APPENDIX A: PLANNING POLICY CONTEXT

Rochford Town Centre Area Action Plan - Issues and Options Consultation

Thank you for consulting the Assembly on the above matter.

The Regional Planning Panel Standing Committee considered a report on this consultation document at its meeting on 6th November 2009 before endorsing the recommendation that 'the Rochford Town Centre Area Action Plan does not give rise to any general conformity issues at this stage.'

Our detailed comments are set out in Appendix A of the attached report which, together with this letter, constitutes our formal response at this consultation stage. Please note that in Appendix A, where regional and local policy have been cross-referenced and no comment has been made, the local policy is considered to conform to the East of England Plan.

If you have any queries concerning the content of the report or any other issue relating to conformity with the East of England Plan, please contact either myself of James Cutting, Team Leader: Strategy & Implementation on tel (01284) 729434 or email 'james.cutting@eera.gov.uk'.

Purpose

To give a response to the Rochford Town Centre Area Action Plan Issues and Options consultation document.

Recommendation

The Standing Committee is asked to consider the recommendation that the comments in this report constitute the Assembly's formal response to the consultation document.

1. Introduction

1.1 Rochford District Council has published for consultation the Issues and Options stage of the Rochford Town Centre Area Action Plan (AAP). The purpose of this Development Plan Document is to set out how Rochford can accommodate change and new growth while still recognising its Conservation Area status.

1.2 The focus for the AAP is the defined town centre boundary. A copy of the 'Broad Land Use Plan' is included at Appendix B.

1.3 The closing date for comments is Monday 30th November 2009. Further details can be found on the Council's website:

http://www.rochford.gov.uk/planning/policy/local_development_framework/rochford_area_action_plan_-_is.aspx

2. Background

2.1 Rochford District covers an area of 168 km2 (65 miles2) and is situated on a peninsula between the River Thames and Crouch. Bounded to the east by the North Sea, it shares marine boundaries with Maldon and Chelmsford, and land boundaries with Basildon, Castle Point and Southend. The A127 and A130 provide strategic road links to the M25 and beyond, and there are direct rail services to London. London Southend Airport is located along the southern boundary with Southend Borough.

2.2 Rochford is the second largest town in the district, and is classified by the Council as a local centre. The 2001 census puts the population at about 7,600. The town centre follows fairly traditional street patterns and has a market square at its heart. Its unique character and layout are regarded as a local asset. Despite a strong local convenience sector Rochford suffers from a significant leakage of spending elsewhere, particularly towards nearby Southend.

2.3 Rochford Railway Station lies to the west of Market Square, and there is a primary school and hospital to the north. To the south-west, Rochford Golf Course provides a green buffer between the town and the nearby Southend Airport. Road and rail links connect Rochford to its close neighbours - Hockley and Southend.

3. Regional and Local Policy

3.1 Regional planning guidance for Rochford is contained within the adopted East of England Plan (May 2008) (the 'Plan') and the remaining saved policies of the Essex and Southend-on-Sea Structure Plan. The 'Plan' requires the Rochford district to contribute a minimum of 4,600 new homes and accommodate a share of the Essex Thames Gateways target of 55,000 new jobs between 2001 and 2021.

3.2 Rochford District Council recently went out to consultation on their Submission Core Strategy1. This sets out the development strategy for the District to 2025 and, through Chapter 12 and policy RTC5, the framework against which this AAP is being brought forward. In assessing this AAP, all relevant policies in the East of England Plan have been considered.

4. Comments

4.1 Rochford has a number of limited opportunities for development within its existing built up area. Following initial public consultation, this AAP puts forward eleven sites and explores opportunities for improvements to the street scene (in keeping with the towns conservation area); better traffic circulation, including access to and from key gateways such as the railway station, and opportunities for making better use of existing car parking areas. The AAP also recognises that taking any of these options further is dependent on any number of viability factors, but believes that those sites put forward offer commercially sound development opportunities.

4.2 At this Issues & Options stage, the Rochford Town Centre AAP does not give rise to any general conformity issues. The Assembly also recognises that the Preferred Option for redevelopment is ultimately a matter for local determination. That said, an AAP that aims to deliver the sustainable redevelopment of previously developed land, improved connectivity and greater access to public and non-motorised forms of transport, and promotes a thriving and active town centre that pays appropriate regard to its existing built heritage is supported.

5. Recommendations

5.1 The Standing Committee is asked to consider the recommendation that the comments in this report and Appendix A constitute the Assembly's formal response to this Issues and Options consultation document.

Appendix A

Part two - General Points

Question - Does the area covered lie within the Eastern Region?
Answer - Yes

Question - Are all references to the East of England Plan correct?
Answer - No
Comments - All references to the East of England Plan need to be checked. In particular, para' 3 (page 63) contains two important factual errors:

The region's housing target is 508,000 (not 421,500 as stated);
The Essex Thames Gateway Sub-region has been set an indicative growth target of 55,000 net new jobs (not dwellings), of which 3000 are expected to come forward in Rochford.

