Option NLR4

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

This proposed site would have serious consequences for traffic on London Road, Rayleigh. At present queues stretch from the Town Centre back to the Carpenters Arms roundabout from around 4.45 p.m. until 6.30 p.m., and the same in the morning rush hour.
With 550 houses and the extra cars this generates traffic would be at an absolute standstill with access for emergency vehicles anywhere within this area as impossible.
Building on Flood Zone 3 is also a cause for concern.

The A129 & A1245 already suffer congestion, more houses would exacerbate this. There is already a green belt boundary, why build on it? Building so close to a flood zone will only make matters worse.

The A129 & A1245 already suffer congestion, more houses would exacerbate this. There is already a green belt boundary, why build on it? Building so close to a flood zone will only make matters worse.

As for Options NLR1 and 2. With this option, the flood zone could act to split the development, however it could also represent an opportunity to integrate the main river (Rawreth Brook) into the development through the inclusion of public open space etc.

Please see our general comments.

Concerns with the additional traffic, infrastucture and the flood zone. Also the loss of existing recreation ares.

Residential Allocation- Options

North of London Road, Rayleigh. Options NLR1 to NLR5.
Over the past 30 years many of houses have been built off of the London Road corridor, especially off Little Wheatleys Chase and Victoria Road.

All the traffic from those houses had to use London Road, and for the 550 proposed new houses they would also have to use London Road or Rawreth Lane.

Even at current traffic levels it only takes us a few minutes to drive to Thurrock Lakeside as it does to Rayleigh town centre from our home in Alexandria Drive, such is the traffic.

Rayleigh, particularly this part, cannot take more traffic and local services would also be overloaded.


Gypsy and Traveller Sites

I am totally against the option GT3, South of London Road, between Little Wheatleys Chase and St. Johns Drive.

This site is very close to long standing local communities who would worry about the ramifications of it being so near.

History shows us such site soon fall into disrepute and general untidiness which taints the whole area, including the houses in that area causing them to be devalued. This in turn causes resentment towards the dwellers of that site.

This site is stated, could cause community cohesion and integration. Why assume either community wants to integrate?

If yorr are duty bound to provide sites for gipsy's and travellers I believe such sites would be more acceptable if they were located in areas not on top of local existing communities such as GT6 north of the A127 and east of the A1245.

Is it also the case the gipsy's already occupy a site as in Option GT1, to the east of A1245 and south of Rawreth Lane without Planning Permission?

Residential Allocation- Options

North of London Road, Rayleigh. Options NLR1 to NLR5.
Over the past 30 years many of houses have been built off of the London Road corridor, especially off Little Wheatleys Chase and Victoria Road.

All the traffic from those houses had to use London Road, and for the 550 proposed new houses they would also have to use London Road or Rawreth Lane.

Even at current traffic levels it only takes us a few minutes to drive to Thurrock Lakeside as it does to Rayleigh town centre from our home in Alexandria Drive, such is the traffic.

Rayleigh, particularly this part, cannot take more traffic and local services would also be overloaded.


Gypsy and Traveller Sites

I am totally against the option GT3, South of London Road, between Little Wheatleys Chase and St. Johns Drive.

This site is very close to long standing local communities who would worry about the ramifications of it being so near.

History shows us such site soon fall into disrepute and general untidiness which taints the whole area, including the houses in that area causing them to be devalued. This in turn causes resentment towards the dwellers of that site.

This site is stated, could cause community cohesion and integration. Why assume either community wants to integrate?

If your are duty bound to provide sites for gipsy's and travellers I believe such sites would be more acceptable if they were located in areas not on top of local existing communities such as GT6 north of the A127 and east of the A1245.

Is it also the case the gipsy's already occupy a site as in Option GT1, to the east of A1245 and south of Rawreth Lane without Planning Permission?

I object to proposal NLR4 as the propsed development is too large, and will cause the loss of too much agricultural and open space.

Having been advised by District Cllr. C. Black that the RDC will accept representations by email in respect of the above document, I submit my comments and objections.

