sites capable of delivering employment growth in the short term.

Following assessment of the CSS presented by the Council for consultation prior to submission to the Secretary of State, Colonnade considers the Plan to be 'unsound' as the document consistently fails to meet the tests of soundness set out in the table following Paragraph 4.52 of PPS12. For clarity, PPS12 confirms that to be 'sound' a Core Strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY and defines 'justified' as "founded on a robust and credible evidence base" and "the most appropriate strategy when considered against the reasonable alternatives" and 'effective' as "deliverable", "flexible" and "able to be monitored".

The rationale for the above is identified in the remainder of these representations, which are provided in the interests of ensuring the Council delivers a strong, robust and logical Core Strategy that guides the future development of the District in a justified and effective manner.

b) Colonnade

As the Council is aware from previous submissions to the Local Development Framework, Colonnade is a strategic land company with a particular interest in the future development of the District as a consequence of a number of sites that it controls, particularly around Rochford.

The Council will also be aware that Colonnade has recently submitted an outline planning application for the residential development of the land at Coombes Farm, Rochford to provide a sustainable urban extension comprising up to 326 residential dwellings, with associated accesses and community uses. Whilst the planning application process is clearly separate from the Local Development Framework production process, Colonnade wishes to continue the promotion of the site as a suitable location for residential development.

Accordingly, these representations focus on the legal requirements and tests of soundness associated principally with the Housing and Employment chapters of the CSS, with reference where appropriate to the sites that are controlled by Colonnade, the outline planning application at Coombes Farm and other issues where relevant.

c) Housing

i. Date of Adoption

The CSS assumes an adoption date of 2010 and plans for the provision of housing to 2025.

Taking account of the potential delays to the adoption of the Plan, including the Examination process, it would be more appropriate for the CSS to provide sufficient flexibility to allow for delays in its adoption. Colonnade considers an adoption date of 2011 for the CSS is a more realistic target.

Taking account of the advice in Paragraph 4.13 of PPS12, which states that the time horizon for the Core Strategy should be "at least 15 years from the date of adoption" it would be appropriate for the CSS to plan for the provision of housing to 2026 at the earliest. As such, Colonnade does not consider the CSS to be 'flexible' in the context of the tests of soundness in the table following Paragraph 4.52 of PPS12.

ii. Housing Delivery

However, setting the above aside, the Housing Chapter identifies the minimum housing delivery target for the period 2001 to 2021 of 4,600 dwellings as set out in the East of England Plan, with the annual average requirement of 250 dwellings per annum to extend provision from 2021 to 2025. It also confirms that the residual target for the period 2006 to 2021 is 3,790 dwellings, taking account of the delivery of 810 dwellings in the period 2001 to 2006, and a further 618 dwellings have been completed between 2006 and 2008.

This leaves a residual housing provision target of a minimum of 3,172 dwellings in the period 2008 to 2021. Taking into account the required provision beyond 2021, the residual housing provision target in the period 2008 to 2025 is a minimum of 4,172 dwellings. The disparity between these figures and those provided within the CSS are explained by the rounding down of the annual average delivery requirement in the period 2006 to 2021 to 250 dwellings per annum, compared with the actual figure of 252.67.

The table at Paragraph 4.6 of the CSS identifies the source of housing provision that will meet the identified minimum requirements and includes figures for 'Extant Planning Permissions' and 'Existing allocations/other appropriate sites identified in Strategic Housing Land Availability Assessment'. These figures, along with the actual completions within the period are combined to produce the figure for the 'Total without Green Belt release' figure.

Setting aside the concern regarding under-provision associated with the rounding down of the annual average delivery requirement in the period 2006 to 2021, the CSS fails to identify the sites that will contribute to the 'Extant Planning Permissions' provision. The identification of the sites that will contribute to the 'Extant Planning Permissions' should be provided in the context of the findings of the Inspector in the appeal by Asprey Homes [APP/G5180/A/07/2043219/NWF] who determined that the reliance on a delivery rate of 100% is unsafe [IR287].

