South Canewdon 60 dwellings

We are fast losing all the open spaces in the area.
Canewdon is a small village that is why we have moved to the area, and we would like to see it kept that way.
There would be much higher car usage due to the lack of public transport.
the school is a village school and would surely struggle to cope with 60 more familys.
By more housing in this area you will be soon turning it into a town.
Already one housing estate has already been erected not long back.
We more strongly object to option SC1 as this will be taking away our view

I was shocked last evening to be told of the proposed development in Canewdon, which seems to have been kept under wraps for probably best reasons only known to the council.

The four sites I have been shown all encompass "Green Belt" land belonging to the Stacey and Robinson families respectively.

When the village was originally built in the sixties the number of houses proposed for the village was a great deal less than was actually built for reasons only politicians and council personal would have known about.

With this proposal of at least 60 new properties which would mean up to a possible 90 additional vehicles on the roads, the infrastructure would not cope.We have regular power cuts and have done for the last 30 years there has only been gas here for the last 20 years and the way the gas companies are working at present they are digging up roads for gas repairs on a regular basis.

The condition of the roads around Canewdon cannot cope now especially with the amount of heavy goods traffic using the "Baltic Wharf" at Wallersea and weight limits which a contravened on a regular basis and an dramatic increase of vehicular traffic would damage the roads still further.
After this last winter there are still serious road defects which haven't been repaired yet. The council can't cope with road repairs now so how would they cope with and increase of vehicular traffic then?

From my property I have wonderful view and would not want it destroyed with any further developments within the village, there a post office, a couple of village shops and a couple of public houses. I am quite sure that some of the proposed properties would be housing association properties which is the norm in developments which could introduce further anti social behaviour in the area, we don't have enough Police Officers now to deal with the goings on in the Rochford District so how would they cope with further developments not only in Canewdon but in the rest of the Rochford District.

May I suggest that you reconsider your options and look for "Brown Field" sites and not "Green Belt"

Canewdon has had its fair share of development, but this would be a step too far. CPRE would like to object to any development in this Village highlighting the following:

The area proposed lies in an area of Green Belt, and it is Al agricultural land.
There is very little public transport so the already unsuitable roads will be under even greater pressure
In addition, Canewdons' roads are used recreactionally by many people. Walkers. runners, cyclist and horseriders. It is an area where people from the surrounding areas come to enjoy being in the Countyside and walk the paths, perhaps train for long distance runs etc.

After seeing the publication of documents for the Allocations development plan, The CPC decided to hold an extraordinary meeting on 20th April 2010 & invited members of the RDC planning committee to present their plans to the parishioners of the village for the four proposed sites for development of green belt land to accommodate 60 new dwellings. During the meeting it was very clear that some parishioners had very strong negative feelings towards any plans for development on the green belt, & the CPC agrees with this.

Firstly the Canewdon Parish council would like to make it clear that it has already consulted it's parishioners during a recent parish plan & village survey (February 2010) with regard to what parishioners thoughts were as to whether the village could accommodate any new houses. The result of this survey showed us that.

* 73% replied that no new houses were needed in Canewdon.
* 79% of parishioners also replied that more houses in Canewdon would spoil the environment.

The position of the CPC is that we would strongly object to the development of green belt in the village, for reasons as follows.

* The village is almost unique within the RDC borough in that it is a stand alone community
* It is located within an open rural setting surrounded by green belt productive agricultural land.
* There are natural boundaries to the village by way of the access roads from three directions, & on approaching the village you are presented with a pleasant open rural view.
* Any development of the green belt would spoil this view, not only for those whose enjoyment of the countryside will be spoilt by new houses being built obscuring their view, but also for those who enjoy the village for recreational purposes.

Having considered the options proposed & presented by RDC in the allocation plan and if this development is to be forced upon the parish, we have chosen site SC1 as the most suitable, for reasons as follows.

* The site makes it easily defensible from further development of the green belt as there are natural boundaries to three sides by means of highways, an ancient hedgerow and a ditch border,
* (A condition would be the development of a natural recreational land barrier to the south to prevent further future expansion into the green belt.)
* The site is located to the South East of the village & is better supported in terms of access by highway.
* The site is big enough to accommodate the building of 60 dwellings in a manner where density would not present a sprawl.

We would also request the following points to be taken into consideration.

1. To meet the needs of the community, all new housing should include a suitable mix of 1 & 2 bedroom houses/bungalows to enable parishioners to buy a house to downsize, & also to enable first time buyers the opportunity to live in the village where they may have grown up & now want to purchase their own living accommodation.
2. Affordable properties with some part rent, & part mortgage.
3. All dwellings to have designs which are sympathetic to the rural environment.
4. Properties to be offered to parishioners firstly & then to people from other areas.


Additionally the CPC would like to insist on the following conditions being met before planning consent is granted.

* Upgrade of existing primary school to allow for extra pupils.
* Secondary school catchment schools reviewed with provisions for free home/school transport
* Public transport links improved into Rochord, Hockley, Southend & Rayleigh.
* Promise of a recreational barrier between site SC1 & agricultural green belt
* Full survey & upgrade of existing sewage infrastructure (village already has regular sewage blockages)
* Full survey& upgrade of existing fresh water supply (village already has low water pressure)
* Full survey & upgrade of existing electricity supply (village suffers from low voltage & frequent power cuts in winter months)
* Full survey & upgrade of telecommunication facilities (the village is currently poorly supported by broadband & there is no cable network)
* Funding support for rebuild of the community village hall (the hall is currently too small for the village population & requires a new roof)
* Improvement of the junction at Canewdon road & Ashingdon road to include a mini roundabout to improve road safety & ease congestion when exiting the village at peak times of the day.
* 40 mph speed limits to be introduced along Lark Hill road & Scotts Hall road to improve road safety on entering the village.


Finally, there are also three other new site proposals from parishioners which the CPC support for further investigation by RDC planning officers.

1. Land from the south of the village pond, to the northern border of Gardiners Lane, this plot also boundaries the Canewdon School playing field & the village allotments on the West & to the East is a ditch border to Farm land.
2. Land located to the East of the village hall, which is bordered on the south by Lambourne Hall road & Pylon Cottages to the East.
3. Land to the East of Rosemount in Anchor Lane & to the south of Anchor Lane, adjacent to the junction of Gardiners Lane and East across to the field where the public footpath Number 10.

Our clients have an in principle objection to providing an extension to Canewdon, as Canewdon is classified as a tier 3 settlement in the Core Strategy. It is recognised in the SHLAA as having poor access to public services (only 6 services running Monday - Friday) and poor access to shops. From our research it seems that there is only one primary school, 1 GP surgery, 2 public houses, a gold course and a country club. It is unlikely that an additional 60 houses will be able to fund significant improvements to infrastructure or additional amenities.

Please find attached a representation to the Site Allocations DPD Issues and Options consultation submitted on behalf of Mr Maughan and Mr Lambourn who seek land south of Rayleigh put forward as a site residential site allocation.

SECTION 1: INTRODUCTION

1.1 This Regulation 25 Statement has been produced by Ransome and Company in response to the Rochford District's Council Allocations DPD: Discussion and Consultation document. We act on behalf of Mr Maughan and Mr Lambourn who seek to put forward land south of Rayleigh as a residential site allocation. The site location plan is attached to the statement in Appendix 1. This site is available, achievable and deliverable.

Appendix 1

1.2 Mr Maughan and Mr Lambourn previously submitted separate representations to the 'Call for Sites' consultation and both requested to be contacted on future LDF consultations. It is noted that the Council misrepresented the sites put forward in terms of location and also failed to notify Mr Maughan and Mr Lambourn on the Council's LDF consultations. The Council has consequently been in breach of the Planning Regulations 2004 as amended. This matter is discussed in further detail in Section 2 of this statement.

