Introduction

If the purpose of this document is to provide people with the opportunity to consider and comment upon allocation options that have been put forward for development then RDC should ensure that the information provided to people is accurate, unbiased and objective. Without this being the case meaningful public debate is impossible and fine words with regards RDC's commitment to community involvement are just words.
Appendix a details sites that have been considered by RDC and supposedly details how the sites compare in terms of size, location, constraints and viability.
The data contained for the site I submitted is incorrect, biased and unobjective. As follows:
- the boundary of the site is shown incorrectly.
- RDC deems that the site requires "Significant investment in walking/public transport". Although I have sought clarification of what this significant investment is, why it is required and why this comment has specifically associated with my site and not others, RDC has yet to provide any additional information with regards this.
- Likely loss of character of site. Again RDC has yet to provide any further detail with regards this comment but surely the character of any site that is developed will change. Why this comment has been associated with my site and not others also remains a mystery.
- "The site offers minimal contributions to the housing targets and therefore will also offer minimal community benefits". The rationale that has been employed here seems to be that if the site is big it is better. I believe that exactly the opposite is true. Bigger sites result in greater urban sprawl. Bigger sites will only be actioned by large national building companies, not smaller local builders (who are more likely to be residents of RDC after all). Large sites necessitate lots of expensive infrastructure before any home can be built, whilst smaller sites can offer a greater level of reuse of existing infrastructure. Selecting a low number of bigger sites is much easier for RDC planning department to manage (less effort and therefore less RDC planning cost in preparing their plan). However, RDC residents will be paying for this false economy for a very long time.
Despite making attempts (including raising a formal complaint) to get some clarity from RDC with regards their comments on the suitability of my site they have yet to do so. Mr Scrutton has on two occassions authored a response to my requests for clarity but neither of these has provided any further details with regards my site. Instead I have was advised by RDC that the purpose of the consultation period is the right way to raise my concerns. I am of the belief that the community would be better served by RDC ensuring that the information they provide into the public consultation is accurate before they release it.
This has now been escalated to the Local Government Ombudsman who have actioned RDC to respond.
So please beware, do not consider that all you read within the DPD document set is true or unbiased.
One last point, I think that RDC residents should be concerned with regards the level of dilligence and openess of RDC's planning department with regards this matter, and also the unnecessary costs that they have incurred by not providing information to justify their "analysis" of submitted sites.
I am keen to discuss and share experiences of RDC with others who have submitted their sites for "consideration".

Many sites have been dismissed for reasons that are totally unacceptable and illogical. I question who and how the allocation decisions have been made considering how many viable sites have been discounted. It looks as though only sites that can deliver large housing numbers have been accepted - this ultimately results in the unnecessary loss of very valuable green belt. Smaller developments should be encouraged to support local building trades rather than getting in big housing companies who don't care about anything in our communities and villages whatever they say they are only in it for the money!!

Thank you for the opportunity to comment on this document.

However, on this occasion we have no comment to make.

I have been through the whole of this document, and I found it to be depressing reading. It seems that there is the intent to cover large areas of our green belt with developments of various kinds. I cannot agree with such a lot of green belt disappearing, and look forward to voting in the coming elections to reflect these views.

The introduction gives a very false impression of an open process - the call for sites was not widely publicised and probably was only directed at large landowners and developers reflecting Rochford's Council planning bias towards large developers. This bias reflects a desire for administrative convenient as it is easier for staff to deal with one large developer than 100 individual applications.

We have the following general advice relating to allocation sites which should be applied where appropriate:

Flood Risk

PPS25 advocates positive, risk-based planning to avoid the impacts of flood risk and its main aim is to "to ensure that flood risk is taken into account at all stages in the planning process to avoid inappropriate development in areas at risk of flooding, and to direct development away from areas at highest risk".

