Policy ED4 - Future Employment Allocations

Agree with locating employment land in certain locations west of Rayleigh and south of London Road. However policy is not specific enough. Much of the Green Belt land south of London Road is visually sensitive public open space and good quality farm land. There would be implications for wildlife, should this part be developed.

PPG4 promotes employment land development in locations well served by rail freight.

The approach to the de-allocation of existing employment sites and identification of new employment allocations is unsound. The existing employment sites, with the exception of Stambridge Mills, are occupied. The future employment allocations will inevitably involve a Green Belt release, and this would be counter-productive to the overall strategy.

We object to the allocaiton of green field sites for employment when existing employment sites can be improved to meet the employment allocation.

Lubards Farm is an established employment area which also provides a variety of community based uses. The site extends to 3.5 hectares of existing employment land and it is considered that this area can be redeveloped to create a more sustainable employment area with further allocation on the adjacent land. The site has attractive farmland surroundings which will enhance a high quality office and business premises development.

The site is a similar distance from Rayleigh rail station as the proposed site at West of Rayleigh and has good public transport links with the rail station. The site is only a short distance from the A130 junction at Rettendon and from the A127 Junction. The site is also closer to the settlements of Rayleigh and Hullbridge and agina is already well linked by public transport. It is considered that this site would be preferable to sites on the very western edge of the District.

The site is closer to Rawreth Lane Industrial Estate so businesses will not be displaced any significant distance. The layout of the existing site at Lubards Lodge Farm, through allocation in this strategy, can be improved to consolidate and improve the wider range of employemnt and community uses.

It is considered that this site offers moree potential with less loss of greenfield Green Belt land than the proposed site at West of Rayleigh and therefore the allocation of land West of Rayleigh is unsound.

We would wish to see Land West of Rayleigh replaced by the site at Lubards Lodge Farm

The are south of london road is too vague .This is green belt some of which is agriculture land some of plotland origin .If we use my previous criteria for development in green belt the in the first instance we should look for land previously used of poor quality .There is land at Michelins Farm which fits this criteria with added advantages that it is bounded by the A130,A127,and theA1245 abbutting the fairglen interchange.It also has the railway on one boundary which facilitates any future transport developments favouring rail in the future .Land adjoining forewarded to Basildons ldf.

Draft Policy ED4 (part 3) is unsound because the proposal to allocate industrial land in proximity to Great Wakering, to provide local employment and mitigate the de-allocation of Star Lane Industrial Estate, is not justified as it is not founded on a robust or credible evidence base.

The amount of this land required, types of uses and location of the site are not set out in the draft policy. It therefore is not justified on a robust or credible evidence base.

The land could in fact be our clients site 'Tithe Park'. However, this is unclear

The draft policy is unsound as the alternative employment land is likely to be located within the green belt, which by virtue of the nature of employment uses, may have a greater impact than providing additional residential development on green belt land, in light of this, it is not consistent with PPG2 which provides the Government' guidance on green belts.

Overall, draft Policy ED4 (part 2) is sound as it is both justified and effective.

The proposed allocation of land north of London Southend Airport for employment uses is in accordance with the emerging Southend Airport Joint Area Action Plan (JAAP). It has been considered by the London Southend Airport & Environs study by Halcrow Group Ltd (June 2008) and is taken into account in the Rochford Employment Land Study by GVA Grimley (September 2008).

The development of the Brickworks Site, as part of the area known as 'north of London Southend Airport', will bring many benefits. The site is previously developed land and currently lies derelict and detracts from the surrounding landscape. Redevelopment will enhance the area and enable the clean up of the site which is likely to incur significant costs.

Whilst the draft policy encourages an Eco-Enterprise centre, it is important that the potential for other employment generating uses are not stifled because of this. It is therefore imperative that the importance of the feasibility study is explicitly stated in the policy, as is proposed. This study will need to examine market conditions, demand for eco-enterprise space, cost of build etc.

We support the principle/policy of providing a range of employment uses across the District rather than focus on provision purely at London Southend Airport.

We also support the principle of a new employment allocation west of Rayleigh. As highlighted in paragraph 11.38 of the Core Strategy, west Rayleigh is an ideal location for strategic employment development. As we have stated in previous submissions to the council, land to the west of Rayleigh has the most direct and least congested link to the two principal roads serving the district (A130 and A127) and the immediate road network has capacity to accommodate further vehicular traffic. Land west of Rayleigh would therefore clearly be an attractive location for commercial/ business operators.

However, we consider that the future employment allocation should be north of London Road, not south of London Road as specified in Policy ED4. We put forward several reasons for this:

• Countryside Properties has extensive experience in providing mixed use developments, including schemes that provide both residential units and employment allocations. Bearing in mind the extent of land under option, north of London Road, we could provide a business or employment park on this land without detriment to the residential amenities of the occupiers of any new residential development, providing a comprehensive sustainable mixed use development through careful masterplanning. The viability of an employment allocation north of London Road would be assisted by the sharing of infrastructure costs with any (adjacent) residential led mixed use scheme (the residential element identified in Policy H2)

• If the employment allocation is to provide for a minimum of 2ha for business/ industrial park (as recommended in the employment land study), plus land for some of those users (to be relocated) on the Rawreth Industrial Estate (which is approximately 10ha), then probably a minimum of 10 to 12ha of land would be required. We are not sure that this size of site could be found south of London Road without affecting/requiring land occupied by existing buildings e.g. Swallows Aquatics, and/or bringing development close to the Little Wheatleys Road or the Little Wheatleys estate (see further bullet point below re green belt boundaries). There may therefore be questions over the deliverability of this allocation (without a clearer understanding of its location). We consider that 10/12 ha of land could be accommodated north of London Road, without encroaching into the flood zone or affecting any existing properties.

• Our experience shows us that for a location to be attractive, a high quality masterplanned business park of sufficient size must be available to provide the quality of environment that many businesses are now looking for. 10/12 hectares would probably be a minimum, especially if the site is to accommodate and support an Eco-Enterprise Centre (see Policy ED1). A 10 ha site could equate to 400,000 square foot of floorspace. We suggest that such a site should accommodate a variety of uses and size of units. This would enable those smaller/start up business who start on the site to have the ability to grow and still remain on the site, utilizing the enterprise centre, small start up units or urban hives (typically providing 2,000 - 5,000 square foot) then moving up to medium sized warehouse units or hybrid/ bespoke buildings. Urban Hives can be adapted to provide office or industrial space.

• As part of our previous "call for sites" submission we stated that a "hopper" or "shuttle" bus service could be provided to serve the site and nearby communities and link the area to the town centre and rail station (transport and service hubs). The benefit of a larger site allocation (mixed use residential/employment and other uses) North of London Road will be more likely to support such a service and help make it more sustainable.

• We question how a new green belt boundary south of London Road could be defined. We would suggest that any allocation here would be separated/divorced from the existing built up area (west of Rayleigh/little Wheatleys) by existing woodland planting, recreational areas, the school and plotlands to the north and west of the school. Any employment site here could not we believe integrate with the existing residential area, unless for example the plotlands are to be included within this allocation (delivery issues with various different ownerships/land assembly) or the woodland or recreation areas are to be lost, contrary to other policies and principles within the Core Strategy and bringing proposed commercial development closer to existing residential properties, to the detriment of their amenities.

In order to meet the number of jobs required in the RSS, additional employment sites will be required. The Employment Land Study recommends that any de-allocations of employment land be compensated for by the allocation of 18 hectares of new employment sites. As the supply of employment land within the District is tight, this will require the release of Green Belt land

In order to ensure that a co-ordinated approach is taken to the release of Green Belt land, the requirements for both employment and housing land should be considered together. The idea of not releasing land for residential and then releasing it for employment purposes is a contradiction, as it still requires the release of Green Belt.

The first paragraph should be reworded as follows:

'In order to compensate for the de-allocation of the existing employment land, as detailed in Policy ED3, new employment allocations will need to be located in sustainable locations to meet the needs of businesses. In order to ensure that where it is appropriate to release Green Belt sites the requirement for employment and housing sites are considered together. This will ensure that the most co-ordinated approach is adopted for the future provision. With regards future employment growth the Council will seek to direct the majority of this to the west of the District and in proximity to London Southend Airport. Some industrial land will be allocated in proximity to Great Wakering to provide local employment and mitigate the de-allocation of Star Lane Industrial Estate.'

Policy ED4 - Future Employment Allocations
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. Concern is raised in relation to the strategy to redevelop existing employment sites for other uses and the provision of new greenfield employment sites. Should it be accepted that the existing employment sites are retained as such, then some or all of the future employment allocations will not be necessary.
Full text: It should be noted that the Core Strategy recognises that there is generally sufficient supply of employment sites but that any de-allocation will have to be compensated for. As a consequence of the strategy to reallocate employment sites under Policy H1, additional greenfield employment land is allocated under Policy ED4. As set out in our submission to Policy H1, the Council's strategy to seek the redevelopment of employment sites for alternative uses is questioned. The allocation of Stambridge Mills as a residential site is of particular concern for reasons identified elsewhere.
Should it be found that any of the employment sites proposed for residential development under Policy H1 should not come forward (in accordance with our submission to Policy H1) then some or all of the new employment sites should not come forward.
Proposed Amendment to Policy E4: Any changes to Policy H1 to retain employment sites should result in some or all of the new employment sites being deleted from Policy E4

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.

Para 4.8 States sustainability underlines any decisions on housing location, primarily: current and future deliverability of infrastructure, eg roads, services, public transport, health.

Policy H1
Para.4.14 Some employment sites are considered more suitable for other uses (eg housing) including Eldon Way/Foundry, Hockley. This is all open to question.

Hockley-re Eldon Way/Foundry
In CS Preferred Options 2008 policy H2 you discarded N.E.Hockley as a housing option - whilst close to centre, station, "impact on highway network from traffic heading through Hockley..along Ashingdon Road..renders location unviable". Clearly the same principle applied to Eldon Way/Foundry for the same reasons.

Response to C.S Preferred Options 2008 and HAAP 2009

June 2009 issue C S Submission issue says Eldon Way will be used for housing, whereas Sept.2009 issue says "alternative uses, including residential.." to be decided by HAAP (Issues consultation done, Pref.Options issue awaited, but judging from JAAP Pref.Options decision - namely biggest option chosen against overriding opposition, it will be housing).

Need to be logical and even-handed in proposals

Health services GP surgeries are full and a PCT health centre will not occur in the foreseeable economic climate.

Ch.10: Highways and Transport
Policy T1, T2 RDC proposes working with ECC Highways, developers, but admits it has no authority, responsibility here. RDC will seek developer contributions, but this is neither detailed nor costed in CS Submission nor HAAP, and contravenes PPS 12.3 para.4.93 which states "The infrastructure planning process should identify as far as possible infrastructure needs and costs". Idea of paying for road & transport improvements through Standard Charges is unproven and unsound.