Furthermore, at the time of writing these representations, the Strategic Housing Land Availability Assessment 2009 has not been published. It is impossible therefore for a full assessment of the proposed housing provision to be undertaken to confirm whether the CSS is 'founded on a robust and credible evidence base' [test of soundness in the table following Paragraph 4.52 of PPS12].

iii. Redevelopment of Employment Sites

Paragraph 4.14 of the CSS refers to the identification of the four employment sites that are considered by the Council to be suitable for redevelopment to residential use. However, the failure to publish the Strategic Housing Land Availability Assessment 2009 either before or alongside the publication of the CSS means that the assumptions made by the Council as to the suitability, availability, viability and deliverability of the sites cannot be assessed.

It has been necessary, therefore, to review the assumptions made in the Rochford Urban Capacity Study 2007 (UCS) regarding the sites. Within the section of the UCS entitled 'Redevelopment of Established Employment Land' [pages 22 & 23] includes a list of those sites assessed, their indicative capacities and the probability of residential development coming forward at the sites within the plan period (identified elsewhere as 2001 - 2021). The list includes the four sites identified in the CSS of Eldon Way/Foundry Estate, Hockley; Rawreth Lane Industrial Estate, Rayleigh; Stambridge Mills; and Star Lane Industrial Estate, Great Wakering.

In total, the UCS identifies an indicative residential redevelopment capacity of 486 units on the four sites (118, 220, 60 and 88 respectively). Of these, it identifies the Rawreth Lane Industrial Estate and Stambridge Mills as having a 'high' probability of coming forward for development in the Plan period (2001 - 2021), which would deliver 280 residential dwellings using the Council's own figures. The Star Lane Industrial Estate (referred to in the UCS as the Star Lane Brickworks) is identified as having a 'medium' probability of coming forward for development in the Plan period, with capacity to deliver 88 residential dwellings. It is unclear, therefore, where the figure for 'Existing allocations/other appropriate sites identified in Strategic Housing Land Availability Assessment'.

Set against this is the identification of these four sites in the CSS as being capable of delivery for residential development within the Plan period, with 671 units delivered between 2006 and 2015 and a further 506 units between 2015 and 2021.

The UCS also states in the same section that:

"There are considerable areas of land in the district that are currently allocated for, and in use as, employment land. The redevelopment of such sites for residential use would reduce demand for residential development on greenfield sites, but would at the same time create a need for alternative sites to be found for employment. Such an approach, which would be likely to require the decontamination of existing employment land to make it fit for residential use, together with development of a greenfield site and implementation of additional infrastructure to serve the new employment area, may well be unsustainable." [our emphasis]

The UCS appears to confirm therefore, that not only would the redevelopment of the four sites listed in the CSS be unlikely within the Plan period, but also potentially unsustainable. In this regard, it is notable that the promoters of Stambridge Mills sought the Screening Opinion of the Council as to whether Environmental Impact Assessment of the planning application for the redevelopment of the site for residential use was required in 2007, but to date are yet to submit a planning application for the redevelopment of the site.

In light of this, Colonnade does not consider the CSS is 'the most appropriate strategy when considered against the reasonable alternatives' [test of soundness in the table following Paragraph 4.52 of PPS12], which include the provision of residential development in East Rochford.

iv. Strategic Housing Growth to the East of Rochford

Furthermore, whilst paragraph 2.62 of the CSS identifies concern relating to the identification of locations to the east of Rochford for development on the basis that 'vehicular movements would inevitably be directed through Rochford's historic core', the CSS later identifies Stambridge Mills as a suitable site for residential redevelopment.

In light of the evident conflicts between the evidence base provided in support of the CSS and the absence of other evidence, the CSS is not considered 'sound' in the context of the tests of soundness in the table following Paragraph 4.52 of PPS12.

v. Housing Trajectory

Paragraph 4.28 of the CSS confirms that policies H1, H2 and H3 of the CSS will deliver housing supply as illustrated in the Housing Trajectory at Appendix H2. This Housing Trajectory is transposed from the 2008 Annual Monitoring Report (AMR).

Whilst on the face of it, the Housing Trajectory appears to confirm that the Council can meet its requirement to identify a five year housing supply, many of the sites identified within the AMR do not conform to the guidance issued by CLG in August 2008, on the assessment of a five year land supply. The guidance identifies sites that can be included within the five year assessment of housing supply as:

"those that are allocated for housing in the Development Plan, sites that have planning permission (outline or full planning permission that has not been implemented) and specific, unallocated brownfield sites that have the potential to make a significant contribution to housing delivery during the 5 year period".