1.3 This site should be considered alongside 'Land south of Wyburn Primary School' which is put forward as a residential site allocation under a separate cover. The two sites are both highly sustainable and collectively could deliver important benefits to Rayleigh.

1.4 Mr Lambourn has also submitted a separate representation that partially includes some of the land that constitutes 'Land south of Rayleigh'.

1.5 This Regulation 25 Statement puts forward land south of Rayleigh as a site allocation within the Rochford Allocations DPD. This Statement is structured as follows:

Section 2 sets out the procedural matters that the Council has been in breach of during the LDF process.
Section 3 sets out the site context for land south of Rayleigh.
Section 4 describes the proposed site allocation at land south of Rayleigh in the context of the Green Belt.
Section 5 considers the Council's housing land supply.
Section 6 considers the sites the Council has suggested as site allocation options.
Section 7 sets out the overall conclusions of the Statement.

SECTION 2: PROCEDURAL MATTERS

2.1 Mr Maughan and Mr Lambourn submitted separate representations to the Council's 'Call for Sites' consultation in 2007. Both Mr Maughan and Mr Lambourn requested that they be contacted for future LDF consultations. Neither Mr Maughan or Mr Lambourn were informed of the Rochford Core Strategy Pre-Submission consultation and as such were not given the opportunity to make representations on the soundness of the spatial strategy set out in the Core Strategy. By not informing Mr Maughan or Mr Lambourn, the Council are in breach of the Town and Country Planning (Local Development) (England) Regulations 2004 as amended. The Core Strategy is consequently unsound on procedural matters. This matter is discussed in more detail below.

2.2 The Council have also misrepresented the representation submitted by Mr Maughan. This site was not recorded accurately and in fact the wrong site was accredited to Mr Maughan. For a matter of correctness both sites are now to be considered as one site and the site location plan is set in Appendix 1 of this report.

Appendix 1

2.3 In addition, the assessment of Mr Maughan's site wrongly states that this site would affect an existing recreational use and a public right of way. There are no public rights of way over this land and this site is not used for recreational purposes.

2.4 In respect to the procedural breach, Paragraph 24 of the Town and Country Planning (Local Development) (England) Regulations 2004 states that representations may be accompanied by a request to be notified about further LDF consultations and importantly the submission of a DPD to the Core Strategy, a request that was undertaken by both Mr Maughan and Mr Lambourn.

2.5 Paragraph 28 relates to the submission of the DPD. Part (e) of this paragraph states that the Council must give notice to those persons who requested to be notified of the submission of the DPD to the Secretary of State. The Council did not do this as they failed to notify Mr Maughan and Mr Lambourn.

2.6 In addition, as significant landowners with land that adjoins Rayleigh and that they have requested to be notified by the Council, Mr Maughan and Mr Lambourn should be consulted as General Consultation Bodies under the Town and Country Planning (Local Development) (England) Regulations 2004. This point has been clarified in paragraph 25 of the Town and Country Planning (Local Development) (England) Regulations 2008 which states that a local planning authority must notify general consultation bodies who may have an interest in the subject of the proposed DPD. It is also stated that the local planning authority must consider whether it is appropriate to invite representations from persons who are resident and/or carrying out business in their area and invite each of those bodies to make representations to the DPD.

2.7 Paragraph 32 considers the handling of site allocation representations. The Council's 'Call for Sites' consultation constitutes a consultation under the planning regulations. Under part (2) of paragraph 32 it is stated that as soon as reasonably practicable after the consultation period the local planning authority must make a site allocation representation available for inspection. This site allocation must be sent to the DPD bodies and appropriate notifications, as listed in the regulations, must be made. Paragraph 33 states that any person may make representations regarding the site allocation put forward. The Council are in breach of the planning regulations under paragraph 32 and 33 as they have inaccurately recorded the sites and stated false information about the sites put forward by Mr Maughan and Mr Lambourn. Appendix 1 of the the Site Allocations Issues and Options document does not include the site put forward by Mr Maughan and instead considers the adjacent scrap site that Mr Maughan did not include in his representation. The Council has also inaccurately drawn the site boundaries put forward by Mr Maughan. This point has also been clarified under paragraph 30 of the Town and Country Planning (Local Development) (England) Regulations 2008.

SECTION 3: THE PROPOSED SITE AND SURROUNDINGS

3.1 The proposed site extends to 6.4 hectares and is located to the south of the urban area of Rayleigh. This site has the potential to deliver up to approximately 190 market and affordable dwellings. The proposed main access into the site would be from Eastwood Road with a secondary access from South View Road.

3.2 The proposed site is located just 1 mile from Rayleigh town centre and 1.4 miles from Rayleigh Train Station which provides convenient public transport connections to Southend-on-Sea, Stratford and London Liverpool Street. A number of bus routes operate along Eastwood Road, with a bus stop adjacent to the proposed access. This provides good and convenient public transport accessibility to Rayleigh Town Centre and Rayleigh Train Station.

3.3 The site is well located to the main centres of employment in Rayleigh being located in close proximity to the town centre but is also just 800 metres by foot from Brook Street Industrial Estate or approximately 1.5 miles by bike or car.

3.4 The site adjoins the urban edge of Rayleigh to the south. The site abuts the rear boundary line of the dwellings located along South View Road and Eastwood Road.

3.5 The boundaries of the proposed site ensure that this site is enclosed. The eastern boundary is characterised by a mature wooded area that prevents views into the site and would also create a natural and defensible boundary for a future development. The southern boundary also has a mature tree line edge that screens the site from the A127 carriageway. The proposed site is located adjacent to an established small commercial site at its south-western boundary. The remainder of the western boundary is also characterised by a mature tree and hedge line. The site is enclosed by the mature landscaping along its boundary which prevents views into the site and provides natural screening.

3.6 The southern part of the proposed site is currently used for non-commercial grazing whilst the northern part has no function. The site has no beneficial agricultural function and no viable equestrian function.

3.7 There are no public footpaths or rights of way that cross this site and the site has no recreational value.

3.8 The proposed site is connected to existing utilities infrastructure.

3.9 The proposed site would be accessed from Eastwood Road.

SECTION 4: THE GREEN BELT

4.1 The site on land south of Rayleigh is currently designated as Green Belt in the Rochford Local Plan. It is considered that this designation is no longer relevant to this site. This matter is discussed in more detail below.

4.2 Very special circumstances to outweigh harm by reason of inappropriateness, and any other harm to the Green Belt needs to be demonstrated for development on Green Belt land. Paragraph 1.4 of PPG2 outlines the intentions of Green Belt planning policy and states that the most important attribute of Green Belt is its openness.

4.3 Appendix 1 of this statement provides an illustrative demonstration of the enclosed nature of this site. It is clear that this site is enclosed and that there is a very limited degree of openness and as such this site does not fulfil the requirements of PPG2. The proposed site does not have any public footpaths running through it and is enclosed by the adjacent urban area of Rayleigh and the dense wooded area to the south, east and west. There are no views across the site from a public viewpoint.

4.4 The boundaries of the proposed site on land south of Rayleigh would create a more permanent or robust defensible boundary for the Green Belt at this location. The eastern and western boundary of the site contains a mature thick wooded area that provides a defensible boundary. The southern boundary is characterised by a mature landscaping with A127 carriageway running adjacent to the boundary. This road and the existing mature landscaping provides defensible boundary to the south.

4.5 Paragraph 1.5 of PPG2 lists the five purposes of the Green Belt:

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

4.6 With reference to point 1 above, the proposed site is located adjacent to the southern edge of Rayleigh. A scrapyard is located adjacent to the site on the south-eastern boundary. This site constitutes a previously developed site within the Green Belt and provides an urban setting to the proposed site on land south of Rayleigh. It is considered that the containment of the site by the A127 carriageway and the mature landscaping along the boundary are important characteristics which ensure that development of the site would not represent unrestricted urban sprawl.