Establish likely level of Standard Charges. Accept you cannot turn district into motorways with wholesale demolition.

In neither CS Submission nor HAAP is there any highways improvement, except idea to replace Spa roundabout with traffic lights and 1 way system up Southend Road and Hockley Rise.

Para.10.5 "..highway improvements serving new developments..in a timely manner..ensuring developments delivered alongside necessary infrastructure".
These improvements cannot possibly be delivered. It should be realised: B1013 (Southend Rd), Rectory Road Hawkwell, Ashingdon, West Rochford - all in area proposed for large new developments are former winding, narrow country roads, tarmacked over for motorised traffic. Large housing increments are unsustainable off these roads, which cannot be altered without much destruction.

Reply to CS Pref. Options 2008 & HAAP Issues/Options 2009

Policy T3, CLT1 Appendix CLT1 Public transport RDC admits this is in the private sector. In Hockley, operator has cut No7 service to 1 per hour from Ashingdon Schools, claiming it is unviable beyond. This is unlikely to change as Hockley is car dependant. No8 bus through Hawkwell is cut to 1 per hour to Rayleigh, for same reason as No7. Proposed planning agreements with developers can't run: eg, a community centre or classroom given by a developer remains once he has moved on - how can that apply for an on-going bus service?

Reply to Infrastructure Transport in CS Pref. Opts. 2008 and to HAAP Issues Opts. 2009.

Ch.11 Economic development

Policy ED3 Core Strategy preferred Options 2008 hinted at possible housing in Eldon Way site. June 2009 Submission version, without consultation, said Eldon Way would be housing (map included Foundry, not the text). September 2009 Submission said redevelopment would be in HAAP (which apart from the Issues/Options version, is unfinished. Judging from results of JAAP Preferred Options where biggest option is chosen, though most respondents were against it, site will be housing, without consultation.

Para.1.25, Para.11.32 Note CH.1 Introduction to CS Submission 2009 para.1.25 East England Plan requires 3000 additional jobs, presumably to 2021. Revised Southend Airport is expected to drive Economic development. But at para. 11.32 Eldon Way-Foundry estate is planned to be more suitably utilized. "..alternative land will be required to accommodated employment uses so displaced" - ie jobs sent to eg new site near Southend Airport - not new jobs.

Reply to HAAP Issues Options 2009

Remove compulsory relocation

Policy ED4 Policy states Council will allocate 18ha of land to make up for de-allocations in ED3 - that proves point above.

Proposals for moving employment to out of town locations with no existing transport links are contrary to government policies PPG4, PPS1 and PPS4 and Core Strategy Policy T1.

Evidence Base is ignored by contravening Hockley Parish Plan 2007 and ignoring resents' views on HAAP Issues/Options. Next stage of HAAP Preferred Options is pre-empted and rendered irrelevant. Core Strategy plans to relocate Eldon Way Foundry estate to Greenfield site with no nearby bus or railway. RDC plans to upgrade the nearest road to dual carriageway, though the connecting B1013 (through Hockley) will stay single, said by ECC Highways statistics to be 72% capacity. Airport bosses and council cannot suggest there will be no traffic growth from JAAP and new industrial site.

Reply to Hockley Parish Plan 2007. HAAP Issues 2009

Move to new industrial site near airport contravenes PPPS4:

- EC7.3C "out of centre sites, with preference given to sites..well served by choice of..transport and..close to centre and..high likelihood of forming links with centre". There is no current public transport and links with centres is unlikely".

- EC 7.5.1 "whether the site is or will be accessible and well served by choice of transport, public transport, walking and cycling, as well as by car..". Remote location, narrow busy B1013 makes the site unsuitable for access by cycle or on foot.

It also contravenes PPS1 (27vii).."reduce need to travel, encourage accessible public transport provision to secure more sustainable patterns of transport..Planning should actively manage patterns of urban growth to make fullest use of public transport and focus development in existing centres, near to major public transport interchanges". Core Strategy undermines its own policy Transport and Highways policy T1 and is unsound.

Although shown on accompanying drawing in earlier versions, there was no prior textual mention of Foundry industrial estate (next to Eldon Way) for redevelopment until current CS 2009 Submission. This was stated to be a typing error, but does not inspire confidence in reliability of drafting.

Revise both 2009 Core Strategy and 2009 HAAP Issues/options

Chapter 12: Retail/Town centres
The Core Strategy misrepresents findings of the Retail and Leisure Study 2008.

Para.12.38 The Core Strategy states (para.12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace."

Whereas the R&LS actually states:

1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure".

2) (10.28) "There is no immediate capacity for additional floorspace".

3) (10.29) "we recommend focus be maintained on developing Hockley's existing strengths, rather than retail expansion"

4) 10.31 "the current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moreover, we have identified that it has a very small catchment population. Accordingly, the council may wish to consider reclassifying Hockley from a town centre to a district centre".

Defer whole of proposals for Hockley town centre to Hockley Area Action Plan.

The Council will work with landowners and its partners to deliver the HAAP.

Remove threat of compulsory purchase orders.

One doesn't perceive impartiality when the Planning Director replies to local' HAAP survey with "The affluent people of Hockley are entitled to famous name shops".

Chapter 5: Character of Place and Local Lists
Para.5.4 "Rochford district has unique character..stems from traditional buildings..still dominate towns and villages".

Para.5.17 "Council believes many buildings..are of local distinctiveness..part of..cherished local scene".

This only applies to favoured places: Rochford, Rayleigh, greenbelt villages. Many Hockley conservable items have been systemically removed for supposedly lucractive development in face of widespread protect. This is for supposed need for housing. In fact heritage items have been replaced by dwellings most cannot afford, and/or are hard to sell due to unsuitability of massing and siting. Many other homes are jeopardised by this practice.

HAAP issues 2009. Core Strategy 2006, 2007,2008, SCI.2006

Fewer 'vested interests', more even handedness. No more pressing people out of businesses, homes for expediency.

A CPRE Fieldwork issue extolled Local Lists, citing refusal of 16 flats to replace character house, not on local list. Inspector said house, façade made a contribution to area character, even if English heritage decided it didn't warrant listing. Council worked to get the house grade listed and even made adjacent area conservation one.

Hockley had one such on a "significant site" faced with 13 flats. Ward Member omitted house from refusal proposal, so house could be demolished. RDC dropped Local List ahead of appeal: "Government frowned on such Lists" (Other LAs, unaware of supposed directive retained theirs. After demolition RDC restored Local Lists, saying Government now support them. When Inspector queried the complaint, the then policy officer said "just politics, lot of local interest, nothing of character in the area[!]. (A dozen such items had been removed). Some "distinctive" Hockley buildings are still condemned (in Greensward Lane:, others threatened (Spa Road). Whereas a modest hue and cry in Rayleigh will usually result in a building being saved.

Conclusion

Core Strategy Submission DPD is basically unsound in many respects

Incomplete information. Amongst others, it refers to Hockley AAP, the first stage of which is complete, but not other three. Rochford AAP first stage has been published in arrears of Core Strategy Submission. Rayleigh AAP is still awaited. Precise housing sites are absent, as Urban Capacity Study 2007 has been superseded by Strategic Housing Land Availability Assessment, not yet published. Traders, residents, are thus responding to Core Strategy Submission with incomplete information.

Lack of community involvement. Chapter 1, Introduction, para. 1.11 "Community involvement is an essential part of the plan making process".

In Statement of Community Involvement 2006 Rochford RDC "recognises need to enable people.to have their voices heard".

Re Public Meetings: "Consideration will be had to timing and venue to ensure meeting is as accessible as possible".

Take Hockley Area Action Plan as an example of the opposite of all this:- Presentation of document was at Hullbridge, 7.30pm. It was also discussed with JAAP at Rochord Freight House (for traders only) at 7am, without publicity. Excuse made: HAAP on RDC website, which none will seek unless knowing it is there. Rochford District Matters newssheet had minute articles on p.3, half way through consultation period. Another excuse: a 2nd presentation by Hockley Residents Association with planning officer present: only because of complaints, and it is not the HRA's responsibility to RDC's job. Due to unavoidable haste of calling meeting, few knew and only 50 were present.

In Core Strategy Submission Hockley Parish Plan has been ignored. Proposals also ignore 95% rejection rate response to HAAP 2009, which included proposals for Eldon Way employment site.

Unfettered right of developers to carry on as if Core Strategy didn't exist. In PPS 12, Ch.4.6 states: "Core Strategies should be flexible and able to show how they handle contingencies". Several large planning applications have been submitted proposing developments outside the Core Strategy which does not indicate how such applications will be handled and does not comply with PPS 12.

Where are we? Finally, at Chapter 1, Introduction, para. 1.24: "the Core Strategy will have to be reviewed in the event of a new Local Area Agreement, post-2011, setting different priorities". So what purpose does all this work serve? So we have hardly finished this exercise, before it all starts again?

Ch. 4 Housing: Ch.10 Transport, Highways; Ch.11 Economic Development; Ch.12 Retail/town centres; Ch.5 Character of place & Local Lists

Chapter 4: Housing

Para 4.8 States sustainability underlines any decisions on housing location, primarily: current and future deliverability of infrastructure, eg roads, services, public transport, health.

Policy H1, Para.4.14 Some employment sites are considered more suitable for other uses (eg housing) including Eldon Way/Foundry, Hockley. This is all open to question.

Hockley-re Eldon Way/Foundry
In CS Preferred Options 2008 policy H2
N.E.Hockley was discarded as a housing option - whilst close to centre, station, "impact on highway network from traffic heading through Hockley...along Ashingdon Road..renders location unviable". Clearly the same principle applied to Eldon Way/Foundry for the same reasons.

Need to be logical and even-handed in proposals

June 2009 issue C S Submission issue says Eldon Way will be used for housing, whereas Sept.2009 issue says "alternative uses, including residential.." to be decided by HAAP (Issues consultation done, Pref.Options issue awaited, but judging from JAAP Pref.Options decision - namely biggest option chosen against overriding opposition, it will be housing).

Policy H1, T1 Proposals for moving employment to out of town locations, at either end of the district, with no existing public transport links, are contrary to government policy PPG14 & PPS1. it also contravenes the Core Strategy's stated aims of reducing carbon emissions; reliance on car transport and providing "an integrated network of cycle paths",

The Core Strategy also contravenes its own policy T1 and is unsound.

Health services GP surgeries are full and a PCT health centre will not occur in the foreseeable economic climate.