Table 4.10: Projected Net Completions of the AMR confirms that the five year housing land supply figure includes sites from 'other land allocated for residential purposes', which are based on land allocations outside existing settlements. However, it should be clarified that these land allocations are not currently allocated for housing development in an adopted Development Plan. As such, these unallocated greenfield sites that are yet to make significant progress through the planning system should be discounted and the five year housing land supply recalculated.

The table below has been prepared to confirm the extent of the shortfall should the sites from 'other land allocated for residential purposes' be removed from the calculation of the Rochford five year housing land supply, in accordance with the guidance issued by CLG:

Recalculated Five Year Housing Land Supply (2009 - 2014):

Year
1st April 2009 to 31st March 2010
Predicted Delivery (A)
106 dwellings
Allocations on 'other land allocated for residential purposes' (B)
0
Residual delivery (A-B)
106 dwellings
Delivery Shortfall
0

Year
1st April 2010 to 31st March 2011
Predicted Delivery (A)
217 dwellings
Allocations on 'other land allocated for residential purposes' (B)
150
Residual delivery (A-B)
67 dwellings
Delivery Shortfall
150

Year
1st April 2011 to 31st March 2012
Predicted Delivery (A)
544 dwellings
Allocations on 'other land allocated for residential purposes' (B)
300
Residual delivery (A-B)
244 dwellings
Delivery Shortfall
300

Year
1st April 2012 to 31st March 2013
Predicted Delivery (A)
395 dwellings
Allocations on 'other land allocated for residential purposes' (B)
375
Residual delivery (A-B)
20 dwellings
Delivery Shortfall
375

Year
1st April 2013 to 31st March 2014
Predicted Delivery (A)
300 dwellings
Allocations on 'other land allocated for residential purposes' (B)
300
Residual delivery (A-B)
0 dwellings
Delivery Shortfall
300

TOTAL

Predicted Delivery (A)
1,562 dwellings

Allocations on 'other land allocated for residential purposes' (B)
1,125 dwellings

Residual delivery (A-B)
437 dwellings

Delivery Shortfall
1,125 dwellings

The above table confirms that the removal of the 'other land allocated for residential purposes' from the calculation of the Rochford five year housing land supply leaves the Council with a minimum net additional housing delivery of 437 dwellings, which equates to a supply of 1.7 years based on the adjusted annual delivery target of a minimum of 255 net additional dwellings per annum. As such, the Council is failing to meet its requirement to demonstrate a five year housing land supply in accordance with PPS3 and the supporting guidance provided by CLG. It is notable that the recent application by David Wilson Homes at Land between Main Road and Rectory Road and Clements Hall Way, Hawkwell identifies an even greater shortfall in the Council's five year housing land supply.

In addition to the above, the AMR does not include a commentary on how deliverability has been assessed against the requirements of paragraph 54 of PPS3.

Furthermore, the guidance from CLG confirms that the windfall sites cannot be relied upon in demonstrating a five year supply unless a Local Planning Authority can demonstrate genuine local circumstances exist to allow this exception. However, the second paragraph of the section entitled 'Housing Trajectory and Five Year Housing Supply' confirms that the estimated completions in the years 2008 to 2013 includes estimated yields through 'intensification' coming forward in future years. With reference to the definition of 'intensification' on page 13 of the AMR, it appears that the 'Housing Trajectory and Five Year Housing Supply' also includes provision for windfall sites. As such, the Council is required to demonstrate the 'genuine local circumstances exist to allow this exception'.

The pressures on delivery and need for additional sites are more acute when it is considered that an average delivery rate of 204 dwellings per annum was achieved during a strong period of housing market growth. In view of the current economic downturn, and significant problems faced within the housing market, the Council should seek to identify appropriate and deliverable sites to meet its regional housing target provision commitments. Suitable sites would include Coombes Farm, which has been positively promoted for development through the LDF process.