Section 2. Residential.
North of London Road, Rayleigh 550 dwellings.
Object. In general I object to all of the proposed sites, NLR1 to NLR5, being built on greenbelt land. (See reasons below).

I would also prefer not to have 220 dwellings built on the Rawreth Industrial Estate but as this is a re-use of brown field land, I could reluctantly accept it provided the all five sites, NLR1 to NLR5 are axed from the proposal.
Personally I have no complaints regarding the Rawreth Industrial Estate and see no good reason to remove it. The relocation of a couple of the larger heavy vehicle premises makes sense and moderisation of the site would be preferable to relocation.
I see this as a better proposition which would retain job security and allow for a few new industrial premises and more job opportunities.

I also support the proposal put forward by the Rawreth Parish Council to expand the village and provide circa 250 dwellings on either side of the A1245 road.
Why the RDC and in particular the elected LDF Committee are so opposed to this is beyond belief. It makes far more sense than building on the greenbelt. It is welcomed by the residents and added to the 220 dwellings at the Industrial Estate, if this is chosen, would provide 470 additional dwellings in the parish. This number represents an approximate 125% increase over the existing 373 dwellings at present.

I am also concerned about surface water drainage and run-off. The reason that, as stated, "Consideration must be given to the section of the site to the south, which lies within Flood Zone 3" is that the land falls toward the south of most of the sites. Major development will create large quantities of run-off water and due account of this does not seem to have been taken. The natural course of the water from the sites is toward the River Crouch via the Rawreth Brook. Properties along this valley have been flooded in the past and I feel sure the situation will worsen following any new development.

Now to my objections to Section 2. Residential.

OPTION NLR1 and NLR4 Object
Firstly it further increases and extends all the residential development that has taken place off Rawreth Lane in the past 20 years and will directly add to the coalescence between Rayleigh Town and Rawreth Parish, which RDC have already stated in the Core strategy that they wanted to avoid at any Rochford District location.
Total traffic access to and from Rawreth Lane would add to the congestion that is a regular problem on this road. I also envisage that another traffic light junction would be needed, which added to those we already have will create even more traffic jams.
It appears that the full allocation of 550 dwellings will be added to the 220 proposed for the industrial estate making 770 in total. This figure is approximately the same as those built in the past 20 years off Rawreth Lane and is well in excess of the "Fair Shares For All" policy promised in the Local Development Framework.



OPTION NLR2 Object
My objections are generally the same as NLR1 and NLR4 above.
I do not agree with the vague comment of "Access to this site would be via London Road or the surrounding residential development". This is too open to suggesting that routes through existing housing estates could be used.


OPTION NLR3 Object
Again my main objection is to development on greenbelt and the disproportionate number of dwellings proposed for the Parish of Rawreth.
The location of the site is probably the best of all five but I must object to this in favour of a new proposal to expand the village of Rawreth either side of the A1245.


OPTION NLR5 Object
Jointly with NLR1, these are the most unfavourable. The prospect of joining London Road to Rawreth Lane by one massive development will be a disaster.
I totally disagree with the statement "This location would enable community cohesion due to its location adjacent to existing residential settlement". It is a further example of coalescence between Rayleigh Town and Rawreth Parish which as I have already commented on above.


Section 2 Gypsy and Traveller Sites Object
I do not agree with large Gypsy/Traveller sites as larger communities seem to have greater power over authority and are more inclined to abuse their position by ignoring the law.
I accept that RDC must make provision for Gypsy/Traveller sites but I feel that no site should be larger than six pitches and distributed equally in the East, Central and West areas of the district as represented by the Area Committees.


OPTION GT1 and GT2 Object
As you well know this site has an eviction order on it and I am disgusted that it is even being considered, let alone extended to accommodate more units.
The current occupants have abused their rights and do not relate to 'other developments or village life'. In fact they are considered to be bad neighbours by many of the locals.
They run businesses from the site eg. car sales adjacent the highway, with well in excess of six vehicles a year displayed For Sale. As I understand it, such trading requires them to register the site as a business.
The site access/egress is directly off a dual carriageway 'A' road and is on a fast bend.
Any housing development would be refused by County Highways in such circumstances and the same rules should apply to this Gypsy/Travellers site.