4.7 In defining Green Belt boundaries, PPG2 advises that such boundaries should be clearly defined, using readily recognisable features, such as roads and tree lines. It is considered that because the proposed site is enclosed by the mature landscaping on the eastern and western boundary and by the A127 carriageway, the site would have a robust and defensible boundary to the Green Belt, were residential development to be allocated at this site. The allocation of the proposed site for residential development would not make adjacent Green Belt land vulnerable to development.

4.8 Point 2 above states that the Green Belt will prevent neighbouring towns from merging into one another. With reference to the second purpose, a distance of 0.25 miles separates Rayleigh and Southend-on-Sea at the closest point. The eastern edge of this proposed site is 0.5 miles from the boundary of Southend-on-Sea and would not bring Rayleigh any closer to Southend-on-Sea. Furthermore, the dense and mature landscaping along the proposed sites eastern boundary provides a robust barrier which prevents Rayleigh and Southend-on-Sea from ever merging.

4.9 Point 3 requires the Green Belt to assist in safeguarding the countryside from encroachment. The enclosed nature of the site would prevent encroachment. The loss of this site is essential for Council to meet its housing minimum housing targets.

4.10 Point 4 requires the preservation of the setting and special character of historic towns. The historic core of Rayleigh is centred along the High Street. Historically, Rayleigh has developed by building on open land to that surrounds the town centre, particularly in the post war years, such that the original historic core is surrounded by more modern development. In these circumstances, the application site does not perform a function in preserving the setting of the historic centre of Rayleigh.

4.11 Point 5 states that the Green Belt is required to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. This point is not applicable in this instance given the need for a release of Green Belt in Rochford District to meet housing targets.

4.12 Therefore it is considered that the site does not perform any of the Green Belt functions set out in PPG2. If the site were to be allocated for residential, the unrestricted sprawl of built-up area of Rayleigh would not follow, nor would Rayleigh and Southend-on-Sea merge. The mature wooded area to the east of the proposed site together with the mature landscaping along the boundary edge and the A127 carriageway to the south would act as a clear and defensible Green Belt boundary and development on the site would not encourage or justify further encroachment into open countryside.

SECTION 5: ROCHFORD'S HOUSING LAND SUPPLY

5.1 This section provides a brief overview of land supply in Rochford with a focus upon the national planning policy, Rochford Core Strategy Submission document and Rochford's Strategic Housing Land Availability Assessment (SHLAA).
a) National Planning Policy Context

5.2 Paragraph 2 of PPS3 states that a principal aim of this policy document is to create a step-change in housing delivery, through a new, more responsive approach to land supply at the local level. Paragraph 7 states that Local Planning Authorities will need to identify and maintain a rolling five-year supply of deliverable land for housing, particularly in connection with making planning decisions.

5.3 Paragraph 11 states that policies in development plan documents should be evidence-based and land availability should be assessed through a Strategic Housing Land Availability Assessment. In respect to the five-year supply, paragraph 54 states that Local Planning Authorities should identify sufficient specific deliverable sites to deliver housing in the first five years. It is stated that for sites to be considered deliverable, sites should:
Be Available - the site is available now.
Be Suitable - the site offers a suitable location for development now and would contribute to the creation of sustainable, mixed communities.
Be Achievable - there is a reasonable prospect that housing will be delivered on the site within five years.

5.4 Paragraph 55 states that Local Planning Authorities should also identify a further supply of specific, developable sites for years 6-10 and, where possible, for years 11-15. Strategic sites which are critical to the delivery of the housing strategy over the plan period should also be identified. Paragraph 56 states that to be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available for, and could be developed at the point envisaged.

5.5 Annex C of PPS3 provides further information on the evidence base required as part of the Strategic Housing Land Availability Assessments. It is stated that a Strategic Housing Land Availability Assessment should:
Assess the likely level of housing that could be provided if unimplemented planning permissions were brought into development.
Assess land availability by identifying buildings or areas of land (including previously developed land and greenfield) that have development potential for housing, including within mixed use developments.
Assess the potential level of housing that can be provided on identified land.
Where appropriate, evaluate past trends in windfall land coming forward for development and estimate the likely future implementation rate.
Identify constraints that might make a particular site unavailable and/or unviable for development.
Identify sustainability issues and physical constraints that might make a site unsuitable for development.
Identify what action could be taken to overcome constraints on particular sites.
b) Rochford's Core Strategy Submission Document

5.6 The East of England Plan requires a minimum of 4,600 dwellings to be provided in the District between 2001 and 2021. In addition, the Local Planning Authority is required to plan for delivery of housing for at least 15 years from the date of adoption of the Core Strategy. Therefore housing needs to be identified for the period to 2024.

5.7 The 2009 Strategic Housing Land Availability Assessment (SHLAA) examined the supply of housing land and, although identified some capacity from extant permissions and other appropriate sites, also ascertained that Green Belt would have to be reallocated in order to meet the requirements of the East of England Plan. It is stated that 2,745 dwellings are required on Green Belt land between 2006 and 2024. This is in addition to the 2,005 dwellings to be delivered on previously developed land.

5.8 The Core Strategy sets out the general locations for housing development. The Council state that the primary factors in determining the location of future housing include current infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency; opportunities to utilise brownfield land; community needs and physical constraints; need to protect areas of landscape value, ecological importance and high quality agricultural land. The Council states that it seeks balance the distribution of housing by focusing growth upon the higher tier settlements.

5.9 The population of Rochford District is unevenly distributed with the largest settlement being Rayleigh which, in 2001, was home to 30,196 people, 38% of the District's residents. As such the Council identified Rayleigh as a primary tier settlement as it contains a range services and facilities including good public transport accessibility. The Core Strategy however notes that their housing needs evidence indicates that 44% of the housing need in the borough originates from Rayleigh. This provides a strong basis in which to focus housing development upon Rayleigh.

5.10 Despite what is said in the Core Strategy, it is clear that Council has failed to consider a balanced approach to housing delivery. However the Council's proposed housing locations do not reflect this statement as the scattered approach around the district will deliver housing away from public transport and key services and will lead to unsustainable patterns of growth. The Council's own evidence states that 44% of the need for housing is focused on Rayleigh, yet Rayleigh will only deliver 19% of housing on Green Belt sites. Indeed 57% of the Green Belt housing site allocations is focused outside the primary tier settlements. This will result in increased car movements between the settlements and will have an unsustainable impact upon the existing infrastructure.

5.11 There is a need for the Council to identify and significant increase in the housing provision for Rayleigh to meet the socio-economic objectives set out in the Rochford Core Strategy Submission draft.

c) Rochford's Housing Land supply (2001 to 2024)

5.12 The Council's SHLAA noted that there is an inadequate housing supply in the district over a fifteen year period to 2024 and as such there is a requirement for the allocation of Green Belt land for residential development. The SHLAA identifies a requirement to allocate 2,477 dwellings on Green Belt land in the period to 2024.

5.13 The Rochford Annual Monitoring Report (AMR) 2008 to 2009 demonstrates that Rochford has failed to deliver 309 dwellings of the required 1,840 between 2001 and 2009. The Council's SHLAA also suggests that 1,658 dwellings will be delivered between 2009 and 2014/15. The Council will also have to deliver 3,759 dwellings between 2009 and 2024.

5.14 It is considered that the land supply assessments used to indicate how these targets will be delivered is not based on a robust assessment and consequently it is clear that the Council cannot meet its housing supply requirements and that a significant dwelling shortfall will develop which will have significant implications for the future delivery of housing in Rochford.

5.15 It is considered that the Council's SHLAA and AMR do not provide an accurate assessment of the strategic housing land supply in Rochford and that in fact the future housing supply situation is worse than recorded. It is considered that the Council's SHLAA fails to take to account of:
Current housing market conditions in Rochford;
The time duration of the planning process i.e. from pre-application to completion;
The build out rates of housing sites; and
Site specific constraints.