The Council is also reminded that the suffix 'RSS14' should no longer be used when referring to the East of England Plan.

Question - Does the area covered include a Key Centre for Development and Change?
Answer - No

Question - Are there any key issues covered by the document that are of strategic or regional importance?
Answer - No

Part three - Consistency/conformity checklist

Question - Is there a clear drive for sustainable development?
EofE plan policy - SS1
AAP ref's - Vision & Objectives
Comments - The broad principles of sustainable development are evident throughout the AAP.

Question - Does policy seek to maximise the use of previously developed land?
EofE plan policy - SS2
AAP ref's - All
Comments - Redevelopment of brownfield site opportunities is consistent with regional policy.

Question - Is there a clear development pattern for urban areas? Is the role of the town centre clear?
EofE plan policy - SS4 SS6
AAP ref's - All

Question - Are regional employment targets met?
EofE plan policy - E1
Comments - This is addressed in the Rochford Core Strategy.

Question - Does the AAP contribute positively towards regional housing targets? Has affordable housing provision in the town centre considered?
EofE plan policy - H1 H2
Comments - The Submission Core Strategy allocates new housing to West Rochford. From this, it is assumed that the area in question lies beyond the AAP boundary. However, the AAP should consider how new housing growth might impact on issues such as transport / public access into the town, and on how it can help support the towns retail sector.

Opportunities for residential development above local shops are considered. These could provide affordable tenure opportunities.

Question - Are culture/leisure issues addressed?
EofE plan policy - C1, C2
AAP ref's - Vision & Objectives

Question - Does the AAP seek to change and influence travel behaviour? Are sustainable urban/rural/local transport issues addressed?
EofE plan policy - T2, T9, TT13 T4, T7, T8
AAP ref's - 2.22-2.26, 2.30-2.41, Objectives & Options, 3.25-3.36
Comments - Existing patterns of traffic movement are identified as a problem.

Any changes that will deliver improvements in pedestrian access, public transport and public transport facilities would be supported. Safe, covered storage facilities at, for example the railway station, may encourage greater use of bicycles.

Question - Are there any policies on parking management?
EofE plan policy - T14
AAP ref's - 2.27-2.29, 3.26-3.27, Site Options
Comments - Rochford has a number of large, ground level, car parks.
Parking controls can be an effective means of influencing travel behaviour. They may also impact on local trade. Any redevelopment of the towns parking areas to meet other needs would be supported, but should only be done as part of a package of measures which deliver improvements in public transport services and greater access via footpaths and cycleways. The AAP will also need to carefully consider what impact parking restrictions may have on the town's current and future retail trade.

Question - Is there a policy relating to green infrastructure?
EofE plan policy - ENV1
AAP ref's - Options, 3.24
Comments - Opportunities that provide green links between the town centre and the more open areas to the south should not be overlooked.

Question - Is conservation/enhancement of the historic environment addressed?
EofE plan policy - ENV6
AAP ref's - 2.15-2.18, Table 3, 3.23
Comments - The need to consider Rochford's Conservation Area status is evident throughout the AAP.

Question - Does this AAP seek to deliver high quality in the built environment?
EofE plan policy - ENV7
AAP ref's - Options

Question - Has the need to reduce carbon emissions been addressed? Are water efficiency measures, water management and flood risk issues addressed? Are waste management issues addressed?
EofE plan policy - ENG1 WAT1-WAT4 WM1-WM8
Comments - Beyond those measures set out in the Core Strategy, the Council should consider whether additional standards for resource efficiency, renewable energy and waste management need to be included in the Area Action Plan.

Question - Is there a policy on implementation and monitoring?
EofE plan policy - IMP1 and IMP2
AAP ref's - 3.37

Part four - Overall Assessment

Question - Is this Development Plan Document in general conformity with the East of England Plan? (If not, what is needed to rectify this?)
Answer - Yes
Comments - At this Issues & Options stage, the Rochford Town Centre AAP does not give rise to any general conformity issues. The Assembly also recognise that the Preferred Option for redevelopment is ultimately a matter for local determination. That said, and AAP that aims to deliver the sustainable redevelopment of previously development land, improved connectivity and greater access to public and non-motorised forms of transport, and promotes a thriving and active town centre that pays appropriate regard to its existing built heritage is supported.

Essex County Council
Rochford Town Centre Area Action Plan Issues and Options


1. General Comments

Although the current document is a Issues and Options Report (rather than the Area Action Plan itself) it should be mentioned that, where appropriate, further guidance will be provided in the further stages of the Area Action Plan that will guide the form and character of developments in more detail. This guidance should include schematic layouts and perspectives, in the form of Design Briefs where appropriate. It would be an important element in achieving an acceptable form of development and helping to ensure that the aims of the Area Action Plan are achieved. This particularly applies to some of the more central sites, redevelopment of which would have the potential to have a considerable impact on the character of the town as a whole. The importance of a thorough site context analysis should be stressed as a prelude to production of any site brief.