Ch.10: Highways and Transport

Policy T1, T2 RDC proposes working with ECC Highways, developers, but admits it has no authority, responsibility here. RDC will seek developer contributions, but this is neither detailed nor costed in CS Submission nor HAAP, and contravenes PPS 12.3 para.4.93 which states "The infrastructure planning process should identify as far as possible infrastructure needs and costs". Idea of paying for road & transport improvements through Standard Charges is unproven and unsound.

Establish like motorways with wholesale demolition.

In neither CS Submission nor HAAP is there any highways improvement, except idea to replace Spa roundabout with traffic lights and 1 way system up Southend Road and Hockley Rise.

RDC are proposing to scatter housing across the district in around 12 or sites but no detailed consideration has been given to the implications for highways across the District. Many roads across the District are at or near capacity but no modelling has been undertaken to determine the impacts.

It is clear that (i) the combined impact of scattering houses across the District and (ii) relocating Eldon Way/Foundry Industrial Estates with no public transport services will exacerbate existing problems. It is clear that the extent of improvements required is both unknown and not funded and the proposal is unsound.

Para.10.5


Policy T3, CLT1 Appendix CLT1
T1 & T2 "..highway improvements serving new developments..in a timely manner..ensuring developments delivered alongside necessary infrastructure".
These improvements cannot possibly be delivered. It should be realised: B1013 (Southend Rd), Rectory Road Hawkwell, Ashingdon, West Rochford - all in area proposed for large new developments are former winding, narrow country roads, tarmacked over for motorised traffic. Large housing increments are unsustainable off these roads, which cannot be altered without much destruction.

Public transport RDC admits this is in the private sector. In Hockley, operator has cut No 7 service to one per hour from Ashingdon Schools, claiming it is unviable beyond. This is unlikely to change as Hockley is car dependant. No 8 bus through Hawkwell is cut to one per hour to Rayleigh, for same reason as No 7. Proposed planning agreements with developers can't run: e.g., a community centre or classroom given by a developer remains once he has moved on - how can that apply for an on-going bus service?

Ch.11 Economic development

Policy ED3 Core Strategy preferred Options 2008 hinted at possible housing in Eldon Way site. June 2009 Submission version, without consultation, said Eldon Way would be housing (map included Foundry, not the text). September 2009 Submission said redevelopment would be in HAAP (which apart from the Issues/Options version, is unfinished. Judging from results of JAAP Preferred Options where biggest option is chosen, though most respondents were against it, site will be housing, without consultation.

Para.1.25 Para.11.32
Policy ED4 T1 & T2 Note CH.1 Introduction to CS Submission 2009 para.1.25 East England Plan requires 3000 additional jobs, presumably to 2021. Revised Southend Airport is expected to drive Economic development. But at para. 11.32 Eldon Way-Foundry estate is planned to be more suitably utilized. "..alternative land will be required to accommodated employment uses so displaced" - ie jobs sent to eg new site near Southend Airport - not new jobs.

Remove compulsory relocation

Policy states Council will allocate 18ha of land to make up for de-allocations in ED3 - that proves point above.

Proposals for moving employment to out of town locations with no existing transport links are contrary to government policies PPG4, PPS1 and PPS4 and Core Strategy Policy T1.

Evidence Base is ignored by contravening Hockley Parish Plan 2007 and ignoring resents' views on HAAP Issues/Options. Next stage of HAAP Preferred Options is pre-empted and rendered irrelevant.

Core Strategy plans to relocate Eldon Way Foundry estate to Greenfield site with no nearby bus or railway. RDC plans to upgrade the nearest road to dual carriageway, though the connecting B1013 (through Hockley) will stay single, said by ECC Highways statistics to be 72% capacity. Airport bosses and council cannot suggest there will be no traffic growth from JAAP and new industrial site.

Revise both 2009 Core Strategy and 2009 HAAP Issues/options

Move to new industrial site near airport contravenes PPPS4:

EC7.3C "out of centre sites, with preference given to sites..well served by choice of..transport and..close to centre and..high likelihood of forming links with centre". There is no current public transport and links with centres is unlikely".

EC 7.5.1 "whether the site is or will be accessible and well served by choice of transport, public transport, walking and cycling, as well as by car..". Remote location, narrow busy B1013 makes the site unsuitable for access by cycle or on foot.

It also contravenes PPS1 (27vii).."reduce need to travel, encourage accessible public transport provision to secure more sustainable patterns of transport..Planning should actively manage patterns of urban growth to make fullest use of public transport and focus development in existing centres, near to major public transport interchanges". Core Strategy undermines its own policy Transport and Highways policy T1 and is unsound.

H1 & RTC6 Although shown on accompanying drawing in earlier versions, there was no prior textual mention of Foundry industrial estate (next to Eldon Way) for redevelopment until current CS 2009 Submission. In recent amendment to the CS this was stated to be due to a typing error!

Chapter 12: Retail/Town centres

The Core Strategy misrepresents findings of the Retail and Leisure Study 2008.

Defer whole of proposals for Hockley town centre to Hockley Area Action Plan.

Para.12.38 H1 & RTC6 The Core Strategy states (para.12.38) "The Retail & Leisure Study indicates Hockley has great potential. Hockley has been identified as having a need for additional convenience floorspace."

Whereas the R&LS actually states:

1) (10.26) "the scale of need does not lend itself to a foodstore capable of retaining a significant proportion of main food shopping expenditure".

2) (10.28) "There is no immediate capacity for additional floorspace".

3) (10.29) "we recommend focus be maintained on developing Hockley's existing strengths, rather than retail expansion"

4) 10.31 "the current nature of Hockley does not lend itself to classification as a 'town centre' as defined by PPS6. Moreover, we have identified that it has a very small catchment population. Accordingly, the council may wish to consider reclassifying Hockley from a town centre to a district centre".

Remove threat of compulsory purchase orders.

The Council will work with landowners and its partners to deliver the HAAP.

Chapter 5: Character of Place and Local Lists
Para.5.4 "Rochford district has unique character..stems from traditional buildings..still dominate towns and villages".
Para.5.17 "Council believes many buildings..are of local distinctiveness..part of..cherished local scene".

This only appears to apply to certain places: Rochford, Rayleigh, greenbelt villages. Many Hockley conservable items have been systemically removed for supposedly lucractive development in face of widespread protect. This is for supposed need for housing. In fact heritage items have been replaced by dwellings most cannot afford, and/or are hard to sell due to unsuitability of massing and siting. Many other homes are jeopardised by this practice.

Conclusion

Core Strategy Submission DPD is basically unsound in many respects:

Incomplete information. Amongst others, it refers to Hockley AAP, the first stage of which is complete, but not other three. Rochford AAP first stage has been published in arrears of Core Strategy Submission. Rayleigh AAP is still awaited. Precise housing sites are absent, as Urban Capacity Study 2007 has been superseded by Strategic Housing Land Availability Assessment, not yet published. Traders, residents, are thus responding to Core Strategy Submission with incomplete information.

Lack of community involvement. Chapter 1, Introduction, para. 1.11 "Community involvement is an essential part of the plan making process". In Statement of Community Involvement 2006 Rochford RDC "recognises need to enable people..to have their voices heard".

Re Public Meetings: "Consideration will be had to timing and venue to ensure meeting is as accessible as possible".

Hockley Area Action Plan as an example of the opposite of all this:- Presentation of document was at Hullbridge, 7.30 p.m. It was also discussed with JAAP at Rochord Freight House (for traders only) at 7 a.m., without publicity. Excuse made: HAAP on RDC website, which none will seek unless knowing it is there. Rochford District Matters newssheet had minute articles on p.3, half way through consultation period. Another excuse: a second presentation by Hockley Residents Association with planning officer present: only because of complaints, and it is not the HRA's responsibility to RDC's job. Due to unavoidable haste of calling meeting, few knew and only 50 were present.

In Core Strategy Submission Hockley Parish Plan has been ignored. Proposals also ignore 95% rejection rate response to HAAP 2009, which included proposals for Eldon Way employment site.

Unfettered right of developers to carry on as if Core Strategy didn't exist. In PPS 12, Ch.4.6 states: "Core Strategies should be flexible and able to show how they handle contingencies". Several large planning applications have been submitted proposing developments outside the Core Strategy which does not indicate how such applications will be handled and does not comply with PPS 12.

Where are we? Finally, at Chapter 1, Introduction, para. 1.24: "the Core Strategy will have to be reviewed in the event of a new Local Area Agreement, post-2011, setting different priorities". So what purpose does all this work serve? So we have hardly finished this exercise, before it all starts again?

Please see attached statement.

Council ref AE25

1.0 Instruction and Introduction

1.1 Charles Planning Associates Limited (Chartered Town Planners) is Instructed by Swan Hill Homes Limited (Swan Hill) to prepare and submit representations on their behalf in respect of the Rochford District Local Development Framework: Core Strategy Submission (September 2009) Development Plan Document.

1.2 The comments refer to the relevant sections and policy designations in the Submission document, as appropriate.

1.3 The comments set out in this submission are intended to assist the District Council in taking forward its Local Development Framework. It is our intention to continue to be involved in the LDF preparation process and we look forward to the opportunity to comment further at the Examination to the Core Strategy.

1.4 If you have any queries regarding the content of this submission then please do not hesitate to contact:

Peter Kneen BSc (Hons) MSc MRTPI
Planner

2.0 Housing:
Policy H1 - The Efficient Use of Land for Housing

2.1 Swan Hill recognises the importance of seeking to concentrate new developments mainly in the existing urban areas, on previously developed land where possible, particularly in view of the Government seeking to ensure 60% of all such new developments are on previously development land (PDL).

2.2 However, given the character of the District, and the strategic housing requirement of the East of England Plan, Swan Hill supports the approach that the Council must also make provision for additional development on the edge of existing settlements on greenfield sites, particularly in the most sustainable locations. As such, Swan Hill supports that where feasible, the redevelopment of existing employment sites for residential/employment purposes can make a contribution towards the strategic housing requirement, provided that sufficient additional employment land is brought forward to ensure the stability of employment levels in the District, and to ensure employment growth meets the East of England Plan requirements.

2.3 Swan Hill considers that Policy H1 should include consideration that new extensions to existing settlements have regard to their potential impact on the wider characteristics and openness objectives of the Green Belt.

Policy H2 - Extensions to Residential Envelopes and Phasing

2.4 Swan Hill generally supports the approach taken by the Council in this policy. As set out above, Swan Hill consider the Council's acknowledgment that housing requirements should be met through the allocation of land on the edge of the existing settlements is the most suitable way forward to meeting the Council's strategic housing requirement and complies with the advice in PPS3.