Ideally the flood risk posed to a Local Authority area should be appraised through the production of a Strategic Flood Risk Assessment (SFRA) and this requirement is set out in Paragraph 25. We acknowledge that the Thames Gateway SFRA was completed in 2006, however this is not PPS25 compliant and does not extensively cover Rochford district. We therefore have no information pertaining to flood risk in your district other than our own flood maps which are based upon the PPS25 definitions of flood zones and are precautionary in that they do not take into account the presence of flood defences. The PPS25 Practice Guide makes it clear (paragraph 3.52) that the suitability of identified sites for housing should be informed by a SFRA and that areas of flood risk should be avoided. Flood risk mitigation measures cannot be considered to overcome flood risk constraints as part of the Strategic Housing Land Availability Assessment.

Our maps also do not map areas of Flood Zone 3b, the functional floodplain, this is something that should be mapped as part of a SFRA (PPS25 Practice Guide, paragraph 4.89). Due to the lack of fluvial flood defences in your district, and in the absence of a SFRA, we would have to take a precautionary approach and assume that all areas of Flood Zone 3, as delineated on our flood maps, are functional floodplain.

A number of the sites included in this DPD are associated with areas of flood risk. A Sequential Test must therefore be carried out in support of this document. For the larger greenfield sites, we believe that no development other than water compatible uses should be accommodated within the areas of flood zone. This would ensure that the integrity of the river corridors is maintained and would provide many benefits to the health and wellbeing of the new community, as well as reflecting government objectives to make space for water. It should be noted that, if all allocations could be made outside of the flood zones delineated by our maps, there might not be a need to carry out a detailed SFRA. Where development has to be allocated within areas of flood risk (as justified through the Sequential Test and the Sustainability Appraisal), a more detailed SFRA would be required to assess the actual level of flood risk posed to sites, and to inform the Exception Test and Emergency Planning as per PPS25. In this instance, the lack of a SFRA would mean that we would have to find the DPD unsound under all three tests of soundness as set out in PPS12.


Surface Water Drainage

High levels of development on greenfield sites will vastly affect the ability of that area to carry out its normal drainage function. In that respect we would expect sustainable drainage to be employed in those areas. The potential for a strategic system serving the whole allocation should be considered. This would provide multiple benefits such as public open space, habitat creation, opportunities for sustainable transport routes and flood risk control.



Water Resources

The Essex Thames Gateway Water Cycle Study Scoping Study (March 2009) identifies that in terms of water resources, Essex and Suffolk Water are currently operating at a demand-supply deficit during dry years and that, although the approval of the Abberton reservoir scheme will largely alleviate these problems in the future, the deficit will remain until this scheme comes online in 2014. The Scoping Report therefore recommends that, as well as seeking high levels of water efficiency in new and existing developments, new development is phased up to 2014. This issue should be considered in future iterations of the Site Allocations DPD. Failing to capture this issue means that we might have to find the DPD unsound under the first and second tests of soundness as set out in PPS12.


Sewerage Infrastructure and Water Quality

The Essex Thames Gateway Water Cycle Study Scoping Study (March 2009) also highlights that there are some potential capacity issues with both the Rochford wastewater treatment works (WwTW) and the sewerage network associated with it which would need resolving around 2015. There might also be some issues with the quality of discharge from the Rayleigh East WwTW which will require further investigation but could be exacerbated by unphased growth.

In terms of water quality, the three WwTWs serving Rochford District - Rochford, Rayleigh East and Rayleigh West - discharge to tributaries of the Rivers Roach and Crouch which are Shellfish Waters and flow into areas designated under national and international environmental legislation (SSSI, SPA and Ramsar designations). The water quality of these watercourses is generally poor and will need improvement under the Water Framework Directive. Page 48 of the Scoping Study states that further development draining to these three WwTWs has the potential to exacerbate the problem. Again further investigation is required into this issue.

It is therefore very likely that a Water Cycle Study will need to be completed in support of your Site Allocations DPD. Without such a study we would have to find the Site Allocations DPD unsound under the first and second tests of soundness as set out in PPS12.