5.16 The Council is unable to demonstrate a robust up-to-date five year supply of deliverable sites. The failure of the AMR to take account of these key matters is discussed below.

5.17 Rochford's annual East of England Plan housing supply requirement is to deliver 230 dwellings per annum. Between 2001 and 2009 this figure was met and exceeded on just two occasions, in 2005/06 and 2006/07. During this period Rochford was required to deliver 1,840 dwellings to meet the East of England housing supply requirement however just 1,531 dwellings were completed, resulting in a housing completion shortfall of 309 dwellings or a housing under-supply of 1.34 years.

5.18 The Council's housing trajectory set out in AMR states that over the next 5 years, annual housing per year will exceed 218 dwellings per annum. This level of growth is optimistic and does not reflect market trends in Rochford. It is a forlorn hope that housing supply could match its pre-credit crunch delivery rates over the five years given that during the pre-credit crunch years prior to 2007/08 Rochford was only able exceed its annual target on just two occasions. The Council has not provided any information that can justify how the housing market will be able to absorb the increased housing delivery that exceeds historical delivery records during a period when financial credit was more readily available.

5.19 The Council initiated a consultation titled 'Call for Sites', asking landowners and developers to put forward sites for consideration. This exercise was undertaken between January 2007 and April 2009. The Council's SHLAA states that these sites were assessed for their availability, suitability and achievability. However the land south of Rayleigh was not assessed and therefore it is clear that the Council is misleading in its assessment.

5.20 The SHLAA states that there is capacity within the District to accommodate 1,273 dwellings between 2009 and 2024 from outstanding planning permissions and other appropriate brownfield sites. This leaves an outstanding balance of 2,477 dwellings to be built by 2024 on land which is currently allocated as Green Belt.

5.22 The Council's SHLAA document and its AMR have failed to take account market factors that affect the delivery housing when consider housing supply to 2024. In particular the Council has not taken account the time delays caused by the planning system and the ability of the housebuilding industry to build out sites.

5.23 The Callcutt Review of Housebuilding Delivery (2007) was commissioned by the Secretary of State for Communities and Local Government to asses housing land supply in the UK. In consideration of timing from planning application submission to project completion, the Calcutt Review it was considered that the average time taken between planning application submission to construction completion is as follows:
Schemes of 15 to 49 units - 35.3 months
Schemes of 50 to 149 units - 39.4 months
Schemes of 150+ units - 44.6 months

5.24 This assessment does not include pre-application preparatory work which is cited in the Callcutt Review as taking 15.4 months on average for all schemes and 25.1 months for schemes of 150+ units.

5.25 The AMR and the SHLAA also do not make an accurate assessment of build out rates for specific sites and it is apparent that these documents do not understand the market forces that dictate the build-out rates. It is clear that in their assessment the Council has used an arbitrary figure that is not based on substantiated evidence. The 'Housing Markets and Planning Analysis Expert Panel - Factors Affecting Housing Build-out Rates: A report by Professor David Adams and Dr Chris Leishman' (the Housing Build-Out Rate Report) sought to determine the speed at which approved housing sites are developed.

5.26 Paragraph 2.4 of this report states that the research results suggest that the average optimal sales rate is about 59 units per annum for greenfield houses and 67 for brownfield apartments. Paragraph 2.5 states that most builders generally appear to set a target of between 40 and 80 units built and sold from each outlet annually. Paragraph 6.2 states that a typical strategy of most companies was to aim for a build and sales rate of about one unit per week on greenfield sites and slightly higher than this on brownfield sites and that this rate reflects the institutional structure of the British housebuilding industry in which fierce competition for land requires controlled and phased release of new development to ensure that the ambitious development values necessary to capture land in the first place are actually achieved when new homes are eventually sold.

5.27 Whilst the SHLAA has only recently been published, it is considered that it is not robust as the site assessment has not sufficiently taken into consideration the deliverability of sites as there is no technical evidence that demonstrates an understanding of the relationship between local housing markets and housing supply.

5.28 The AMR and SHLAA assessment of sites are optimistic and simplistic in their assessment of construction start dates and build-out rates. The housing land supply in Rochford is in fact worse than that set out in the AMR and SHLAA documents. Based on the assumptions using well founded national research it is clear that the Council has over estimated to the delivery of at least three sites identified within their SHLLAA and AMR. These sites are addressed below:
North London Road - The Council's AMR states that construction will start at this site in 2016/17 and that 550 dwellings will be delivered by 2019/20. The Council's projected delivery rate exceeds that cited by Government research. Assuming that the start date is correct it likely that site would take up to 9 years to deliver with 60 dwellings delivered per annum. At least 120 dwellings would be delivered in the period post 2024.
West Rochford - The Council's AMR states that construction will start at this site in 2012 and that 600 dwellings will be delivered by 2016/17. The Council project that 200 dwellings will be delivered in 2013/14 and that build out rates exceed 100 in four of the five years. This assumption is unrealistic and does not take account of the ability of the construction industry to deliver new dwellings. The start date is optimistic as it takes at least 2-years on large sites exceeding 150 dwellings from planning to start date. The first dwellings that would be completed, assuming a planning application is submitted in 2010, in 2013. Given the current stage of this DPD consultation it is unlikely that this site have a start date pre-2016. It is also highly optimistic that 600 dwellings would be delivered within 5-years as stated by the Council. Government research indicates that it would take up to 10 years to deliver this site. It is likely that the majority of this site will be delivered at the end of the 15-year period and that at least 120 dwellings will be delivered post 2024.
South West Hullbridge - The Council's AMR states that construction will start at this site in 2019/20 and that 250 dwellings will be delivered by 2021 and a further 250 dwellings to be delivered post 2021. If the start date is correct then this site will only be able to deliver 120 dwellings by 2021 and 260 dwellings post 2024.

5.29 The housing supply over estimation amounts to at least 500 dwellings or an undersupply of over 2-years of housing. It is clear therefore that Council needs to identify more housing sites. It is necessary for the Council to allocate more residential sites to ensure that sufficient sites are available to meet the minimum housing requirements set out in the East of England Plan.

SECTION 6: THE COUNCIL'S PROPOSED OPTIONS

6.1 This section considers the options for residential development put forward by the Council in the Site Allocations Issues and Options consultation. The comments in respect to these sites are follows:
a) North of London Road, Rayleigh

6.2 My clients support the principle of a release of Green Belt land in Rayleigh to support residential development to meet the East of England Plan requirements however my clients objects to Options NLR1, NLR2, NLR3, NLR4 and NLR5.

6.3 This site is characterised by its open undulating landscaping that makes it a visually prominent site at the edge of Rayleigh. This site has a number of constraints such as the pylons that cross the site and part of the site being within a flood zone. The removal of the pylons to allow residential development will be a costly undertaking that would reduce the potential community benefits that the Council seeks from this site.

6.4 Furthermore the site conflicts with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Rayleigh in a visually prominent location.
The open nature of this location will set the precedent for further development to take place to the west of Rayleigh. This will create the risk of materially reducing the gap between Wickford and Rayleigh. Consideration should be given to recent development to the east of Wickford as gap between the settlements is eroding.
This location constitutes good quality agricultural arable land that is characterised by its undulating form. Development at this location would prevent the safeguarding of the countryside from encroachment.

6.5 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside and consequently there are no easily defined boundaries. The built edge of Rayleigh would be very prominent from the Green Belt at this location.

b) West Rochford

6.6 My clients do not object to the principle of a release of Green Belt land at Rochford to support residential development to meet the East of England Plan requirements however my clients object to identification of land west of Rochford and Options WR1, WR2, WR3 and WR4 as a suitable option.