2.5 The need for suitable greenfield urban extensions represents the best way forward for the Council to meet its strategic housing requirement, as set out in the East of England Plan. Swan Hill supports the recognition that the potential supply of alternative previously developed sites is limited, without detrimentally affecting the character of the District, and therefore the best way forward is the use of sustainable greenfield urban extensions to the existing settlements of the District.

2.6 However, Swan Hill consider that a fundamental consideration that the District Council should consider relates to the potential impact of the urban extensions on the Green Belt policy has been somewhat overlooked. The wider sustainability credentials of the settlements of the District should only be one of many key considerations for determining the level of expansion. In view of the proximity of Southend-on-Sea to all the main settlements of the District, and the influence this has on the likely location many people would travel for employment and leisure, sustainability of many of the settlements is not a key overarching factor, and greater weight should be placed on the potential impact on the openness of the Green Belt, as this cannot be remedied if development occurs in the wrong location.

2.7 As such, Swan Hill considers that determining the location of growth for the main settlements should be to identify those locations where the impact on the wider setting of the Green Belt can be minimised. Further justification for those general locations chosen should be identified in Policy H2. In this regard, Swan Hill has serious concerns regarding the removal of Land South West of Great Wakering as a viable option for the growth of the settlement. The development of this area of Great Wakering, in addition to the potential redevelopment of the Star Lane Industrial Estate could provide a more comprehensive development, whilst ensuring that the wider openness of the Green Belt is maintained. Land South West of Great Wakering is significantly better placed to limit the impact on the wider Green Belt than Land West of Great Wakering, and could contribute to the provision of an important amenity and wildlife site for the local community.

2.8 In addition, Swan Hill consider that the Council now has no reserve provision in the event that any of the existing employment sites set out in Policy H1 fail to come forward for development within the envisaged timescale. Further, Land West of Great Wakering has not been identified in the SHLAA as a deliverable site to help meet the strategic housing requirement, contrary to the requirement set out in PPS3.

2.9 As such, Swan Hill would support the provision of suitable sites which could be safeguarded for future development in the likelihood of a shortfall in supply.

Policy H3 - Extensions to Residential Envelopes Post 2021

2.10 As set out above, Swan Hill supports the overall approach the Council has taken towards the provision of sustainable urban extensions as a suitable means of meeting their strategic housing requirement. However, as set out for Policy H2 above, Swan Hill has serious concerns regarding the removal of several proposed sites set out in the October 2008 Preferred Options Core Strategy, without any guarantee of the ability to deliver those sites set out in Policy H1.

2.11 As also considered above, the inclusion of West of Great Wakering for 250 dwellings should not be included ahead of South West of Great Wakering, in view of the fact that the site is not identified in the SHLAA as available, suitable and achievable as required by PPS3, and thus is not supported by a robust and creditable evidence base for its inclusion as a strategic site for development.

2.12 Whilst Swan Hill acknowledge that alterations to Policy H1 has resulted in the removal of some locations for growth in Policy H3 (as set out in the Sustainability Appraisal), Swan Hill does not consider that the most appropriate locations have been chosen.

2.13 In addition to the matters raised above, the use of West of Great Wakering would also result in the loss of valuable agricultural land, which clearly in a Green Belt location, should be less suitable for development than other sites, such as South West of Great Wakering, which would have limited impact on the wider Green Belt policy, and not result in the loss of valuable agricultural land.

2.14 Finally, in respect of Policies H1, H2 and H3, all of the above comments are based on our interpretation of the Submission Version Core Strategy when compared to the October 2008 Version of the Core Strategy. Without the ability to undertake a detailed assessment of the Council's SHLAA, it is not possible to clarify the proposed Core Strategy position regarding the proposed direction of growth proposed for the settlements in the District. As such, Swan Hill reserves the right to make additional representations regarding the proposed Policies H1, H2 and H3 following the publication of the SHLAA in due course.

Policy H4 - Affordable Housing

2.15 In general terms, Swan Hill supports the approach taken by the Council towards the provision of affordable housing for new residential developments. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy H5 - Dwelling Types

2.16 Swan Hill supports the policy provision of H5, and considers that the approach taken by the Council for this policy represents a suitably flexible alternative to stipulating percentages of dwelling mix, sought by some local authorities. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy H6 - Lifetime Homes

2.17 In regard to this policy, Swan Hill objects to the Council's policy where all new dwellings should be provided to the Lifetime Homes Standard. Whilst it is acknowledged that the UK has an aging population, Swan Hill considers that seeking to provide Lifetime Homes on all sites is considered to be overly onerous for proposed developers, particularly when considering the requirement for all car parking spaces to be suitable for disabled users, which could result in more schemes becoming unviable. Therefore, the provision of a percentage of Lifetime Homes should be considered through negotiations with the Council at the planning application stage, and should be determined on a case-by-case basis.

3.0 Character of Place:
Policy CP1 - Design

3.1 The Town and Country Planning (General Development Procedure) Order 1995 (As Amended) makes the submission of a Design and Access Statement for most types of planning applications a Statutory requirement, and as such, the provision of a Design Brief represents a pre-requisite of all major planning applications.

3.2 Policy CP1 seeks to ensure the provision of good, high quality developments that reflect local characteristics and distinctiveness, this ideology is supported by Swan Hill.

4.0 The Green Belt:
Policy GB1 - Green Belt Protection

4.1 Following the amendments to the wording of the Policy since the October 2008 Preferred Options Core Strategy, Swan Hill is now generally supportive of Policy GB1 and its supporting text. However, as expressed above, it is important that where alterations to the Green Belt boundary occur as a result of the extension of the settlements to meet the strategic housing requirement, both the minimal amount of land is taken and where that land is taken for development, it represents the best available land which has a minimal impact of the wider openness characteristic of the Green Belt.

5.0 Environmental Issues:
Policy ENV3 - Flood Risk

5.1 Swan Hill generally supports the approach set out in Policy ENV3 regarding ensuring development accords with the sequential test of PPS25. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy ENV4 - Sustainable Drainage Systems (SUDS)

5.2 Following the revisions from the October 2008 Preferred Options Core Strategy, Swan Hill now generally supports the approach set out in Policy ENV4. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy ENV8 - On-site Renewable and Low Carbon Energy Generation

5.3 Whilst Swan Hill recognises the importance of reducing carbon emissions, particularly in new housing developments, and the role this can play in reducing the nations overall Greenhouse emissions. As such Swan Hill is generally supportive of Policy ENV8. It is noted that Policy ENG1 of the East of England Plan sets out sets out a threshold of developments comprising 10 or more dwellings. Swan Hill consider it important for the District Council to justify the reduction in the threshold level.

5.4 Further, no assessment of Policy ENV8 has been set out in the Sustainability Appraisal which justifies the change in threshold from that of Policy ENG1 of the RSS.

Policy ENV9 - Code for Sustainable Homes

5.5 Following the revisions from the October 2008 Preferred Options Core Strategy, Swan Hill now generally supports the approach set out in Policy ENV9. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

6.0 Community Infrastructure, Leisure and Tourism:
Policy CLT1 - Planning Obligations and Standard Charges

6.1 Swan Hill generally supports the overall approach the Council has taken in Policy CLT1. It is considered Policy CLT1 sets out a degree of flexibility to ensure that all sites are considered on a site-by-side basis, assessing the individual merits of each planning application, in order to ensure the levels of contributions applicable meet the five tests of Circular 05/05. The Policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policies CLT5 - Open Space;
CLT7 - Play Space;
CLT8 - Youth Facilities; and,
CLT10 - Playing Pitches

6.2 Swan Hill supports the need for new residential developments to incorporate a degree of new publicly accessible open space, children's play space, youth facilities and playing pitches, and as such, generally supports the policy approaches taken by the Council.

6.3 However, it is important that whilst the Council may seek to undertake an assessment of providing standard charges for new development, which, as set out in Policy CLT1, this should be based on thorough public consultation and consideration and sound justification. Swan Hill consider that within the provision of a standard charge, it is important that such provision allows for a degree of flexibility to ensure that each site is assessed individually and on its own merits. This is particularly important for those sites close to existing open spaces and facilities. As such, the levels of open space and recreation facilities required in the 'standard charge' should be based on an up-to-date PPG17 Open Space assessment, which should be used to form a key consideration in the levels of provision likely to be required in the standard charge system proposed.

7.0 Transport:
Policy T1 - Highways

7.1 Swan Hill supports the overall objectives set out in Policy T1 requiring developments to be located and designed to reduce the reliance on the private car and to meet the infrastructure needs generated by development or seek to help achieve these needs is acceptable in principle.

7.2 Swan Hill recognises the importance of providing sufficient infrastructure provision to meet the requirements of development, and that where developments have insufficient consideration of impact on existing infrastructure, they should be considered unacceptable and contrary to National policy guidance. However, Swan Hill considers it important to emphasise that the developer's role should not be seen as a means to meet existing shortfalls in provision.

Policy T3 - Public Transport

7.3 Swan Hill is generally supportive of the policy approach set out in T3, however, as set out in paragraph 7.2 above, it is important that the District Council do not consider that it is the developer's responsibility to resolve existing shortfalls in provision of public transport, and any contribution towards additional public transportation provision should only be to mitigate against the additional level of demand likely from the development proposed.

Policy T5 - Cycling and Walking

7.4 Swan Hill supports the general approach to this policy, as Swan Hill recognises the importance of promoting the use of alternatives to the private car. The policy provision acknowledges the need to ensure relevant contributions in the event of additional travel demands generated by individual developments, whilst also setting out additional aspirations for the cycle network in the District.


7.5 As such, Swan Hill considers this policy accords with the advice of National Policy and is therefore considered sound by Swan Hill.

Policy T8 - Parking Standards

7.6 The Council has recently (January 2007) adopted SPD on the requirements for parking standards, and as such, Swan Hill generally supports the policy approach chosen by the Council. As set out in the SPD, whilst Swan Hill generally supports the approach taken by the District Council towards setting residential parking standards, in that the Council has recognised that in the suburban areas, even with some access to public transport, the majority of residents will rely on the use of private cars. However, Swan Hill has concerns over the failure of the District Council to comply with the provisions of PPG13: Transport (2001) which sets out that Local Planning Authorities should not set minimum standards for car parking. Whilst it is acknowledged that PPS3 sets out provision for the consideration of local circumstances, it is considered that the Council has not justified this deviation from PPG13's maximum standard.

7.7 Whilst it is acknowledged that such justification may become apparent through the work currently being undertaken by Essex County Council, until such time, the District Council should only seek to apply the maximum standards indicated in PPG13. However, Swan Hill recommends that the District Council make provisions in the wording of the Policy to allow for changes in the event that future policy on car parking standards need to reflect the County standard, following the completion of the County Council review.