The document acknowledges (paragraph 2.15) that the Conservation Area Appraisal and accompanying management plan set out measures to preserve and enhance the character or appearance of the area. The key elements of these documents will need to be reflected in any solutions brought forward for Rochford Town Centre. The Area Action Plan provides an ideal opportunity to do this. Specifically, these initiatives could include the rationalisation of signage, the reduction in street clutter, upgrading of surface materials etc.

The Issues and Options document concentrates on specific sites but the importance of Conservation Area-wide initiatives that would result in an upgrading of the area should not ignored. The Conservation Area can be enhanced through the encouragement of incremental, small-scale improvements throughout the whole Conservation Area. Also, tree planting and landscaping improvements in car parks should be specifically encouraged as identified in the Management Plan.

In terms of presentation, the Issues and Options document would have benefited from a composite plan showing the locations of the potential opportunity sites (A-K). This would have enabled easier and better appreciation of how the sites relate to each other and to the overall town structure. Also a plan with road names shown would be useful. It is hoped that these omissions can be remedied during the further stages in preparation of the Area Action Plan.

2. The Site Options

The following comment applies to the individual site options,

SITE A - redevelopment of this site should be informed by a carefully thought out design brief, with the height and scale of new building reflecting the other buildings in the square. Any development option for Site A will need to consider the potential for extensive urban archaeological deposits surviving within the area of the Market Place, and the impacts the development will have upon this resource.

SITE B - restriction of vehicular use in the square will not automatically create a pedestrian space. It could become merely empty unless some attraction or facility makes pedestrians want to use the square. The routing of buses through West Street should be carefully considered because buses have caused damage to listed and other buildings and create traffic congestion. The full or part pedestrianisation of the Market Square would need to consider the potential for extensive urban archaeological deposits surviving within the area and the impacts development will have upon this resource.

SITE C - any redevelopment should consider retention of the Indian restaurant and florist. Any development option for the site would need to consider the potential for peripheral urban and industrial archaeological deposits surviving on the fringe of post-medieval Rochford and the potential impacts the development will have upon this resource.

SITE D - redevelopment of the site would fill the gap in the street scene and enhance the appearance of the town. The size and appearance of any buildings are important in Conservation Area terms, but their use is a lesser issue. Any development option for the site will need to consider the potential for urban archaeological deposits surviving within the historic core of Rochford and the impacts the development will have upon this resource.

SITE E The car dealer's is pretty much an historic building and should remain. Any development option for Site E will need to consider the potential for peripheral urban and industrial archaeological deposits surviving on the fringe of post-medieval Rochford and the potential impacts the development will have upon this resource.

SITE F - development could help create a stronger, continuous frontage on Bradley Way. Any development option for the site will need to consider the potential for archaeological deposits surviving on the fringe of post-medieval Rochford and the potential impacts development will have upon this resource.

Sites G & H - Any development option for these two sites will need to consider the potential for peripheral urban archaeological deposits surviving outside the present built area of Rochford and the potential impacts development will have upon this resource.

Site J - Any development option for the site will need to consider the potential for peripheral archaeological deposits surviving outside the historic core of Rochford and the potential impacts development will have upon this resource.

3. Historic Environment matters

Whilst the Issues and Options document mentions the historic environment, this principally relates to the built environment with no reference to the significant archaeological deposits surviving as below grounds deposits. The further stages in production of the Action Area Plan should include reference to these important deposits as they form an essential part of the history of Rochford town and help provide a sense of place to the settlement.

To ensure that the historic environment is appropriately considered within the Action Area Plan the following changes to the existing text are recommended: (changes in Bold)

Paragraph 1.7 - Thirdly, Rochford Town Centre is a designated Conservation Area (Policy BC1 of the Rochford District Replacement Local Plan) and has a strong historic character and a number of cultural and heritage assets that are important to preserve or manage. Thus any development that takes place will need to be extremely carefully managed.

Paragraph 1.9 - The focus for the AAP is the defined town centre boundary as illustrated on the current Local Plan Proposals Map. The historic heart of Rochford Town Centre is the Market Square.........

Paragraph 1.10 - The town centre includes a high number listed buildings, sites of significant archaeological potential and it has a high intrinsic value.

Paragraph 1.14 - Alongside the regional and local planning policy documents, there are a number of other documents (Rochford Futures Study; Annual Monitoring Report; Urban Capacity Study; Employment Land Study; Conservation Area Appraisal; Retail and Leisure Study, Rochford Historic Town Assessment) and Rochford Historic Environment Characterisation Project, that explore the issues that Rochford is facing. These documents have fed into this Area Action Plan and are also summarised in Appendix A.