6.7 This site is characterised by open agricultural land that forms the gateway into Rochford from Hockley and Hawkwell. Neither of the options would be appropriate and constitutes urban sprawl that conflicts with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:

The development of this site will result in the unrestricted sprawl of Rochford in a visually prominent location that links Hockley, Hawkwell, Rochford and Southend-on-Sea.
The proposed options will result in the development of land that provides an important gap that prevents the coalescence of Rochford with Hawkwell and Southend-on-Sea.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.8 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

c) South Hawkwell

6.9 My clients object to the principle of a release of Green Belt land at Hawkwell as development at this location will result in unrestricted development that threatens to create a sense of coalescence with Rochford, particularly given that the Council proposes development to the west of Rochford. Consequently my client objects to Options SH1, SH2, SH3 and SH4 as a suitable option for residential development.

6.10 This site is characterised by its wooded character that provides an important green lung for this part of Essex. Each of the proposed options will result in the destruction of an important wooded area. It is considered that this location cannot support the quantum of development suggested within the Issues and Options consultation document.

d) East Ashingdon

6.11 My clients object to the principle of a release of Green Belt land at Ashingdon and all the proposed options as this location is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh, the primary settlement in Rochford District.

6.12 Each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.13 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.14 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

e) South West Hullbridge

6.15 My clients object to the principle of a release of Green Belt land at Hullbridge as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District and development at Hullbridge would fail to meet the housing need that exists in Rayleigh. The quantum of development at this location is broadly similar to that proposed for Rayleigh, however the Council's own evidence demonstrates that 44% of the identified housing need in the borough comes from Rayleigh. The Hullbridge options therefore constitute a mismatch between location and the need and demand for housing. My clients consequently object to options SWH1, SWH2, SWH3 and SWH4.

6.16 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Hullbridge at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.17 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.18 This Green Belt location is also constrained by its location in proximity to the River Croach and the impact of flooding.

6.19 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

f) South Canewdon

6.20 My clients object to the principle of a release of Green Belt land at Canewdon as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District. My clients consequently object to options SC1, SC2, SC3 and SC4.

6.21 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Canewdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.22 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.23 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

g) South East Ashingdon

6.24 My clients object to the principle of a release of Green Belt land at Ashingdon as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed and that development at this location would have a detrimental impact the character of the countryside. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District. My clients consequently object to Options SEA1, SEA2, SEA3 and SEA4.

6.25 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.26 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.27 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

h) West Great Wakering

6.28 My clients object to the principle of a release of Green Belt land at Great Wakering as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed and that development at this location and that the proposed quantum of development is disproportionate when considered against the size of the settlements in Rochford District and against the locations of identified housing need. West Great Wakering is remote from the rest of the district and has poor transport links. Residential development at the quantum proposed would result in a significant increase in the number car trips in this part of South East Essex, My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District which has the greatest proportion of identified need and has good public transport access. My clients consequently object to options WGW1, WGW2, WGW3, WGW4 and WGW5.

6.29 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.30 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.31 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

SECTION 7: CONCLUSIONS

7.1 We request that land south of Rayleigh be allocated as a residential site within the Site Allocations DPD. This statement has demonstrated that:
1. The proposed site is well located to Rayleigh and would meet the Council's housing objectives and will assist in delivering housing to meet the Council's identified housing need in Rayleigh.
2. The proposed site would not conflict with the Green Belt objectives set out in PPG2.
3. The Council has under-estimated the amount of housing required on Green Belt sites to meet the districts housing requirements and consequently the Council needs to identify more housing locations and sites.
4. The Council's proposed residential sites are inappropriate as they constitute sites that conflict with PPG2 and the dispersed nature of these sites would result in unsustainable development away from public transport and key services that will lead to significant increases in car movements. Furthermore these sites would not assist in relieving the housing need in Rayleigh as identified by the Council.

Please find attached a representation to the Site Allocations DPD Issues and Options consultation submitted on behalf of Mr Maughan and Mr Lambourn who seek land south of Rayleigh put forward as a site residential site allocation.

SECTION 1: INTRODUCTION

1.1 This Regulation 25 Statement has been produced by Ransome and Company in response to the Rochford District's Council Allocations DPD: Discussion and Consultation document. We act on behalf of Mr Maughan and Mr Lambourn who seek to put forward land south of Rayleigh as a residential site allocation. The site location plan is attached to the statement in Appendix 1. This site is available, achievable and deliverable.

Appendix 1

1.2 Mr Maughan and Mr Lambourn previously submitted separate representations to the 'Call for Sites' consultation and both requested to be contacted on future LDF consultations. It is noted that the Council misrepresented the sites put forward in terms of location and also failed to notify Mr Maughan and Mr Lambourn on the Council's LDF consultations. The Council has consequently been in breach of the Planning Regulations 2004 as amended. This matter is discussed in further detail in Section 2 of this statement.

1.3 This site should be considered alongside 'Land south of Wyburn Primary School' which is put forward as a residential site allocation under a separate cover. The two sites are both highly sustainable and collectively could deliver important benefits to Rayleigh.

1.4 Mr Lambourn has also submitted a separate representation that partially includes some of the land that constitutes 'Land south of Rayleigh'.

1.5 This Regulation 25 Statement puts forward land south of Rayleigh as a site allocation within the Rochford Allocations DPD. This Statement is structured as follows:

Section 2 sets out the procedural matters that the Council has been in breach of during the LDF process.
Section 3 sets out the site context for land south of Rayleigh.
Section 4 describes the proposed site allocation at land south of Rayleigh in the context of the Green Belt.
Section 5 considers the Council's housing land supply.
Section 6 considers the sites the Council has suggested as site allocation options.
Section 7 sets out the overall conclusions of the Statement.

SECTION 2: PROCEDURAL MATTERS

2.1 Mr Maughan and Mr Lambourn submitted separate representations to the Council's 'Call for Sites' consultation in 2007. Both Mr Maughan and Mr Lambourn requested that they be contacted for future LDF consultations. Neither Mr Maughan or Mr Lambourn were informed of the Rochford Core Strategy Pre-Submission consultation and as such were not given the opportunity to make representations on the soundness of the spatial strategy set out in the Core Strategy. By not informing Mr Maughan or Mr Lambourn, the Council are in breach of the Town and Country Planning (Local Development) (England) Regulations 2004 as amended. The Core Strategy is consequently unsound on procedural matters. This matter is discussed in more detail below.

2.2 The Council have also misrepresented the representation submitted by Mr Maughan. This site was not recorded accurately and in fact the wrong site was accredited to Mr Maughan. For a matter of correctness both sites are now to be considered as one site and the site location plan is set in Appendix 1 of this report.

Appendix 1

2.3 In addition, the assessment of Mr Maughan's site wrongly states that this site would affect an existing recreational use and a public right of way. There are no public rights of way over this land and this site is not used for recreational purposes.

2.4 In respect to the procedural breach, Paragraph 24 of the Town and Country Planning (Local Development) (England) Regulations 2004 states that representations may be accompanied by a request to be notified about further LDF consultations and importantly the submission of a DPD to the Core Strategy, a request that was undertaken by both Mr Maughan and Mr Lambourn.

2.5 Paragraph 28 relates to the submission of the DPD. Part (e) of this paragraph states that the Council must give notice to those persons who requested to be notified of the submission of the DPD to the Secretary of State. The Council did not do this as they failed to notify Mr Maughan and Mr Lambourn.

2.6 In addition, as significant landowners with land that adjoins Rayleigh and that they have requested to be notified by the Council, Mr Maughan and Mr Lambourn should be consulted as General Consultation Bodies under the Town and Country Planning (Local Development) (England) Regulations 2004. This point has been clarified in paragraph 25 of the Town and Country Planning (Local Development) (England) Regulations 2008 which states that a local planning authority must notify general consultation bodies who may have an interest in the subject of the proposed DPD. It is also stated that the local planning authority must consider whether it is appropriate to invite representations from persons who are resident and/or carrying out business in their area and invite each of those bodies to make representations to the DPD.