Ecology

We would expect all proposed development sites to protect, enhance, and wherever possible recreate habitats. All opportunities to provide for ecological gain on site should be taken.


Historic Landfill Sites

Some sites lie within 250m of a former landfill site. On the 22nd of June 2007 we sent your Authority a CD containing historic landfill data which has all the information which we hold on these historic landfill sites and this should be consulted for further information.


Waste Management

The government and construction industry have a target to halve waste to landfill by 2012, the management of waste should therefore be considered as early as possible during the property design phase to ensure that minimal volumes of waste arise during the construction of the development, and the demolition at the end of its life. The design of the development can also influence the ability of residents to be able to recycle their waste and we would suggest that designs incorporate facilities to aid in this, especially in multiple-occupancy buildings. We would also suggest that consideration is given to the provision for recycling within public areas.

These matters should be considered as part of the development brief for the sites being allocated as these new developments will provide an important opportunity to reduce waste at the earliest possible stages of design.

Where the development sites will require the preparation of a Site Waste Management Plan in accordance with the Site Waste Management Plan Regulations 2008, please note that we strongly recommend the use of the BRE's SMARTWaste Plan. Please see http://www.smartwaste.co.uk for further information.


Informative

Under the terms of the Water Resources Act 1991, and local byelaws, the prior written consent of the Environment Agency is required for any proposed works or structures, in, under, over or within 9 metres of the top of the bank of a designated 'main river', or the toe of a designated flood defence.

Erection of flow control structures or any culverting of a watercourse requires the prior written approval of the Environment Agency under s.23 of the Land Drainage Act 1991 or s.109 of the Water Resources Act 1991. The Environment Agency resists culverting on nature conservation and other grounds and consent for such works will not normally be granted except for access crossings.

Thank you for consulting The Coal Authority on the above.
Having reviewed your document, I confirm that we have no specific comments to make on
this document at this stage.
We look forward to receiving your emerging planning policy related documents; preferably
in an electronic format. For your information, we can receive documents via our generic
email address planningconsultation@coal.gov.uk, on a CD/DVD, or a simple hyperlink
which is emailed to our generic email address and links to the document on your website.
Alternatively, please mark all paper consultation documents and correspondence for the
attention of the Planning and Local Authority Liaison Department.

Re: Rochford Local Development Framework:
Development Management DPD and Allocations DPD Discussion and Consultation Documents - Regulation 25
I refer to the Council's letter dated 17 March 2010 inviting the East of England Regional Assembly to comment on the above Development Plan Documents.
The Regional Assembly was dissolved on 31 March 2010. As part of the transition to the new regulatory framework, consultations made to the Assembly are being taken forward by a successor body, the East of England Local Government Association, and it is on its behalf that this response has been made.
This letter and the attached reports constitute the East of England LGA's formal response to the above consultation documents. Your attention is drawn to the specific comments made within each report. In particular, the Council is reminded that regional policy requires all local authorities to plan for and make provision for Gypsy and Traveller accommodation needs beyond 2011.
If you have any queries concerning the content of this letter, the attached reports, or with any other issue relating to implementation of the Regional Spatial Strategy, please contact either myself or James Cutting.

1. Introduction
1.1 On 17 March 2010 Rochford District Council wrote to the East of England Regional Assembly to notify them of publication of its Allocation Development Plan Document (DPD) Discussion and Consultation Document under Regulation 25 of the Town and Country Planning (Local Development) (England) (Amendment) Regulations 2008.
1.2 This DPD sets out potential options for the location of new residential and employment development, leisure and community uses, and public open space in order to meet the requirements identified in the Rochford Core Strategy.
1.3 With the enactment of the Local Government, Economic Development and Construction Act 2009 and the Consequential Amendments (SI 2010/602), local planning authorities outside London do not have to make a request seeking the opinion from the Regional Planning Body. Instead, the local planning authority must consult with the Responsible Regional Authority. When acting jointly with the Regional Development Agency (EEDA), The East of England Local Government Association is one of the Responsible Regional Authorities (RRAs) charged with keeping the regional strategy under review. Government guidance2 also directs the RRAs to actively engage with local authorities to promote the implementation of the Regional Strategy.
1.4 The East of England Regional Assembly was dissolved on 31 March 2010 and the requirement to seek its opinion was removed. With the transition to the new regulatory framework, consultations made to the Assembly are being taken forward by the East of England Local Government Association.