8.0 Economic Development:
Policies ED3 - Existing Employment Land
ED4 - Future Employment Allocations

8.1 In respect of Policies ED3 and ED4, Swan Hill notes that they have changed considerably since the October 2008 Preferred Options document, in that they are site specific regarding the location of the proposed redevelopment of existing employment sites. These four sites are also identified in Policy H1 - Efficient Use of Land, and in general, Swan Hill supports the approach to the redevelopment of these sites (where feasible) based on the assessments of the sites set out in this version of the Core Strategy.

8.2 However, Swan Hill has concerns that these policies might not be considered suitably sound given that insufficient opportunity has been allocated for consultation on their redevelopment. Without the SHLAA being publically available prior to the consultation on this Core Strategy, an insufficient evidence base has been provided to corroborate that these sites are neither suitable or deliverable to meet the test of soundness requirements.

Policy ED4 is not sound as it is not precisely worded.

The main text of point 1 of policy ED4 confirms that land to the South of London Road, west of Rayleigh will be used for the relocation of displacement of Rawreth Industrial Estate industrial uses and for additional office development. The bullet points then state that industrial development will be acceptable.
The first para of point 1 should be clear and confirm that additional industrial development in addition to that displaced from Rawreth Industrial estate will be acceptable.

Proposed Change

We request the following amendment to point 1 of policy ED4:

The Council will allocate land to the south of London Road, Rayleigh to accommodate a new employment park capable of accommodating businesses displaced by the redevelopment of Rawreth Industrial Estate as well as additional office space B1 - B8 uses. It will have the following characteristics:

Site location plan received, see Council ref AE30

Local Development Framework

Representations on the Core Strategy
Submission Document, November 2009
On behalf of Barratts Eastern Counties

Introduction

The requirements of Core Strategies are enshrined in the 2004 Planning and
Compensation Act, the Town & Country Planning (Local Development) England (Regulations) 2004 and the 2008 policy guidance in PPS12. The requirements of Coe Strategies are clear. And they are legal requirements. The Core Strategy must comply with the Local Development Scheme, Statement of Community Involvement and the Regulations. The Core Strategy must be subject to a sustainability appraisal, have regard to national guidance, conform generally with the Regional Spatial Strategy and have regard to any Sustainable Community Strategy. A Core strategy must be sound - justified, effective and consistent with national policy. The following
representations therefore focus on these legal requirements.

HOUSING
Paragraph 4.6 - Evidence Base

To meet the soundness test Submission Core Strategies (SCS) must be justified, that is to say it must be founded on robust and credible evidence base and comprise the most appropriate strategy when considered against reasonable alternatives. The housing strategy in as far as it identifies a need for Green belt sites is sound, however, there are other elements which are unsound.

Paragraph 4.6 notes that the Strategic Housing Land Availability Assessment (SHLAA) has examined the supply of housing. It is presumed that the Table at paragraph 4.6 is the outcome of this examination. Whilst the SHLAA has some leigitimacy in that it identifies various sites that are apparently available, we are concerned that because the SHLAA was only published in November 2009 it post dates the SCS. This implies that the SCS is driving the SHLAA exercise rather than the other way round. Whilst this may have no real practical effect on the outcome of the SCS and the identified need for Green Belt sites, the Inspector will be mindful of the advice in paragraphs 33 and 54 of PPS3 that SCS draw on the evidence in SHLAA. It may be that the SCS should explain how the evidence base has been used to justify the strategy.

PPS12 explains at paragraph 4.37 that Core Strategies are based on thorough evidence. Since the SHLAA has only recently been published it is considered that the SCS is unsound as it is not justifiable. This, together with other comments on the SCS, indicates that the process should be delayed to ensure that a more robust document is placed in front of the EiP Inspector.

Table at Paragraph 4.6 - Evidence base

From our review of the available evidence it would appear that the housing land supply is insufficient and that Green Belt release are required. From the wider strategy being promoted we note that some of the sites that the District Council consider to be 'appropriate' are likely to relate to existing employment areas. As set out elsewhere in our representations, we maintain sever reservations that the redevelopment of existing employment sites for alternative uses and particularly the Eldon Way Industrial Estate is unsustainable. We will make reference to the effectiveness of this strategy in relation to sustainability, whether it is justified in the context of National Policy and the deliverability of such a strategy elsewhere.

In particular, paragraph 11.32 of the SCS refers to existing employment land and sites within the UCS. It does not refer the SHLAA and as such it appears that an evidence base to support the re-use of employment land for residential is not reported in the SCS.

Having reviewed the 2008 Annual Monitoring Report, as we did when commenting on the 2008 Preferred Options Core Strategy, we maintain severe doubts as to the appropriateness of some of the previously developed sites identified as potential housing sites and their expected housing yield. Whilst we cannot at this stage ascertain whether the SHLAA sites referred to in this table correlate with the Annual Monitoring Report and indeed the 2007 Urban Capacity Study, it is our view that there will be some commonality and so the reliance on these sites is likely to be at odds with Government Policy. We shall elaborate on this objection in relation to the specific housing policy below.

We note that the last two rows in the Table at paragraph 4.6 set out figures with and without Green Belt releases. The text to this section of the Core Strategy should, for reasons of clarity, explain that Green belt review will be necessary in order to deliver the required housing.

Paragraph 4.9

The table on page 40, which sets out the settlement tiers, is supported. Rayleigh, Rochford/Ashingdon, Hockley/Hawkwell are clearly the largest settlements in the District and they benefit from good employment, housing, leisure, community and public transport provision. These settlements are the most sustainable ones with the greatest mix of uses. Consequently, it is sensible that the Core Strategy identifies these as top tier settlements and is able to target them with growth accordingly. This component of the strategy is justified by reference to sustainability data and is effective, since targeting development at these locations will ensure a more sustainable pattern of development.


Paragraph 4.14

We maintain that the strategy for redeveloping the Eldon Way Industrial Estate for housing and other alternative uses to employment is unsound. It is neither justified nor effective. The Industrial Land Availability Study 2006 sets out on page 7 strategic objectives. The 3rd objective seeks to Support town centre and industrial estate enhancement initiatives aimed at improving the environment ensuring the area is economically prosperous and competitive. Clearly the strategy as currently drafted envisages major changes to existing industrial estates, including alternative uses. This strategy is not consistent with other strategies and evidence based studies and so cannot be justified in the context of the tests set out in PPS12. It is also an ineffective strategy since the new employment locations that would free up the Eldon Way site for redevelopment relies on transport infrastructure that has no certainty of being delivered. Principally, the erosion of employment uses at Eldon Way could
make the settlement of Hockley/Hawkwell less sustainable and thus conflict with the tiered approach on page 40, paragraph 4.9.

Policy H1

Prioritising the use of previously developed land ("pdl") is supported in principle. It is a justified strategy in the context of PPS3 and effective as sequential choices can be made by implementing the policy. However, the District Council is also promoting a strategy which seeks the redevelopment of existing employment locations to alternative uses and by consequence is identifying green field sites for new employment development elsewhere (Policy ED4 refers). This 'land swapping' is not considered consistent with PPS3, nor is it considered to be justified or effective in delivering the desired strategy. This is particularly the case as most of the existing employment sites are occupied and therefore unavailable for redevelopment. In addition, the new Greenfield sites are in an arguably less sustainable locations away from the top tier settlements identified on page 40 of the Submission Core Strategy. Clearly this element of the strategy is inconsistent with the wider strategy.

The Industrial Land Availability Study 2006 is included as an evidence base by the District Council. It includes an introductory section, which explains that the authority wishes to make Rochford the place of choice for new business. It includes several strategic objectives on page 7 including "Support town centre and industrial estate enhancement initiatives aimed at improving the environment ensuring the area is economically prosperous and competitive." It reviews existing employment areas and identifies vacant land, including land available from allocations. It does not include any assessment of new sites or potential opportunities for new sites that might have been expected to feed into the Core Strategy. The strategy for identifying Green Belt site employment allocation does not appear to be based on any evidence in this document and in that context cannot be justified. The strategy being promoted potentially conflicts with Government policy in PPG13, PPG2 and emerging PPS4.

The Employment Land Study 2008 is a much later document. It has a key recommendation on page ii "we recommend that Rochford District Council adopts strong policies to protect existing employment land." Furthermore under recommendations for existing sites on page iii-iv of that document it states "In our view, Hockley Trading Centre is a strategically well placed employment location. However, we recognise the ambitions of the Hockley Town Centre masterplan and that within this the Council should consider it to be allocated for other uses. However, we recommend that this reallocation happen only if provision is made within the masterplan for office use within Hockley Town Centre as part of a mixed use scheme." The view of the writers of this document is clear - the Eldon Way Industrial estate (Hockley Trading Centre) is a good employment site and that it is for other reasons that alternative uses are being considered and only then if office development is supported. This supports our representations that new future uses at
the Eldon Way site should be employment dominated and that alternative uses should relate to the objectives of the Town Centre which is to enhance the shopping and leisure facilities. Residential is not an appropriate alternative.

This document recommends the use of land to the west of Rayleigh for employment and envisages Green belt release. However, the SCS does not explain through the evidence base why existing employment sites should be 'deallocated' and Green belt land unnecessarily used.

In addition to these key issues we have some specific concerns. As a consequence we maintain an objection to the second paragraph of Policy H1. This policy states that the Council will seek the redevelopment of various industrial estates including Eldon Way. The Policy says that alternative uses will be sought (presumably alternative to the existing employment offer) and that new land will be allocated elsewhere. This policy statement, in relation to Eldon Way in particular, is unsound for a number of reasons:

The emerging Hockley Area Action Plan consulted upon in 2008 states that the Eldon Way Industrial Estate is strategically well placed. In a sense this statement underplays the true importance of this highly sustainable employment location and only major employment area in Hockley/Hawkwell. The employment area is adjacent to the railway station and located a short distance from the main bus routes that run along Spa Road. Some of the residential areas of the town are also within walking distance of this commercial area, thus providing a potential for sustainable travel by employees. The Eldon Way Industrial Estate is therefore right at the heart of the settlement of Hockley/Hawkwell and provides an opportunity to meet sustainable transport objectives by reducing the need to travel by car. Consequently, this employment area should be highlighted as a premier employment site in sustainability terms, both in the context of PPG13, PPG4 and PPS6. To encourage alternative uses as set out in Policy H1 implies the removal of the majority of employment based activity at Hockley/Hawkwell and this would be contrary to National policy, would not be the most appropriate strategy when considered against alternatives and is therefore unsound.