It may, therefore, be more appropriate for the Council not merely to allocate sufficient sites to meet the minimum targets set down by the East of England Plan, but to identify a reservoir of land capable of coming forward for development should the sites identified through the CSS and Allocations Development Plan Documents (DPD) fail to come forward for development within the anticipated timescales.

vi. Appendix H1

As set out in the representations to the Preferred Options Core Strategy, there is continuing concern that the list of improvements to infrastructure required in support of residential development as set out in Appendix H1 fails to provide the necessary justification for its inclusion. Whilst the preamble seeks to clarify why the infrastructure is sought, the inclusion of this list should be fully justified, otherwise it is of little value. Furthermore, it would be of benefit to provide further details of the existing community infrastructure provision and capacity within the evidence base.

The failure to provide the necessary justification for its inclusion means that the CSS will not be 'founded on a robust and credible evidence base' [test of soundness in the table following Paragraph 4.52 of PPS12].

d) Character of Place

As set out in the representations to the Preferred Options Core Strategy, Colonnade considers that, with respect to the requirement to produce and adhere to Development Briefs for large residential developments, as set out in Policy CP1, the Council should not seek to impose further demands on developers where existing regulations provide sufficient requirements regarding design. In this instance, Design and Access Statements provide sufficient design guidelines for developments and there is no additional information provided in the policy or supporting text that clearly sets out the justification for this requirement.

e) Green Belt

With reference to the comments regarding the redevelopment of employment sites under the 'Housing' section above and the requirement to allocate sufficient land to meet the minimum housing provision targets as required by the East of England Plan, Colonnade considers that the chapter on Green Belt, and policy GB1 in particular, fails to provide the necessary evidence base that will allow it to be monitored effectively.

It is inherent that the proposed redevelopment of previously developed employment sites for residential use in order to reduce the requirement to allocate previously undeveloped land for residential use will displace these employment uses. In turn, therefore, the separate allocation of previously undeveloped Green Belt to accommodate the compensatory employment provision is required. This is accepted in principle at paragraph 11.11 of the CSS.

Without providing clarification of the anticipated quantum of land required to accommodate the provision of housing and compensatory and new employment land, it is not possible to monitor the performance of policy GB1.

However, using the Council's figures in the table setting out the breakdown of the housing provision figures in Chapter 4 of the CSS (assuming that actual completions and extant permissions are all on previously developed land), setting aside the displacement of employment uses referred to above, approximately 42% of the required minimum housing provision target is capable of being accommodated on previously developed land (2,005 units from a total of 4,750). As such, the Council is required to provide at least 58% of the required minimum housing provision target on the Green Belt (2,745 units from a total of 4,750).

If these figures are adjusted to take account of the displacement of employment uses (assuming the provision of an equal quantity of land is required to compensate for the employment land that is redeveloped), this figure changes to 17.5% on previously developed land and 82.5% on Green Belt (828 and 3,922 units from a total of 4,750 respectively). Even allowing for the achievement of higher densities of employment on new developments, the figures above are unlikely to change significantly.

Furthermore, the table in Chapter 4 also confirms that no previously developed land will be available for development beyond 2021, or 2015 if account is taken of the displacement of the employment uses.

In light of this, not only does Chapter 6 fail to provide the necessary evidence base that will allow it to be monitored effectively, it is also necessary to consider whether it presents the most appropriate strategy for addressing the required release of Green Belt land to accommodate the defined housing and employment delivery targets to 2025 and beyond as necessary. Colonnade considers a more robust approach that is flexible and capable of being monitored, would be to clearly identify those sites capable of delivery in the short term, which for the avoidance of doubt includes those sites being promoted by Colonnade, with a reservoir of alternative sites set aside for future growth.

As set out in the representations to the Preferred Options Core Strategy, Colonnade considers that the inclusion of an affordable housing exception policy within the CSS will aid the delivery of community housing within rural areas. However, the CSS does not contain such a policy, or adequately address the issue of community housing within rural areas and the CSS is not considered to provide sufficient flexibility to allow for the delivery of essential rural housing.

f) Environmental Issues

Colonnade has concerns regarding the justification for and effectiveness of a number of the policies contained within the Environmental Issues chapter, as follows:

• Policy ENV1: The Council fails to identify how it will "maintain, restore and enhance" the sites of nature conservation importance that are identified, or how the performance of this policy will be monitored;
• Policy ENV3: In the context of the advice at paragraph 4.32 of PPS12 regarding the reformulation of national policies, Colonnade does not consider that this policy is required; and

• Policy ENV9: As set out in the representations to the Preferred Options Core Strategy, Colonnade does not consider that the necessary evidence base has been provided to justify a policy that seeks to go above and beyond the policy targets for the Code for Sustainable Homes as set out by Central Government.

g) Community Infrastructure, Leisure and Tourism

Policy CLT1 refers to the requirement for residential and employment development to contribute to the infrastructure identified in Appendix CLT1 through Standard Charges.