2.7 Paragraph 32 considers the handling of site allocation representations. The Council's 'Call for Sites' consultation constitutes a consultation under the planning regulations. Under part (2) of paragraph 32 it is stated that as soon as reasonably practicable after the consultation period the local planning authority must make a site allocation representation available for inspection. This site allocation must be sent to the DPD bodies and appropriate notifications, as listed in the regulations, must be made. Paragraph 33 states that any person may make representations regarding the site allocation put forward. The Council are in breach of the planning regulations under paragraph 32 and 33 as they have inaccurately recorded the sites and stated false information about the sites put forward by Mr Maughan and Mr Lambourn. Appendix 1 of the the Site Allocations Issues and Options document does not include the site put forward by Mr Maughan and instead considers the adjacent scrap site that Mr Maughan did not include in his representation. The Council has also inaccurately drawn the site boundaries put forward by Mr Maughan. This point has also been clarified under paragraph 30 of the Town and Country Planning (Local Development) (England) Regulations 2008.

SECTION 3: THE PROPOSED SITE AND SURROUNDINGS

3.1 The proposed site extends to 6.4 hectares and is located to the south of the urban area of Rayleigh. This site has the potential to deliver up to approximately 190 market and affordable dwellings. The proposed main access into the site would be from Eastwood Road with a secondary access from South View Road.

3.2 The proposed site is located just 1 mile from Rayleigh town centre and 1.4 miles from Rayleigh Train Station which provides convenient public transport connections to Southend-on-Sea, Stratford and London Liverpool Street. A number of bus routes operate along Eastwood Road, with a bus stop adjacent to the proposed access. This provides good and convenient public transport accessibility to Rayleigh Town Centre and Rayleigh Train Station.

3.3 The site is well located to the main centres of employment in Rayleigh being located in close proximity to the town centre but is also just 800 metres by foot from Brook Street Industrial Estate or approximately 1.5 miles by bike or car.

3.4 The site adjoins the urban edge of Rayleigh to the south. The site abuts the rear boundary line of the dwellings located along South View Road and Eastwood Road.

3.5 The boundaries of the proposed site ensure that this site is enclosed. The eastern boundary is characterised by a mature wooded area that prevents views into the site and would also create a natural and defensible boundary for a future development. The southern boundary also has a mature tree line edge that screens the site from the A127 carriageway. The proposed site is located adjacent to an established small commercial site at its south-western boundary. The remainder of the western boundary is also characterised by a mature tree and hedge line. The site is enclosed by the mature landscaping along its boundary which prevents views into the site and provides natural screening.

3.6 The southern part of the proposed site is currently used for non-commercial grazing whilst the northern part has no function. The site has no beneficial agricultural function and no viable equestrian function.

3.7 There are no public footpaths or rights of way that cross this site and the site has no recreational value.

3.8 The proposed site is connected to existing utilities infrastructure.

3.9 The proposed site would be accessed from Eastwood Road.

SECTION 4: THE GREEN BELT

4.1 The site on land south of Rayleigh is currently designated as Green Belt in the Rochford Local Plan. It is considered that this designation is no longer relevant to this site. This matter is discussed in more detail below.

4.2 Very special circumstances to outweigh harm by reason of inappropriateness, and any other harm to the Green Belt needs to be demonstrated for development on Green Belt land. Paragraph 1.4 of PPG2 outlines the intentions of Green Belt planning policy and states that the most important attribute of Green Belt is its openness.

4.3 Appendix 1 of this statement provides an illustrative demonstration of the enclosed nature of this site. It is clear that this site is enclosed and that there is a very limited degree of openness and as such this site does not fulfil the requirements of PPG2. The proposed site does not have any public footpaths running through it and is enclosed by the adjacent urban area of Rayleigh and the dense wooded area to the south, east and west. There are no views across the site from a public viewpoint.

4.4 The boundaries of the proposed site on land south of Rayleigh would create a more permanent or robust defensible boundary for the Green Belt at this location. The eastern and western boundary of the site contains a mature thick wooded area that provides a defensible boundary. The southern boundary is characterised by a mature landscaping with A127 carriageway running adjacent to the boundary. This road and the existing mature landscaping provides defensible boundary to the south.

4.5 Paragraph 1.5 of PPG2 lists the five purposes of the Green Belt:

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

4.6 With reference to point 1 above, the proposed site is located adjacent to the southern edge of Rayleigh. A scrapyard is located adjacent to the site on the south-eastern boundary. This site constitutes a previously developed site within the Green Belt and provides an urban setting to the proposed site on land south of Rayleigh. It is considered that the containment of the site by the A127 carriageway and the mature landscaping along the boundary are important characteristics which ensure that development of the site would not represent unrestricted urban sprawl.

4.7 In defining Green Belt boundaries, PPG2 advises that such boundaries should be clearly defined, using readily recognisable features, such as roads and tree lines. It is considered that because the proposed site is enclosed by the mature landscaping on the eastern and western boundary and by the A127 carriageway, the site would have a robust and defensible boundary to the Green Belt, were residential development to be allocated at this site. The allocation of the proposed site for residential development would not make adjacent Green Belt land vulnerable to development.

4.8 Point 2 above states that the Green Belt will prevent neighbouring towns from merging into one another. With reference to the second purpose, a distance of 0.25 miles separates Rayleigh and Southend-on-Sea at the closest point. The eastern edge of this proposed site is 0.5 miles from the boundary of Southend-on-Sea and would not bring Rayleigh any closer to Southend-on-Sea. Furthermore, the dense and mature landscaping along the proposed sites eastern boundary provides a robust barrier which prevents Rayleigh and Southend-on-Sea from ever merging.

4.9 Point 3 requires the Green Belt to assist in safeguarding the countryside from encroachment. The enclosed nature of the site would prevent encroachment. The loss of this site is essential for Council to meet its housing minimum housing targets.

4.10 Point 4 requires the preservation of the setting and special character of historic towns. The historic core of Rayleigh is centred along the High Street. Historically, Rayleigh has developed by building on open land to that surrounds the town centre, particularly in the post war years, such that the original historic core is surrounded by more modern development. In these circumstances, the application site does not perform a function in preserving the setting of the historic centre of Rayleigh.

4.11 Point 5 states that the Green Belt is required to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. This point is not applicable in this instance given the need for a release of Green Belt in Rochford District to meet housing targets.

4.12 Therefore it is considered that the site does not perform any of the Green Belt functions set out in PPG2. If the site were to be allocated for residential, the unrestricted sprawl of built-up area of Rayleigh would not follow, nor would Rayleigh and Southend-on-Sea merge. The mature wooded area to the east of the proposed site together with the mature landscaping along the boundary edge and the A127 carriageway to the south would act as a clear and defensible Green Belt boundary and development on the site would not encourage or justify further encroachment into open countryside.

SECTION 5: ROCHFORD'S HOUSING LAND SUPPLY

5.1 This section provides a brief overview of land supply in Rochford with a focus upon the national planning policy, Rochford Core Strategy Submission document and Rochford's Strategic Housing Land Availability Assessment (SHLAA).
a) National Planning Policy Context

5.2 Paragraph 2 of PPS3 states that a principal aim of this policy document is to create a step-change in housing delivery, through a new, more responsive approach to land supply at the local level. Paragraph 7 states that Local Planning Authorities will need to identify and maintain a rolling five-year supply of deliverable land for housing, particularly in connection with making planning decisions.

5.3 Paragraph 11 states that policies in development plan documents should be evidence-based and land availability should be assessed through a Strategic Housing Land Availability Assessment. In respect to the five-year supply, paragraph 54 states that Local Planning Authorities should identify sufficient specific deliverable sites to deliver housing in the first five years. It is stated that for sites to be considered deliverable, sites should:
Be Available - the site is available now.
Be Suitable - the site offers a suitable location for development now and would contribute to the creation of sustainable, mixed communities.
Be Achievable - there is a reasonable prospect that housing will be delivered on the site within five years.