Whilst it is acknowledged that improvement to the Eldon Way Industrial Estate can and should take place, the extent to which the mix of employment uses should be altered in favour of alternative land uses requires careful consideration. It is our view that a mix of existing or indeed new employment land uses with some Town Centre type uses should dominate the Eldon Way site. A mix of employment types between offices, light industry and other high technology industries should be encouraged as this will provide many locational advantages to the firms that agglomerate together. The Council says that the existing uses on this site are harmful to amenity. However, the site has operated for many years without any significant issues and if renewal for B1 type uses are encouraged then the employment area can be maintained without harm to amenity. Renewal of the employment stock can help develop and improve trade, improve the sustainability of businesses as a whole and make for a more flexible labour market as skill levels are varied. A singularly different use altogether or a variety of uses which excludes employment could undermine the long term sustainability of the area and Town Centre. As such Policy H1 is not an effective strategy and should be amended to acknowledge the importance of Eldon Way and the need to renew the employment stock to ensure that the site maintains its important role as a employment site, albeit with some ancillary alternative use development where appropriate.

The 2008 Retail Study notes that Hockley Town Centre is not strong and there is trade leakage. Eldon Way Industrial Estate provides a customer base for existing town centre uses. Weekday spending within town centres is an important contributor to the viability of many retail and leisure businesses either through expenditure by employees during the lunchtime trade or expenditure by employers, on necessary goods and services. This relationship helps sustain the critical mass of a centre and provides a platform for new retail and leisure growth. It is important to have a balanced centre with a variety of uses. Policy H1, as currently drafted, implies the removal of employment related development and this is likely to harm the vitality and
viability of Hockley Town Centre. The Council has presented no evidence to suggest that this is not the case. Importantly, the 2008 Retail Study explains that there is a need for additional retail and office space. In principle we would support additional office and other B1 type uses plus retail but employment uses should always dominate for the sustainability reasons given above. Retail and office development are likely to present a viable alternative to some of the more industrial type uses.

Consequently, we do not support the phrasing of the third paragraph of Policy H1 and maintain that the most appropriate strategy is to seek renewal of the employment stock with employment based uses and with some new retail development. Removal of employment land uses completely as currently implied-which was the approach adopted in the emerging Hockley Area Action Plan - is not a justifiable strategy.

One of the key tests of a Core Strategy is consistency between policies in the
emerging Plan and this strikes at the heart of demonstrating an effective strategy. Policy H1 implies alternative uses to employment and the relocation of Eldon Way to a site identified under Policy ED4. However, Policy RTC6 sets out a suite of policy criteria for Hockley Town Centre which includes employment and commercial activities. In addition Policy ED3 seeks the protection of sustainable employment sites (Eldon Way) and notes that some reallocation of existing employment sites will include a proportion of employment. It notes that in the case of Eldon Way employment development will form a component. The policies appear at odds with one another. The third paragraph of Policy H1 should be deleted as the second paragraph is sufficient to set a strategic context for delivering new housing development. The employment policies and Hockley specific policies should be left to consider the type and quantum of land uses appropriate in the area. If the third paragraph of H1 is to be retained then it should tie in more with Policy RTC6 and in our view explain that employment uses should dominate any redevelopment proposals for the Eldon Way site and that retail and leisure uses should be a supporting proportion.

Implementation, Monitoring and Delivery - page 132 onwards

One of the key tests of soundness is that the Core Strategy should be effective - it should be able to deliver its strategy. The Implementation strategy set out at page 132 onwards of the Core Strategy does not explain how Policy H1, RTC6 and the strategy for redeveloping Eldon Way (Policy ED2 and ED3) will be delivered. The comment at Policy ED3 on page 161 identifies it as a potential risk and alludes to land assembly difficulties and the choices to be made by owner/occupiers. In order to deliver the strategy there should be a clear understanding as to whether the new land use values being promoted are sufficient to encourage relocation voluntarily. Secondly there is a need for more information to be gathered and presented to show
that current occupiers and landowners are wiling to relocate and the timescales likely for this. For example, do the building lease contracts enable early review or are there any break out clauses. There should be some commentary on whether the Council will engage in compulsory purchase orders to pursue their strategy should the 'encouragement' route fail. As currently drafted there is no clear path to deliver the strategy and the danger is that despite reallocation, the sites identified for redevelopment will not come forward in the plan period. In this regard, evidence to satisfy the test of soundness is not provided.

Policy H2 - General Locations

We support the strategy that new housing growth should be targeted at land South of Hawkwell. This area is suitably located to the urban area of Hockley/Hawkwell and to tie in with the settlement tiers on page 40 of the Submission Core Strategy the same terminology for settlement should be used. This ensures a consistency within the SCS. The choice of this location as a housing growth area is appropriate as it would not contribute to the coalescence of the urban area with Ashingdon (there is existing
development between this identified housing area at Rectory Road and Ashingdon and moreover, Rectory Road can form a natural physical boundary for the new Green belt boundary. This area is also well located to the existing road network. Cherry Orchard Way has recently been improved and provides much better accessibility to the proposed housing growth area than any other location around Hockley/Hawkwell. The existing bus routes along Rectory Road also make this location sustainable and the additional housing proposed will help underpin the financial viability of bus routes in this area. Locally there are employment opportunities, including the small commercial estate off Main Road. The Eldon Way Industrial Estate adjacent to the Town Centre also provides the opportunity for employment locally. Extensive public open space, play pitches and built leisure facilities are located just to the north of this area and a community hall is located off Briar Close, nearby. The area to the south of Hockley/Hawkwell is close to local shops on the corner of Heycroft Road and Main Road and there are numerous footpath links between this area and the local community including links via Thorpe Road, Thorpe Close, Briar Close, Hawkwell Park and Park Gardens. The area therefore provides the opportunity to enhance existing links, including cycle links, and
contribute towards community integration - more so than other sites on the south side of this settlement. The site is also in the control of one house builder and deliverable.

However, we find that the Policy is not fully consistent with national policy and
furthermore needs to be reviewed in order to be justified and effective. We have concerns as to how the Green Belt review strategy set out at Policy H3 and in the Local Development Scheme integrates with this policy and feel that Green Belt review should be more explicit throughout the SCS. We note that it is only Policy H3 which indicates the need for Green Belt land review. In fact Policy H3 only pays lip service to the need for a Green Belt review and provides, at best, loose advice in this regard. It says that prior to 2021 Green Belt will be safeguarded save for the releases noted under Policy H2. Policy H3 then goes onto talk about land release for development after 2021 but no time period is set out to provide a framework for any Green Belt review in this latter period. In our view Policy H2 and certainly Policy H3 and Policy GB1 should explain fully the need for a Green Belt review and that such a
review should take place for a defined period. That such a review has not taken place in advance of the SCS is a serious matter for the Inspector to consider in the context of soundness. That said, it is considered that any review of Green Belt should have regard to a period beyond 2021 as indicated by draft Policy H3. Paragraph 1.9 of the East of England Plan explains "this RSS covers the period to 2021 but sets a vision, objectives and core strategy for the longer term". 2026 is therefore considered a minimum suitable period that any Green Belt review must have regard to in order to meet the 5 year land supply requirements in PPS3 for the period after 2021. However, Policy SS7 of the East of England Plan talks about Green Belt reviews up to 2031. In view of this and the need to explore the circumstances of Rochford - that existing settlements cannot contain future housing growth; that Green Belt is necessary to provide housing; and that these provide exceptional reasons to vary the Green Belt locally (paragraph 2.6 to 2.7 of PPG2) the policies and strategy for the SCS should identify a Green Belt review covering the
period to 2031 and set out why a review is necessary.

Policy H2 - Phasing and Quantum

The 2008 Preferred Core Strategy document indicated that the area south of Hawkwell should deliver 330 dwellings over a phasing period to post 2021 (see Policy H2 and H3 of that document). The SCS reduces the quantum of housing in this area to 175 but expects delivery by 2015. At a broader level the Preferred Options Core Strategy of 2008, (Policy H2) required 1,450 dwellings to 2015 and a further 1,050 by 2021. In the SCS the figures are now 775 and 1,010 respectively.

Since the SHLAA post dates the publication of the SCS, we are uncertain as to the reason why such a significant reduction in quantum of housing and extensions to the residential envelope is considered necessary. Presumably it is the 'new' strategy to redevelop existing employment areas within the settlements that has led to this change. Our representations on this strategy and specifically the Eldon Way Industrial Estate are included elsewhere within our representations. Previously we have commented on the Table at paragraph 4.6 of the Submission Core Strategy and the lack of evidence to underpin that table. It seems odd that in the space of a year the expected requirement for Greenfield sites has effectively halved on the basis of a SHLAA exercise. The community is therefore not able to effectively comment on the housing land supply and at this stage the Submission Core Strategy
is legally unsound.

That said, we are of the view that the quantum of housing envisaged south of Hockley/Hawkwell should be more than the 175 currently envisage. In coming to this view we have reviewed the Urban Capacity Study and the latest housing figures in the Annual Monitoring Report 2008. We conclude that the shortfall in housing land supply is such that 330 dwellings in this location is appropriate.

The recently published SHLAA is based upon the data obtained from the Urban Capacity Study 2007, a call for sites exercise and data from the Annual Monitoring Report 2008.

The 2007 Urban Capacity Study (UCS)

1. 2007 is widely recognised as being the peak level of house prices in the UK and it was acknowledged by Government and practitioners alike that 2007 house prices were at an unsustainable level. It is our view that utilising the 2007 UCS as an evidence base without reference to the market does not pick up the depressed demand that is likely to now exist. Recent corrections to the housing market now mean that housing land prices are at a much lower and arguably more affordable level than before. The implications are that some pdl may not be viable for housing development. Often brownfield sites have much higher development costs than Greenfield sites and so the yield from urban capacity will be much lower than anticipated in the 2007 study. One example is the employment allocation of the Adopted Local Plan located at 76-92 Main Road, Hawkwell. This site has been allocated for several years and has been available during the most recent rises in residential property prices during
2006-07. As a consequence the lack of progress on the site can only be described by its current occupancy and perhaps it comprises high value
uses that do not encourage redevelopment. Despite this the site is identified as having high potential for alternative use and high potential demand. The SHLAA form notes that there is no information on legal constraints (e.g., tenancy agreements) As a consequence it is difficult to see how this could continue to be a potential site and as a consequence the allowance for green field releases should be increased.