1.4 The closing date for comments on this DPD is 30 April 2010. Further details can be found at: http://www.rochford.gov.uk/planning/policy/local_development_framework/allocations_development_plan_d.aspx
2. Background
2.1 The district of Rochford covers an area of 168 sq. km's (65 sq. miles). Situated on a peninsula between the River Thames and River Crouch, it is bounded to the east by the North Sea, shares marine boundaries with Maldon and Chelmsford, and land boundaries with Basildon, Castle Point and Southend. The A127 and A130 provide road links to the M25, and rail services operate into London Liverpool Street. London Southend Airport is located along the southern boundary with Southend Borough.
2.2 The district has a noticeable east-west divide, with the majority of its residents living in the west in the three main urban areas of Rochford, Rayleigh and Hockley. A significant proportion of the workforce, estimated at 68%, works beyond the district boundary, with Southend exerting a particularly strong influence. Approximately 75% of the district is designated as Metropolitan Green Belt.
3. Planning Guidance
3.1 Regional planning guidance for Rochford is set out in the East of England Plan (May 2008) and the remaining saved policies of the Essex & Southend-on-Sea Structure Plan. The former requires Rochford to deliver a minimum 4,600 new homes and contribute 3,000 new jobs (as part of a wider Essex Thames Gateway policy area target of 55,000 new jobs) during the plan period 2001 - 2021.
3.2 Rochford's Core Strategy was submitted to the Secretary of State for approval in January 2010. An Examination in Public is due to commence in May 2010. The Core Strategy, which sets out the strategic spatial planning framework for the district to 2025, was found to be in general conformity with the East of England Plan following discussion of a report presented to the Assembly's Planning Panel Standing Committee in October 2009.
4. Comments
4.1 The East of England LGA recognises that the allocation of sites to meet identified housing, employment, community and environmental needs is ultimately a matter for local determination. To ensure consistency with regional policy objectives, priority should be given to existing brownfield sites and to those sites capable of providing opportunities to deliver high quality, sustainable development.
4.2 As sites come forward for development through the planning system that are at or above agreed regional significance thresholds, further information may be required by the East of England LGA in order to carry out a conformity assessment.
5. Recommendation
5.1 It is recommended that the comments in this report constitute the East of England LGA's formal response to this consultation.

Question
Are references to the East of England Plan correct?

Answer
Yes

Question
Does the area covered by this DPD address any issue that is of strategic or regional importance?

Answer
Yes

Comments
This DPD makes reference to London Southend Airport and its environs.

Question
Does this DPD identify an appropriate range of site options that will enable the delivery of development to meet regional targets for housing and employment growth, allow for the delivery of community and leisure facilities, and the protection of the natural environment?

Comments
The East of England LGA recognises that the allocation of sites to meet identified housing, employment, community and environmental needs is ultimately a matter for local determination. To ensure consistency with regional policy objectives, priority should be given to existing brownfield sites and to those sites capable of providing opportunities to deliver high quality, sustainable development.
The inclusion of site options to meet traveller needs up to 2011 is noted. However, the Council is reminded that adopted regional policy sets out a requirement for pitch provision to be made beyond 2011 and the Council should therefore be planning for the delivery of a further 13 pitches during the plan period 2011 and 2021.

Question
Does the DPD support the implementation of policies in the East of England Plan?

Comment
Yes