However, whilst the general principle of securing planning obligations through the application of standard charges is broadly accepted, the list of infrastructure requirements set out in Appendix CLT1 is not supported by sufficient evidence base to identify its robustness and credibility. As such, Colonnade does not consider either policy CLT1 or Appendix CLT1 is justified in the context of PPS12.

It is also noted that, despite the clarification sought by Colonnade at the Core Strategy Preferred Options stage, the CSS fails to confirm what information should be contained within Health Impact Assessments, which are required by policy CLT4. Once again, Colonnade requests further clarification of what is involved in the assessment and the expected outputs, which will provide greater clarity and will allow the policy to be monitored.

h) Transport

Policy T8 confirms that the Council will apply minimum parking standards. As set out in the representations to the Preferred Options Core Strategy, the guidance in Planning Policy Guidance Note 13: Transport (PPG13) is clear regarding the imposition of parking standards.

Paragraphs 52-56 of PPG13 confirm that the Local Planning Authorities should apply maximum not minimum parking standards. In order to satisfy the legal requirements set out in PPS12, the policy must reflect PPG13 to promote sustainable transport choices and further provide incentives for developers to locate further residential land closer to local service centres by requiring maximum parking standards for residential developments.

i) Economic Development

As set out in the representations to the Preferred Options Core Strategy, the land at Three Ashes Farm provides an excellent opportunity to deliver employment growth in the short term and may be a suitable site for the 'Eco-Innovation Centre' that is being promoted by the Council. Its identification as a suitable location for strategic employment growth, or the provision of an Eco-Innovation Centre, would accord with the general principles of the policies contained within Chapter 11.

The identification of Purdeys Industrial Estate as fit for purpose (in paragraph 11.32 and the Council's 2008 Employment Land Study 2008) and therefore it should be maintained and if possible expanded, is welcomed and Colonnade considers that Three Ashes Farm could deliver this expansion, providing a natural extension to Purdeys Industrial Estate and being strategically located close to the Airport.

Three Ashes would address the negative impacts that the nearby residential area experiences from the existing Industrial Estate by providing a buffer between established uses and the residential area with less intensive employment activities. The highways analysis that has been carried out has suggested that it would not have an adverse impact on roads and congestion. Furthermore, there are very few opportunities for businesses to expand and Three Ashes could provide this opportunity.

j) Conclusions

Following the submission of representations to the Preferred Options Core Strategy, Colonnade is disappointed to note that the CSS fails to take account of the majority of the issues raised in their representations.

In addition, Colonnade considers the plan to be 'unsound' as the document consistently fails to meet the tests of soundness set out in the table following Paragraph 4.52 of PPS12 and respectfully requests that the Council notifies Iceni, on behalf of Colonnade, of the future arrangements for the Examination of the Core Strategy. Furthermore, Colonnade wishes to take this opportunity to formally register a request to appear at all stages of the Examination in Public, including the pre-hearing meeting and any planned hearing sessions whereby issues raised in the context of this letter are to be discussed. Please confirm this request, and that the representations made to the Preferred Options Core Strategy will be taken into account alongside the current representations, by way of return to this letter.

Iceni Projects, on behalf of Colonnade Land LLP trusts that the Council will find these representations to be constructive and helpful in taking forward the Core Strategy. Should you wish to discuss any aspect of these representations further, please do not hesitate to contact us.

It is important that development is directed away from the sites of international, national and local nature conservations importance and support the implementation of the Crouch and Roach Management Plans.

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.

ROCHFORD LOCAL DEVELOPMENT FRAMEWORK
CORE STRATEGY SUBMISSION DOCUMENT

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

CHAPTER 4 HOUSING

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

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

CHAPTER 5 CHARACTER OF PLACE

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

CHAPTER 8 ENVIRONMENTAL ISSUES

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

Policy ENV6 Large Scale Renewable Energy Projects

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

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

CHAPTER 11 ECONOMIC DEVELOPMENT

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

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

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