2. There are considered to be other instances in the UCS and the recently published SHLAA where the assumptions and calculations would indicate that the 1301 urban capacity figure is over optimistic and the SHLAA assessment is limited. In the assessment of 'non-residential sites in appropriate locations' within the UCS assumptions are made as to the probability of sites coming forward for new housing. 68-72 West Street, Rochford is identified as a high probability site but we note that it has been subject to 7 refusals of planning permission/conservation consent. There is a significant gap between the urban capacity identified as being suitable by the Council and the capacity applied for by the owners. Given its alternate use value, it is debateable whether the two capacity figures can be reconciled. No 247 London Road is another example of a site allocated in the Local Plan but which hasn't come forward. This is now the subject of a proposal for a care home and if approved would further limit the scope for market/affordable housing capacity on the site. A striking example of how the urban capacity study has underestimated is also evidence by 2-4 Alderman's Hill, Hockley - described as a disused service station. There has been no residential development application on
this site since 2004 and most recent applications have sought commercial use of the site. Rather than being evidence of housing land deliverability, this particular site evidences the need for commercial uses in the area.
There are therefore deliverability doubts over these 'high probability' categories which amount to some 40 units.

3. In relation to the assessment in the UCS entitled 'intensification of existing
residential uses' we note that the assessment is premised on an assessment of recent trends taking into account net completions between 2001-2006 and 2005-06. This is effectively an assessment of windfall trends and not an approach that PPS3 encourages. Importantly Table 3-12 in the urban capacity study seeks to project forward urban capacity from residential redevelopment - a period that benefited from high house prices and PPG3 guidance encouraging redevelopment. These two circumstances have markedly changed and so the assumptions and conclusions drawn would also have changed. Even taking into account the UCS discounting, the reliability of the 404 units from this source must be questioned and in our view the 1301 figure cannot be a sound basis for urban capacity and further Greenfield releases are necessary.

4. In the section of the UCS entitled 'subdivision of dwellings' and 'living above the shop' it is estimated that recent trends would result in 7 and 15 units. Our concerns with using trends as a basis for urban capacity are detailed above - PPS3 does not encourage this. Rather, local authorities are charged with surveying their areas, identifying which areas may yield urban capacity and how much and developing policies to achieve that. Government guidance does not encourage the estimation of windfalls in the way the UCS does.

5. Redevelopment of established employment land is a separate section
within the UCS. At 1 above we identify the low probability of the Main Road residential allocation coming forward. This remaining section of the UCS considers 11 further employment sites which were first identified in the 2000 UCS. Three of these are considered to have a high probability of coming forward. We have looked at these three sites and can find no evidence that they are likely to come forward. In the 8 years between 2000 and 2008 the three identified high probability employment sites have not been developed and there is no reason to assume that the next 5-10 years will be any different. For example the Rawreth Industrial Estate is identified as being well used in the UCS and although it has some unneighbourly uses there is no indication that the site is available, suitable or deliverable for residential. Land between 39-69 Lower Lambricks, Rayleigh is identified as having a high probability of residential uses. Yet there is no evidence of any pre-application advice or planning applications for this area. Stambridge Mills, Mill Lane, Stambridge is a further example. This site is separated from the urban area, in a flood risk zone and protected in the 2006 Replacement Local Plan by Policy EB9 which promotes B1 uses. Against this background there is only two relevant planning applications affecting this area both date from the early 1990's and relate to a plant room and loading bay. There is no evidence that this is likely to come forward for residential purposes in the next 5-10 years.

6. In the UCS extant permissions are identified as 856 dwellings. It is
important to note that this figure needs to be continually reassessed so
that from the point of adoption of the Core Strategy a 5 and 10 year
housing land supply is available. The SHLAA notes extant permissions for
2009-14 being 106. As noted below extant permissions do not necessarily
translate into deliverable sites. There is therefore a contingency that
needs to be built in. Further allocations on greenfield land need to be
increased and as such the quantum of housing in the area south of
Hockley/Hawkwell should be increased to 330 dwellings in order to begin
to meet the shortfall identified.

The District Council's 5 year housing supply assessment

7. The District Council's Annual Monitoring Report ("AMR") 2008 purports to
demonstrate a 5 year housing land supply. The preamble to Table 4.10 in
the AMR 2008 explains that Rochford District Council ("RDC") has
included units under construction, units with full permission, units with
outline permission, units with a resolution to grant, units subject to preapplication discussion/Urban Capacity Assessment and land allocations in
its trajectory. The reader is referred to Appendix B which breaks down the
sites in more detail. The recently published SHLAA also includes a table
showing a potential 1273 dwellings deliverable. However, it refers to
"appropriate brownfield sites." Since these 'appropriate sites' are do not
benefit from an application or a planning permission it is difficult to
programme them into the housing delivery trajectory.

8. In the full planning permission category of the AMR 2008 where work has
not yet started there can be no guarantee that all these sites will be delivered in the 5 years. This comment relates to the one above in relation to the recently published SHLAA. It is not uncommon for permissions to be obtained to provide a means for valuing a site where the owner has no immediate plans to sell the site or develop housing. Delivery may also be hampered by funding constraints, or site assembly problems (where sites are in an alternative use or relocation constraints). Appendix B of the AMR 2008 does not set out the intentions of the landowner or whether the sites are truly achievable in the 5 year period as per PPS3 requirements. The SHLAA purports to show developer intentions at Appendix C but the assessment by the local authority into the legitimacy of some of the claims is not presented. The evidence base is not as full as it should be to demonstrate the robustness of Table 4.6 of the SCS. It is also unclear the extent to which this table is based on either the UCS 2007, AMR 2008, SHLAA 2009 or a combination of all three. This should be set out clearly.

9. In addition, to the 'non delivery' of a proportion of new homes in the AMR
2008, there is concern at the timings of delivery in that data set, for
example, 10 units in 2008-2009 relates to outline planning permissions
and it is doubtful whether reserved matters can be turned round quick
enough to begin delivering housing in this year period. There could well
be examples in that set of data where the delivery of units in the first year
of the 5 is unlikely, thus delivery is reduced for that period and pushed
back and this process is then compounded throughout the data set up to
and beyond year 5. Statistical evidence from the Department of
Communities and Local Government ("CLG") reveals that building starts
are 43% down on the quarter to March 2009 compared with March 2008.
It is not clear whether the recently published SHLAA has taken this into
account and unless it does the data in the Table at 4.6 of the SCS cannot
be relied upon, particularly given the current recessionary circumstances.
In relation to the Table at Paragraph 4.6 a refinement is therefore needed
to take into account this effect on phasing.

10. This problem is compounded for other units relied upon where permission
has been granted but no start on site has been made; this accounts for a
considerable number of sites in 2009-10 period (100 dwellings) which is
(year 2 of the 5 year period). A delay in these will require more Greenfield
sites to be identified in order to meet the shortfall.

11. Finally we note that the East of England Plan expresses its land supply
requirement as a minimum. This strategy is not reflected in the
Submission version of the Core Strategy policy H2.

12. In summary since neither the UCS nor the Annual Monitoring Report form
a SHLAA, reservations are maintained about the degree to which
sufficient housing land has been identified.

Policy H3

In the Preferred Options Core Strategy 2008 more locations were identified for
housing growth in the post 2021 phase. Whilst it is our view that land south of
Hockley/Hawkwell should benefit from a greater number of dwellings than the 175 currently identified (330) in order to make the strategy effective. We are concerned at the significant change in strategy between the Preferred Option Core Strategy and the Submission version, which has significantly less housing growth on green field sites. This change in strategy is so significant that we would question whether it is appropriate in the context of soundness and the consultation processes that have taken place so far.

We also have concerns as to how the Green Belt review strategy set out at Policy H3 and in the Local Development Scheme integrates with other policies in the SCS and feel that Green Belt review should be more explicit throughout the SCS. As it currently stands there is a potential conflict with national policies and limited justification for the Green belt strategy. We note that in Policy H3, which indicates the need for Green Belt land review, the advice is limited and unclear. In fact Policy H3 only pays lip service to the need for a Green Belt review and provides, at best, loose advice in this regard. It says that prior to 2021 Green Belt will be safeguarded save for the releases noted under Policy H2. Policy H3 then goes onto talk about land release for development after 2021 but no time period is set out to provide a
framework for any Green Belt review in this latter period. In our view Policy H3 and Policy GB1/H2 should explain fully the need for a Green Belt review and that such a review should take place for a defined period. That such a review has not taken place in advance of the SCS is a serious matter for the Inspector to consider in the context of soundness. That said, it is considered that any review of Green Belt should have regard to a period beyond 2021 as indicated by draft Policy H3. Paragraph 1.9 of the East of England Plan explains "this RSS covers the period to 2021 but sets a vision, objectives and core strategy for the longer term". 2026 is therefore considered a minimum suitable period that any Green Belt review must have regard to in order to meet the 5 year land supply requirements in PPS3 for the period after 2021. However, Policy SS7 of the East of England Plan talks about Green Belt reviews up to 2031. In view of this and the need to explore the
circumstances of Rochford - that existing settlements cannot contain future housing growth; that Green Belt is necessary to provide housing; and that these provide exceptional reasons to vary the Green Belt locally (paragraph 2.6 to 2.7 of PPG2) the policies and strategy for the SCS should identify a Green Belt review covering the period to 2031 and set out why a review is necessary. Not to do so is unsound for justification and effectiveness reasons.

Policy H4 - Affordable Housing

As currently drafted we feel that the policy is not concise enough and that the policy does not reflect current guidance. The phrase 'at least' would indicate that in most cases affordable housing above 35% will be sought. Our understanding is that the 35% figure is recommended in the SHMA and that to provide a policy framework which seeks to go beyond that figure would potentially be unworkable as many sites could not financially bare the burden of over a third of the net developable area not yielding a value. The policy should be redrafted so that "a target of 35% affordable housing shall be provided on all developments of 15 or more units..."

The last policy paragraph provides some scope to relax this policy, if there are clear site constraints that make on site provision impossible. The policy, though, is not particularly clear on what would constitute exceptional circumstances. For example, physical site constraints, which unusually raise development costs, would be one such reason and this should be specified. There may be other reasons including the nature of housing needs in the part of the District the site is located which justify affordable housing below the 35% target. Design reasons may also have a bearing on how provision is made and in what form, particularly if the site is in an historic area where design might override housing need argument. It is therefore recommended that the policy expand on the type of circumstances where affordable
housing may be relaxed and the type of information that will be sought of applicant's who have a need to invoke this part of the policy.

Policy H5

In support of the policy, it is advantageous that no percentages requiring a specific mix are included. This flexibility will enable developers and the Council to respond directly to changing circumstances in the local housing market. In the past some authorities have set out a percentage for the type of housing they require only to find that after a few years of strict implementation there is an oversupply of property of that type and no flexibility in the policy to address the problem.