5.4 Paragraph 55 states that Local Planning Authorities should also identify a further supply of specific, developable sites for years 6-10 and, where possible, for years 11-15. Strategic sites which are critical to the delivery of the housing strategy over the plan period should also be identified. Paragraph 56 states that to be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available for, and could be developed at the point envisaged.

5.5 Annex C of PPS3 provides further information on the evidence base required as part of the Strategic Housing Land Availability Assessments. It is stated that a Strategic Housing Land Availability Assessment should:
Assess the likely level of housing that could be provided if unimplemented planning permissions were brought into development.
Assess land availability by identifying buildings or areas of land (including previously developed land and greenfield) that have development potential for housing, including within mixed use developments.
Assess the potential level of housing that can be provided on identified land.
Where appropriate, evaluate past trends in windfall land coming forward for development and estimate the likely future implementation rate.
Identify constraints that might make a particular site unavailable and/or unviable for development.
Identify sustainability issues and physical constraints that might make a site unsuitable for development.
Identify what action could be taken to overcome constraints on particular sites.
b) Rochford's Core Strategy Submission Document

5.6 The East of England Plan requires a minimum of 4,600 dwellings to be provided in the District between 2001 and 2021. In addition, the Local Planning Authority is required to plan for delivery of housing for at least 15 years from the date of adoption of the Core Strategy. Therefore housing needs to be identified for the period to 2024.

5.7 The 2009 Strategic Housing Land Availability Assessment (SHLAA) examined the supply of housing land and, although identified some capacity from extant permissions and other appropriate sites, also ascertained that Green Belt would have to be reallocated in order to meet the requirements of the East of England Plan. It is stated that 2,745 dwellings are required on Green Belt land between 2006 and 2024. This is in addition to the 2,005 dwellings to be delivered on previously developed land.

5.8 The Core Strategy sets out the general locations for housing development. The Council state that the primary factors in determining the location of future housing include current infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency; opportunities to utilise brownfield land; community needs and physical constraints; need to protect areas of landscape value, ecological importance and high quality agricultural land. The Council states that it seeks balance the distribution of housing by focusing growth upon the higher tier settlements.

5.9 The population of Rochford District is unevenly distributed with the largest settlement being Rayleigh which, in 2001, was home to 30,196 people, 38% of the District's residents. As such the Council identified Rayleigh as a primary tier settlement as it contains a range services and facilities including good public transport accessibility. The Core Strategy however notes that their housing needs evidence indicates that 44% of the housing need in the borough originates from Rayleigh. This provides a strong basis in which to focus housing development upon Rayleigh.

5.10 Despite what is said in the Core Strategy, it is clear that Council has failed to consider a balanced approach to housing delivery. However the Council's proposed housing locations do not reflect this statement as the scattered approach around the district will deliver housing away from public transport and key services and will lead to unsustainable patterns of growth. The Council's own evidence states that 44% of the need for housing is focused on Rayleigh, yet Rayleigh will only deliver 19% of housing on Green Belt sites. Indeed 57% of the Green Belt housing site allocations is focused outside the primary tier settlements. This will result in increased car movements between the settlements and will have an unsustainable impact upon the existing infrastructure.

5.11 There is a need for the Council to identify and significant increase in the housing provision for Rayleigh to meet the socio-economic objectives set out in the Rochford Core Strategy Submission draft.

c) Rochford's Housing Land supply (2001 to 2024)

5.12 The Council's SHLAA noted that there is an inadequate housing supply in the district over a fifteen year period to 2024 and as such there is a requirement for the allocation of Green Belt land for residential development. The SHLAA identifies a requirement to allocate 2,477 dwellings on Green Belt land in the period to 2024.

5.13 The Rochford Annual Monitoring Report (AMR) 2008 to 2009 demonstrates that Rochford has failed to deliver 309 dwellings of the required 1,840 between 2001 and 2009. The Council's SHLAA also suggests that 1,658 dwellings will be delivered between 2009 and 2014/15. The Council will also have to deliver 3,759 dwellings between 2009 and 2024.

5.14 It is considered that the land supply assessments used to indicate how these targets will be delivered is not based on a robust assessment and consequently it is clear that the Council cannot meet its housing supply requirements and that a significant dwelling shortfall will develop which will have significant implications for the future delivery of housing in Rochford.

5.15 It is considered that the Council's SHLAA and AMR do not provide an accurate assessment of the strategic housing land supply in Rochford and that in fact the future housing supply situation is worse than recorded. It is considered that the Council's SHLAA fails to take to account of:
Current housing market conditions in Rochford;
The time duration of the planning process i.e. from pre-application to completion;
The build out rates of housing sites; and
Site specific constraints.

5.16 The Council is unable to demonstrate a robust up-to-date five year supply of deliverable sites. The failure of the AMR to take account of these key matters is discussed below.

5.17 Rochford's annual East of England Plan housing supply requirement is to deliver 230 dwellings per annum. Between 2001 and 2009 this figure was met and exceeded on just two occasions, in 2005/06 and 2006/07. During this period Rochford was required to deliver 1,840 dwellings to meet the East of England housing supply requirement however just 1,531 dwellings were completed, resulting in a housing completion shortfall of 309 dwellings or a housing under-supply of 1.34 years.

5.18 The Council's housing trajectory set out in AMR states that over the next 5 years, annual housing per year will exceed 218 dwellings per annum. This level of growth is optimistic and does not reflect market trends in Rochford. It is a forlorn hope that housing supply could match its pre-credit crunch delivery rates over the five years given that during the pre-credit crunch years prior to 2007/08 Rochford was only able exceed its annual target on just two occasions. The Council has not provided any information that can justify how the housing market will be able to absorb the increased housing delivery that exceeds historical delivery records during a period when financial credit was more readily available.

5.19 The Council initiated a consultation titled 'Call for Sites', asking landowners and developers to put forward sites for consideration. This exercise was undertaken between January 2007 and April 2009. The Council's SHLAA states that these sites were assessed for their availability, suitability and achievability. However the land south of Rayleigh was not assessed and therefore it is clear that the Council is misleading in its assessment.

5.20 The SHLAA states that there is capacity within the District to accommodate 1,273 dwellings between 2009 and 2024 from outstanding planning permissions and other appropriate brownfield sites. This leaves an outstanding balance of 2,477 dwellings to be built by 2024 on land which is currently allocated as Green Belt.

5.22 The Council's SHLAA document and its AMR have failed to take account market factors that affect the delivery housing when consider housing supply to 2024. In particular the Council has not taken account the time delays caused by the planning system and the ability of the housebuilding industry to build out sites.

5.23 The Callcutt Review of Housebuilding Delivery (2007) was commissioned by the Secretary of State for Communities and Local Government to asses housing land supply in the UK. In consideration of timing from planning application submission to project completion, the Calcutt Review it was considered that the average time taken between planning application submission to construction completion is as follows:
Schemes of 15 to 49 units - 35.3 months
Schemes of 50 to 149 units - 39.4 months
Schemes of 150+ units - 44.6 months

5.24 This assessment does not include pre-application preparatory work which is cited in the Callcutt Review as taking 15.4 months on average for all schemes and 25.1 months for schemes of 150+ units.

5.25 The AMR and the SHLAA also do not make an accurate assessment of build out rates for specific sites and it is apparent that these documents do not understand the market forces that dictate the build-out rates. It is clear that in their assessment the Council has used an arbitrary figure that is not based on substantiated evidence. The 'Housing Markets and Planning Analysis Expert Panel - Factors Affecting Housing Build-out Rates: A report by Professor David Adams and Dr Chris Leishman' (the Housing Build-Out Rate Report) sought to determine the speed at which approved housing sites are developed.