OPTION GT3 Object
Yet another large site with access on to a main road. Also, if Option NLR3 is a chosen site, there will be a similar situation where occupants do not relate with other developments. It is not in their nature.

It is noted that with Options NLR1, NLR2, NLR4 & NLR5 part of the site lies within Flood Zone 3.

The sequential test of PPS25 seeks to direct development to areas at least risk of flooding (Zones 1 & 2). As such land in Zones 1 & 2 should be considered prior to considering residential development on land within Zone 3.

In addition, Options NLR1, & NLR2 would also project a considerable distance from the existing settlement into the Green Belt; as such it would be difficult to create a defensible boundary, contrary to PPG2.

On behalf of Rawreth Parish Council I confirm that this six page letter is a formal response of objection to the Allocations DPD, Discussion and Consultation Document on the following counts:
The overall proposals shown in the ADPD for the Parish of Rawreth amount to overdevelopment within a semi rural Parish with disproportionate allocations in comparison to the remainder of the District and are totally unacceptable and unsustainable under PPG2 and the Council object most strongly to the document as drafted and the proposals therein.

Within the ADPD the Parish of Rawreth has site specific allocations shown for housing, industry and gypsy and traveller sites, whilst other Towns and Parishes within the District appear in the document but are confined to one area of site allocations be it housing, industry or gypsy and traveller sites and on much smaller scales. Overall under the ADPD the Parish of Rawreth stands to take the biggest allocation of houses in one phase, with its overall allocation being only 50 less than that of West Rochford.

Rawreth Parish Council has never been opposed to development within the Parish, however they have always expressed that appropriate amounts of additional housing should be built on smaller, existing and brownfield sites within the greenbelt thus enhancing the lives of new and existing residents instead of eroding our green buffers and starting the coalescence of Rayleigh and Wickford.
Rochford District Council have chosen to totally ignore the alternative proposals put forward by Rawreth Parish Council in the "Call for Sites" document all of which would use previous brownfield sites within the green belt, enhance the centre of Rawreth and avoid the use of so much farmland GB1. Building approximately 200 houses within Rawreth village, with a possibility of more at a later date, would alleviate the need for such a large scale development of 550 houses all in one place. Drainage, traffic and access would all be much enhanced and under our proposal any development would have less impact on the lives of residents within the Parish and neighbouring areas. These proposals however have in the opinion of the Council never been considered or taken seriously.

The area surrounding the Parish of Rawreth is seen as "The Gateway to Rochford" yet under the ADPD the proposals for the land north of London Road NLR1 to NLR5 will take away beautiful, productive, open farmland and turn it into a mix of housing and industry. To build 550 houses on the North/South Eastern area of this land, to legalise and possibly double the Gypsy and Traveller Site on the North Western edge GT1 and to add an Industrial Site on the South Western Corner, which was supposed to be the Green Buffer within NLR1, is absolutely unacceptable and unsustainable under PPG2. To consider placing ANY of these proposals on this area of high quality farmland will absolutely destroy the openness and character of this entire part of Rawreth for ever. In addition the existing roads, A1245, A129, Rawreth Lane and Beeches Road/Watery Lane are already full to capacity and frequently at a standstill, to add more traffic as a result of these proposals is completely unacceptable.

On Thursday the 25th of March 2010 Rawreth Parish Council undertook a 12 hour constant traffic survey in both Rawreth Lane and Beeches Road. In Rawreth Lane during the hours of 7am and 7pm 7,179 vehicles were recorded travelling in an Easterly direction and 7,217 in a Westerly direction, this is a road that does not even have a B classification. In Beeches Road during the hours of 7am to 7pm 2,848 vehicles were recorded travelling in an Easterly direction and 2,022 were recorded travelling in a Westerly, this is a very small, winding rural lane.

The full details of these surveys are attached.