Policy ED2 - London Southend Airport

It is considered that to grow non aviation related employment at a location north of Southend Airport where sustainable access from the rest of Rochford District requires careful consideration. Most Airports are serviced by aviation related employment development and as such a location close to the airport is sensible and sustainable. However, for surface access reasons it would be inappropriate to encourage travel from Rochford's main settlements to what essentially would be a rural location for general employment uses. Whilst sustainable access would be improved by a railway station and better bus links, there is no evidence to suggest that a sustainable surface access strategy for non related employment development at the Airport can be achieved. Paragraph 11.22 explains the critical importance of a
railway station to the delivery of the strategy yet the Transport Chapter and
Implementation Chapter provide neither a policy nor an assessment of deliverability. It is also notable that the South Essex Rapid Transit Policy T4, as set out at paragraph 10.16, notes that Rochford is not proposed to be served but may be served in future phases. This uncertainty is no way to plan for a major employment land supply strategy in the District. In relation to PPS12, the ability to deliver sustainable green field employment sites away from the top tier settlements of Hockley/Hawkwell, Rochford and Rayleigh is unsound.

Policy ED3

We fully support the first sentence of the Policy and note the apparent contradiction with the statements in Policy H1 and elsewhere which seeks to develop on alternative uses at industrial estates such as Eldon Way.

This contradiction is evidence in the second paragraph of Policy ED3. In our
representations on Policy H1 we have explained why it is not sound to diminish the employment stock at Eldon Way and the importance of maintaining a dominance of employment type uses at this estate. These arguments are not repeated here.

We note the sentiments of the third paragraph and in accordance with our
representations elsewhere are of the view that this sentence should be revised to explain that Eldon Way will accommodate principally employment type uses. As noted elsewhere uses which are an alternative to employment would diminish this highly sustainable employment site and this is unsound when assessed against National Policy.

Policy ED4 - Future Employment Allocations

In part, the de-allocation strategy is not supported as it is considered unsound when set against sustainability criteria. In relation to the Eldon Way Industrial Estate it is considered critical to the ongoing sustainability of this settlement that employment uses are maintained at this location. It is close to the railway station, bus routes and local residential areas from which the opportunity exists for employees to walk or cycle to work. Its location adjacent to the Town Centre offers opportunity for some retail and leisure development to complement the centre and to maintain a supporting function. These sustainable benefits would not occur with the deallocation of Eldon Way or the significant erosion of its employment floorspace. Whilst redevelopment of the employment site to achieve new employment is supported, the dominant land use should continue to be employment use. As a consequence, the 18ha of land required for employment in this policy is considered to be excessive and the policy should be reviewed to explain that redevelopment of existing employment sites for primarily new employment development will be
encouraged.

Policy T4

It is noted that the South Essex Rapid Transit policy, as elaborated upon at
paragraph 10.16 notes that Rochford is not served but may be served in future phases. This uncertainty is contrary to the delivery principles of soundness and directly puts at issue the employment land supply strategy in the District which is founded on sustainable access to new sites. In relation to PPS12, the ability to deliver sustainable green field employment sites away from the top tier settlements of Hockley, Rochford and Rayleigh is unsound.

Appendix H1, CTL1 - Infrastructure

It is recognised that necessary infrastructure provision is an important part of creating a sustainable development and in that context appendix H1 is supported. The supporting text notes that the table at Appendix H1 is not exhaustive and in that context it is very important that the framework properly distinguishes between what should be provided as part of new development schemes and what shouldn't. It is therefore essential that the framework acknowledges the importance of Circular 05/05 and the tests which say that provision of infrastructure and/or contributions should be:

* Relevant to planning
* Necessary to make the proposed development acceptable in planning
terms
* Directly related to the proposed development
* Fairly and reasonably related in scale and kind to the proposed
development
* Reasonable in all other respects

As is made clear (Paragraph B9 of Circular 5/05) contributions should not be used to make good existing deficiencies in infrastructure provision. Nor are they to be used to secure contributions to the achievement of wider planning objectives that are not necessary for consent to be granted. In that context the Core Strategy should set this out as its policy framework.

Policy GB1 - Green Belt

The objectives of this policy are supported, although as noted in other
representations the SCS is unsound as it does not meet the tests in relation to
justification, compliance with national policy or effectiveness of strategy.

Policy GB1 mentions the objective to allocate the minimum amount of Green Belt land necessary. The policy should link to the requirements of PPG2 and RSS which are discussed in relation to the representations on Policy H2 and H3. The policy should set out a timeframe for the review and why Rochford requires a Green Belt review (what the exceptional circumstances are in this District that justify a review of local boundaries. The policy should be amended to set out a 2031 time frame and this may require the SCS to have an extended life span beyond 2021.

We would recommend the deletion of the word character since Green Belt
designation is not related to landscape character as currently drafted. For clarity we would also recommend that the Policy or its supporting text explain that a Green Belt review will takes place in support of an allocations document (paragraph 6.6) in order to identify an appropriate new boundary. This is particularly necessary given the commitment to a Green belt review in the adopted Local Development Scheme.

Policy CLT1 - Planning Obligations and Standard Charges

In view of the need to test fully the basis on which standard charges are based it is important that any document produced is in a development plan document that enables an examination in public. The policy should explain this in order that when the document is produced it accords with Policy and is based on sound evidence.

ENV9 - Code for Sustainable Homes

Object. The advice from the Department of Communities and Local Government is that the new requirement to have a rating against the Code does not make it mandatory to build a Code home or to have each new home assessed against the Code. It does however mean that all buyers of new homes be given clear information about the sustainability of the new home. A house builder can do this in one of two ways:

- they can chose to build a Code home, have that home assessed against the
Code and provide the home buyer with a Code certificate stating the star rating the home has achieved
- or, they can chose to build to current building regulations standards, not to pay for an assessment and instead download a nil-rated certificate of non-assessment (also referred to as a nil-rating) to provide to the home buyer.

As such the Rochford policy requirement that coding 3 be achieved by 2010 and Code 6 by 2013 is out of step with Government advice. The policy wording should explain that it is just the coding that is a requirement of new homes and not necessarily that new homes should be constructed to achieve a standard.

The current Government objectives are for the code to be introduced over a
reasonable period with development to be code 3 by 2010, code level 4 by 2013 and code level by 2016. In this regard the policy, as drafted, seeks to achieve code 6 by 2013 and consequently compresses the code requirements into a shorter time scale with the costs associated expected to be subsumed within the housing market though higher prices. This is not a realistic strategy for the delivery of sustainable homes and we consider that the policy should be revised to extend the period of compliance but to also make it more flexible based on local circumstances.

Research undertaken on behalf of the Housing Corporation and English
Partnerships, published in February 2007 'A cost review of the code for sustainable homes' reveals that code 6 is unlikely to be unattainable given existing technologies and that achieving code 5 could result in a 12% to 20% increase in costs that would have to be passed onto the consumer. Given the variability of the housing market with peaks and troughs, it is unlikely that the housing market would be able to subsume this level of price increase.

The code system policy as currently drafted does not have regard to site
circumstances and so many of the requirements could be difficult to meet. For
example, micro electricity generation on site may be difficult to achieve where local circumstances deter the capture of wind or solar power. If more expensive technologies are required to generate power than is the norm then costs will rise. There may be other competing reasons why designs cannot include certain sustainability measures if housing sites are in sensitive landscape and historic locations. Alternatively there may be significant development costs associated with site specific circumstances and so viability of the site's development becomes a valid consideration. By insisting on the code for sustainable homes other policy objectives such as affordable housing at particular rates and other contributions may need to be reconsidered. Consequently, we are of the view that this policy should be drafted in a
manner which enables site specific circumstances to be taken into account. As noted above the Government explains that the code is a certification requirement and does not necessarily mean that buildings are constructed in accordance with a code level.

It is also important to note that it is not the purpose of planning legislation to duplicate other legislation. In this regard, the policy should accept that the Building Regulations will be the main vehicle for implementing this policy and that unless the coding requires external development then there will be no need to specify what is to be carried out in a planning application.

Iceni submitted representations to the Core Strategy Strategy Submission (CSS) document on behalf of Colonnade Land LLP (CLLLP) in October 2009. In reviewing the document, it was considered that the document consistently fails to meet the tests of soundness set out in the table following Paragraph 4.52 of PPS12 particularly with regard to the requirement to find the document justified, that is 'founded on a robust and credible evidence base'; effective, that is 'deliverable and flexible' and consistent with national policy. To clarify this matter further, the representations of CLLLP confirm that:
* The plan fails to cover at least 15 years from the date of adoption since the CSS should look to plan for the provision of housing up to 2026 at the earliest.
* At the time of the submission of representations to the CSS, the Strategic Housing Land Availability Assessment 2009 had not been published. As a consequence, representations to the CSS did not include an opportunity to comment on the information contained within this document. In this regard, the CSS consultation document was not supported by a robust, transparent and credible evidence base.
*The Stambridge Mills site is identified within the CSS policy H1 for high density residential development. The site lies wholly in Flood Zone 3 and identification of this site is considered inappropriate as there is no evidence provided within the consultation package that the Sequential Test and the Exception test have been applied. The absence of an evidence base means that poligy H1 is not justified, effective, or consistent with national policy (in particular the requirements of paragraph 14-20 of PPS25).
*The CS is not supported by a compliant Strategic Flood Risk Assessment (SFRA). The CSS is reliant on the Thames Gateway South Essex SFRA which was produced in accordance with PPG25. In the absence of a PPS25 compliant SFRA the CSS is neither 'justified' nor consistent with national policy and is therefore unsound.
*As a consequent of the two points above, Stambridge Mills is not considered to be deliverable within the context of paragraph 54 of PPS3. Consequently the CSS is not consistent with PPS3 and is not flexible enough to ensure the CSS can meet minimum housing targets contained within the East of England Plan.

The full case of the CLLLP is set out in the representations to the CSS and separately in representations to the SHLAA which we understand were not registered by the Council.

It is also noted that representations submitted by the Environment Agency indicates similar concerns in relation to the Stambridge Mills site in the context of the lack of sufficient evidence to justify the underlying assumption that protecting Green Belt land should take preference to avoiding high density development in areas within Flood Zone 3 which would pose risk to life and property.

In order to produce a legally compliant and sound CSS, the Council should:
To make the document jusfitied:
*Re-open the consultation on the CSS in order that the Strategic Housing Land Availability Assessment can be considered within the consultation package;
*Delay the Core Strategy in order that the Council can produce an up to date and PPS25 compliant SFRA
To make the document effective:
*Undertake a Sequential Test and Exception test to ensure that the Stambridge Mills site is suitable for residential development and conforms with the requirements of PPS 25
To make the document in accordance with national policy:
*Identify sufficient sites in the event that identified housing sites are found to be undeliverable or undevelopable in accordance with PPS3;
*Undertake the sequential and exception tests as required by PPS25
*Produce an SFRA as required by PPS25

Iceni, on behalf of CLLLP seek the opportunity to present their representations in full on the Core Strategy due to the wide ranging implications and significant nature of the objections to date.