Addition to Appendix A - Rochford Historic Town Assessment: Comprises an archaeological and historical assessment of Rochford, It forms part of the Essex Historic Towns Survey which is an extensive urban survey as defined by English Heritage. )

Table 2: Character - Rochford's Town Centre is defined by its historic character. The built form is of a fine grain and relatively small, intimate and human scale. It has a very high intrinsic quality. The Market Square is at the historic heart of the town and surrounded, in the main, by attractive buildings looking onto it. The town has developed about a medieval cruciform pattern of streets, which come together at Horners Corner to the east of the Market Square.

Paragraph 2.15 - For the purposes of this study a thorough understanding of the historic environment character is essential to understand the area's special qualities and the reasons why it has been designated as a Conservation Area....

Paragraph 2.16 - Generally the special character of Rochford Town Centre is comprised of the interrelationship of the following elements:
- A well preserved historic medieval market town centred on a cross roads and market place
- A collection of historic buildings of high architectural quality many of which are listed
- A characteristic medieval and post medieval street plan comprising axial roads, infilled market, Back Lane and irregular frontages all of which illustrate the settlements medieval origins and high potential for surviving archaeological deposits.

Figure 3 Heritage and Conservation - should include the extent of the historic core as identified in the Rochford HEC and Historic Environment Record

Table3 - Conservation and Heritage
- Rochford Town Centre is a Conservation Area with a picturesque historic core and a collection of buildings of high historic and architectural quality, some are listed
- Rochford has a fine grain of development with intimate spaces of human scale, good enclosure which should be respected in any new development
- Any developments in the town centre will need to respond to this context having regard to the detailed analysis carried out in the Conservation Area Appraisal
- Any developments within the town centre and its immediate hinterland will need to fully consider the cultural assets and the high potential for the survival of significant archaeological deposits and the requirements for appropriate preservation or mitigation.

4. Transportation matters

No specific comment on transportation matters is made at this stage. However, of relevance are the transportation considerations which have informed preparation of the Core Strategy and assessment of development options for the Rochford and Ashingdon areas. More detailed consideration will be required of the transport implications of proposals as they emerge through the further stages of the Area Action Plan. The County Council, as Local Highway Authority, can offer further advice and guidance on transportation matters as proposals for the town centre evolve.

5. Education matters

The further stages of the Area Action Plan should consider the improvement of walking and cycling routes to school because travel to school routes cross through the town centre.

The definition of Infrastructure in the Glossary includes schools but not Early Years and Childcare. In order to capture all types of education use of the term 'Education' is preferred in this context.

6. Uncertain phraseology or meaning

The document contains some phrases and indistinct meanings that should be clarified in further stages of the Plan,

Paragraph 2.6: 'The UPS is being adopted as a supplementary planning document by most district and borough councils in Essex' should be expanded to state whether Rochford itself has adopted the Supplement.

Table 2: 'The surrounding countryside encroaches into the town' should be amended by insertion of 'extends' and deletion of 'encroaches' which implies an unwanted intrusion.

Paragraph 2.13: 'Spar represents an unsympathetic response to West and North Streets' may be better expressed as 'The design of Spar is not sympathetic to the character of West and North Streets'.

Paragraph 2.14: 'Opportunities may exist to stitch the different elements of the town together' should be expanded to clarify the meaning.

Paragraph 2.27: 'Very little information is available on actual parking utilisation of these car parks as they are both pay and display parking facilities'. The lack of information should be rectified given the comments on pressure of parking in Market Square and the possibility of some of the Proposed Site Options resulting in loss or reconfiguration of existing car parking areas. The Area Action Plan should be based on a clear understanding of levels of car park usage

Paragraph 2.33: 'Cycling through Rochford is of a generally acceptable standard' should be expanded to clarify the meaning.

Paragraph 2.34: 'Cycle racks are for persons using retail facilities and station and are therefore not covered' should be expanded to clarify why this is the case and whether any action is required.

Paragraph 2.37: the omission of information for the Express 20 route should be rectified

Table of Main Issues (page 33):
- 'Street Network/ Management' - the statement in the fourth bullet that 'The parking area in Market Square is pressurised' uses odd phraseology.
- 'Bus Service' - the distinction made between 'signs' instead of 'stops' is not clear.

Paragraph 3.3: It is not clear what measures would assist achievement of the suggested support of small and local businesses.

Ordnance Survey acknowledgement is missing from the plans

Thank you for sending the Issues and Options Document to the Government Office.

Detailed comments on paragraphs and proposed policies are appended to this letter. The majority of comments deal with minor issues of an editorial and drafting nature.

Please contact me if you would like to discuss anything contained in this letter or on any aspect of your work with the Local Development Framework.