In addition to the above comments the Parish Councils observations, objections and proposals on specific options are as follows:

Land North of London Road. Large scale development here will have massive impact on all local roads- A1245, A129, Rawreth Lane and Beeches Road/Watery Lane. The development will impact highly on drainage and surface water run-off which will cause even more flooding to parts of the Parish which are already classified as being within Flood Zone 3, Watery Lane in particular has been closed twice already this year in February, with motorists needing to be rescued by the Fire Service using boats.

In March this year Cllr Hudson said quite categorically in a local newspaper that all the traffic generating from the proposed sites North of London Road would gain access to and from the A129 and, therefore, would have no effect whatsoever upon Rawreth Lane, this statement is completely contra to the proposals detailed under NLR1, NLR4 and NLR5 where access is quite clearly gained from Rawreth Lane.
NLR1, NLR4 and NLR5, would have massive impact on the traffic in Rawreth Lane and are completely unsustainable and impracticable.

NLR2, NLR3 would have better access in and out of the area as long as correct and adequate roads are put in.

SWH1 States that "sustainable urban drainage systems MUST be implemented" - this is an absolute minimum as the whole area is only just above sea level and subject to possible large scale flooding. Areas within the Parish are already within Flood Zone 3.

All schemes for the Parish of Hullbridge would result in a huge increase in traffic using either Rawreth Lane or Beeches Road/Watery Lane which are both already full to capacity. Watery Lane is a very narrow, winding lane which is frequently closed due to 3 foot deep flooding and any attempt to "straighten " it must also be subject to consideration of the resident Water Vole population which nest within the watercourses and ditches in this area, this is a protected species . No scheme at all should include housing along any part of Watery Lane as in SWH2 and SWH4.

GT1 - The only gypsy and traveller site pinpointed for real consideration is in the Parish of Rawreth , alongside the very busy A1245 dual carriageway. Essex Highways have already objected to this site on the grounds of safe access. It is within 100metres of traffic lights at the junction with Rawreth Lane, with traffic accelerating at this point. To allow access at this point is extremely dangerous.

GT2 - Is even more dangerous as, to double the size of this site to accommodate ALL the pitch requirements for the whole district, would result in even more traffic accessing the site within the area of this busy junction.

GT3, 4 & 5 - could all accommodate some of the pitches and, all have good access to surrounding roads.

GT6 - would have good access and would be able to accommodate all pitches required.

GT7 - Has very restricted access, is an unmade road/track with no mains services. Use of this site would lead to increase in traffic in Rawreth Lane.

In addition to the ADPD gypsy and traveller proposals Rawreth Parish Council put forward a proposal within the "Call for Site" document that land to the North of the A127 and East of the A1245 directly opposite GT6 in a Easterly direction would be very suitable as a Gypsy and Traveller site, this proposal in the opinion of the Council should be reconsidered, the site has the capacity to support the full allocation of required pitches has access to all routes and allows the Traveller community to remain in one area continuing their own community cohesion.

E13, E14, E15 & E16 would all be able to accommodate the relocation of Rawreth Industrial Estate and could fit in fairly well with the already established businesses, Wheatleys Garden Centre, Swallows Fish Centre and the Cafe. They would all provide good access to A1245, A129 and A127, but would initially increase the traffic on the immediate A129 area.

E17 Is most strongly objected to. This is the "green buffer", the land that Rochford District Council have indicated in all the Land to the North of London Road Proposals would be put to green "park" use to establish a barrier to stop houses etc., being built right up to the A1245.

In additional ADPD Industrial Site proposals the Parish Council put forward a proposal within the "Call for Site" document that land to the North of the A127 and West of the A1245 shown in the ADPD document as GT6 would be very suitable as an industrial site if properly designed with security, the site would also adjoin proposed industrial sites within the Basildon District. The site provides excellent road and transport links with its close proximity to all the major routes, the A127, A130 and A13 and adjoining the main Southend to London Liverpool Street railway line. The site is currently under enforcement action for inappropriate use therefore to develop this further as an industrial site would ensure the correct use of what is already semi industrial land thus ensuring the environmental improvement of the site as a whole. This proposal in the opinion of the Council should be reconsidered,
Community Facilities - Education:
Rawreth Parish Council do not agree with allocating land on North of London Road for a new Primary School. This would have a very serious detrimental effect on St Nicholas Primary School, located within less than a mile of this proposal EDU11. St Nicholas has capacity and planning to double the size of the present school but is unable to do this, as all other local Primary Schools have spare capacity and a new school with its enormous incumbent costs is, therefore, not necessary in this location. Education predictions have indicated that there will be spare capacity within the area in the next few years which could result in one of the local schools having to close.

In addition to the ADPD the Council have considered the Development Management DPD Regulations document and comment as follows.

The National Policy on Green Belt PPG2 states "The most important aspect of the Green Belt is its openness". PPG2 states that the purpose of including land with the GB are as follows:

To check the unrestricted sprawl of large built-up areas.
To prevent neighbouring towns from merging into one another.
To assist in safeguarding the countryside from encroachment.
To preserve the setting and special character of historic towns.
To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

The Land North of London Road in its current use complies with all of these points and MUST therefore be retained and preserved as it stands.

The Parish Council looks forward to receiving your acknowledgement of this submission by return.

RE: ALLOCATIONS AND DEVELOPMENT MANAGEMENT DEVELOPMENT PLAN DOCUMENTS



Thank you for giving Anglian Water the opportunity to comment on the above document.



Please find our comments summarized on the attached document.

Regulation 25 - Allocations Development Plan Document

Re; Land West of Rawreth Industrial Estate and South of Rawreth Lane, Rayleigh, Essex

Thank you for your letter dated 17th March 2010 advising me that the Council is seeking
comments on the recently published Regulation 25 Allocations Development Plan Document.

I continue to act for Robin Levy and Lisa Jane Jinks the freehold owners of the land shown
on the accompanying plan, and I would be grateful if the following comments are registered
in respect of the relevant allocation options.

My clients' land extends to approximately 11 acres and is situated immediately adjoining the
existing settlement boundary on the western side of the town of Rayleigh. I have already
made representations proposing the allocation this land for residential and other purposes
and I have considered the latest LPA DPD publication in this light. I reiterate my clients wish
to see their land identified for development in association with adjacent land. I also reiterate
my clients' intention to collaborate fully with adjacent landowners to ensure a smooth and
timely delivery of development if allocated.

I note that there are three proposals in the DPD for the allocation of land north of London
Road, Rayleigh, for housing, a primary school, public park, youth and community facilities,
and play space. These are identified as Options NLR1, NLR2, and NLR3.

Options NLR1, 4 and 5

These appear to be the most practical and efficient options for an allocation to meet the Core Strategy Submission Document 'desire' for 550 dwellings etc. on land to the west of
Rayleigh.

These are the largest of the five option sites and their 'regular' size and shape would enable
an efficient development to be easily planned. For NLR1 and 4 there are no existing land
uses that would be displaced or need to be relocated. My comments in respect of NLR3
concerning the displacement of sports pitches, should be considered in relation to the
potential allocation of NLR5

The extant road access off Rawreth Lane was engineered to accommodate a greater volume of traffic than presently utilises it. Rawreth Lane experiences no traffic flow stress at this point and so would be a sensible access point for new development for options 1, 4 and 5, with good access onto the A129 and A1245. The existing electricity pylons are located close to the western site boundary (or outside it in the case of NLR4 and 5) and can be planned around (i.e. retained within the public park and/or relocated) without constraining the efficient use of the land. With a public park and play space located on the western side of these option sites a strong and defensible Green Belt boundary can be created and a buffer provided to the A1245.

The orientation of these option land areas would mean that they would be ranged along the
existing settlement boundary and would be seen from the principal vantage points to the
west in that context and against the backdrop of the town. Those principal vantage points
would also be farther than equivalents for Option site NLR3. The landscape impacts of
development at NLR1, NLR4 and NLR5 would thus be less than that of Option NLR3, even
taking into account the elevated position of some of the land concerned.

Less vulnerable uses can be accommodated at the southern end of the sites, of which a very
small proportion is at some risk of flooding in an extreme flood event.

Accordingly, my clients would strongly support the allocation of the land identified as
Option NLR1 and NLR4 for residential and associated purposes, closely followed by
NLR5.

Option NLR2

This site includes some of my clients land. Access to the option site could easily be provided by extending the existing public highway leading to the Macro Store southwards. Whilst the option site is bisected by the river along who's banks a risk of flooding exists, the extent of land concerned is small and can be planned around. Access could also be provided through to the adjacent residential estate and thus would improve permeability. In landscape terms, the site would provide a hard urban edge, particularly if public open space is located towards the western side and used to create a buffer to the A1245. This would be defensible in a Green Belt sense in the long term.

My clients therefore support the allocation of the land identified as NLR2 for residential and associated purposes but consider that Option NLR1, 4 and 5 are preferable.

Option NLR3

This option site would be located alongside the London Road, which suffers from significant
traffic flow problems at peak times as a result of commuters leaving and returning to the
town of Rayleigh each morning and evening at 'rush hour'. The creation of a new access to
serve 550 dwellings and associated developments so close to the Carpenter's Arms
roundabout is likely to exacerbate traffic flow issues. I can see no obvious way of
addressing this matter, even with substantial developer contributions utilised to modify the
road layout or alignment in the area.

I also consider that this option site would have the greatest effect upon the landscape
because it would project into the countryside the furthest of the three options. It would be a
linear ribbon-like development with its greatest length projecting into the rural area to the
west of Rayleigh, rather than being oriented along the settlement's western boundary as with
Option Sites 1 and 2. Development of this land would be visible from the A1245 and A129 to
a significant degree on what are two principal approaches to the town of Rayleigh. Land at
NLR3 would be particularly visible for much of the A1245 to the west seen from its elevated
position when facing southwards. From this vantage point the urban extension would not
relate well to the existing settlement boundary and would make the town appear
disproportionately large in the landscape. For these reasons, this option would have the
greatest visual impact and I do not agree that a strong and defensible Green Belt boundary
would be created. I believe that it would in fact lead to pressure to allocate, develop or
otherwise urbanise the land intervening between it and the Carpenter's Arms roundabout to
the west.

In addition, the land is presently occupied by the Lower Barn Farm business complex and by
adjacent sports pitches (at least two football pitches and a cricket pitch) with associated
pavilion/clubhouse and changing facilities. It would be illogical to propose to retain these
sports facilities in situ and site housing development to the west, and if this was to be
proposed then why include the land within the option site. Development of Option NLR3 will
therefore require the loss or at least the reallocation of the existing sports pitches. This
would be in addition to provision of the public park and play space required by the Core
Strategy Submissions Document. Even if replacement pitches can be accommodated
elsewhere within their present 'catchment' it is nevertheless a further 'burden' to the
development and complicates delivery due to the normal requirement to provide
replacement sports facilities before the existing ones are redeveloped. The
relocation/cessation of business units at the Lower Barn Farm may also affect delivery,
although I acknowledge that the long lead-in time would mean that leases can be terminated
and land acquired if necessary. Whilst these constraints are not unassailable they render the
site less attractive in my view than Options NLR1 and NLR2.

For these reasons my clients would object to the allocation of the land identified as
NLR3 for residential and associated purposes due to access, Green Belt, landscape,
design and layout, and delivery issues. Further, my clients consider that Options
NLR1 and 4 are firstly equally preferable, followed by Options NLR5 and 2.

I would be grateful if you would register my clients support and objections as appropriate.
Please do not hesitate to contact me should you wish to discuss any matters relating to the
above.

Objection to housing in Rayleigh and Traveller Sites.
See paper copy for details.

Objections made on housing in Rayleigh and Traveller Sites.
See paper copy for details.

Objection to the housing at North of London Road.
See paper copy for details.