5.26 Paragraph 2.4 of this report states that the research results suggest that the average optimal sales rate is about 59 units per annum for greenfield houses and 67 for brownfield apartments. Paragraph 2.5 states that most builders generally appear to set a target of between 40 and 80 units built and sold from each outlet annually. Paragraph 6.2 states that a typical strategy of most companies was to aim for a build and sales rate of about one unit per week on greenfield sites and slightly higher than this on brownfield sites and that this rate reflects the institutional structure of the British housebuilding industry in which fierce competition for land requires controlled and phased release of new development to ensure that the ambitious development values necessary to capture land in the first place are actually achieved when new homes are eventually sold.

5.27 Whilst the SHLAA has only recently been published, it is considered that it is not robust as the site assessment has not sufficiently taken into consideration the deliverability of sites as there is no technical evidence that demonstrates an understanding of the relationship between local housing markets and housing supply.

5.28 The AMR and SHLAA assessment of sites are optimistic and simplistic in their assessment of construction start dates and build-out rates. The housing land supply in Rochford is in fact worse than that set out in the AMR and SHLAA documents. Based on the assumptions using well founded national research it is clear that the Council has over estimated to the delivery of at least three sites identified within their SHLLAA and AMR. These sites are addressed below:
North London Road - The Council's AMR states that construction will start at this site in 2016/17 and that 550 dwellings will be delivered by 2019/20. The Council's projected delivery rate exceeds that cited by Government research. Assuming that the start date is correct it likely that site would take up to 9 years to deliver with 60 dwellings delivered per annum. At least 120 dwellings would be delivered in the period post 2024.
West Rochford - The Council's AMR states that construction will start at this site in 2012 and that 600 dwellings will be delivered by 2016/17. The Council project that 200 dwellings will be delivered in 2013/14 and that build out rates exceed 100 in four of the five years. This assumption is unrealistic and does not take account of the ability of the construction industry to deliver new dwellings. The start date is optimistic as it takes at least 2-years on large sites exceeding 150 dwellings from planning to start date. The first dwellings that would be completed, assuming a planning application is submitted in 2010, in 2013. Given the current stage of this DPD consultation it is unlikely that this site have a start date pre-2016. It is also highly optimistic that 600 dwellings would be delivered within 5-years as stated by the Council. Government research indicates that it would take up to 10 years to deliver this site. It is likely that the majority of this site will be delivered at the end of the 15-year period and that at least 120 dwellings will be delivered post 2024.
South West Hullbridge - The Council's AMR states that construction will start at this site in 2019/20 and that 250 dwellings will be delivered by 2021 and a further 250 dwellings to be delivered post 2021. If the start date is correct then this site will only be able to deliver 120 dwellings by 2021 and 260 dwellings post 2024.

5.29 The housing supply over estimation amounts to at least 500 dwellings or an undersupply of over 2-years of housing. It is clear therefore that Council needs to identify more housing sites. It is necessary for the Council to allocate more residential sites to ensure that sufficient sites are available to meet the minimum housing requirements set out in the East of England Plan.

SECTION 6: THE COUNCIL'S PROPOSED OPTIONS

6.1 This section considers the options for residential development put forward by the Council in the Site Allocations Issues and Options consultation. The comments in respect to these sites are follows:
a) North of London Road, Rayleigh

6.2 My clients support the principle of a release of Green Belt land in Rayleigh to support residential development to meet the East of England Plan requirements however my clients objects to Options NLR1, NLR2, NLR3, NLR4 and NLR5.

6.3 This site is characterised by its open undulating landscaping that makes it a visually prominent site at the edge of Rayleigh. This site has a number of constraints such as the pylons that cross the site and part of the site being within a flood zone. The removal of the pylons to allow residential development will be a costly undertaking that would reduce the potential community benefits that the Council seeks from this site.

6.4 Furthermore the site conflicts with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Rayleigh in a visually prominent location.
The open nature of this location will set the precedent for further development to take place to the west of Rayleigh. This will create the risk of materially reducing the gap between Wickford and Rayleigh. Consideration should be given to recent development to the east of Wickford as gap between the settlements is eroding.
This location constitutes good quality agricultural arable land that is characterised by its undulating form. Development at this location would prevent the safeguarding of the countryside from encroachment.

6.5 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside and consequently there are no easily defined boundaries. The built edge of Rayleigh would be very prominent from the Green Belt at this location.

b) West Rochford

6.6 My clients do not object to the principle of a release of Green Belt land at Rochford to support residential development to meet the East of England Plan requirements however my clients object to identification of land west of Rochford and Options WR1, WR2, WR3 and WR4 as a suitable option.

6.7 This site is characterised by open agricultural land that forms the gateway into Rochford from Hockley and Hawkwell. Neither of the options would be appropriate and constitutes urban sprawl that conflicts with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:

The development of this site will result in the unrestricted sprawl of Rochford in a visually prominent location that links Hockley, Hawkwell, Rochford and Southend-on-Sea.
The proposed options will result in the development of land that provides an important gap that prevents the coalescence of Rochford with Hawkwell and Southend-on-Sea.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.8 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

c) South Hawkwell

6.9 My clients object to the principle of a release of Green Belt land at Hawkwell as development at this location will result in unrestricted development that threatens to create a sense of coalescence with Rochford, particularly given that the Council proposes development to the west of Rochford. Consequently my client objects to Options SH1, SH2, SH3 and SH4 as a suitable option for residential development.

6.10 This site is characterised by its wooded character that provides an important green lung for this part of Essex. Each of the proposed options will result in the destruction of an important wooded area. It is considered that this location cannot support the quantum of development suggested within the Issues and Options consultation document.

d) East Ashingdon

6.11 My clients object to the principle of a release of Green Belt land at Ashingdon and all the proposed options as this location is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh, the primary settlement in Rochford District.

6.12 Each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.13 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.14 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

e) South West Hullbridge

6.15 My clients object to the principle of a release of Green Belt land at Hullbridge as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District and development at Hullbridge would fail to meet the housing need that exists in Rayleigh. The quantum of development at this location is broadly similar to that proposed for Rayleigh, however the Council's own evidence demonstrates that 44% of the identified housing need in the borough comes from Rayleigh. The Hullbridge options therefore constitute a mismatch between location and the need and demand for housing. My clients consequently object to options SWH1, SWH2, SWH3 and SWH4.

6.16 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Hullbridge at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.17 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.18 This Green Belt location is also constrained by its location in proximity to the River Croach and the impact of flooding.

6.19 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

f) South Canewdon

6.20 My clients object to the principle of a release of Green Belt land at Canewdon as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District. My clients consequently object to options SC1, SC2, SC3 and SC4.

6.21 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Canewdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.22 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.23 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

g) South East Ashingdon

6.24 My clients object to the principle of a release of Green Belt land at Ashingdon as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed and that development at this location would have a detrimental impact the character of the countryside. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District. My clients consequently object to Options SEA1, SEA2, SEA3 and SEA4.

6.25 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.26 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.27 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

h) West Great Wakering

6.28 My clients object to the principle of a release of Green Belt land at Great Wakering as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed and that development at this location and that the proposed quantum of development is disproportionate when considered against the size of the settlements in Rochford District and against the locations of identified housing need. West Great Wakering is remote from the rest of the district and has poor transport links. Residential development at the quantum proposed would result in a significant increase in the number car trips in this part of South East Essex, My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District which has the greatest proportion of identified need and has good public transport access. My clients consequently object to options WGW1, WGW2, WGW3, WGW4 and WGW5.

6.29 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.30 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.31 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

SECTION 7: CONCLUSIONS

7.1 We request that land south of Rayleigh be allocated as a residential site within the Site Allocations DPD. This statement has demonstrated that:
1. The proposed site is well located to Rayleigh and would meet the Council's housing objectives and will assist in delivering housing to meet the Council's identified housing need in Rayleigh.
2. The proposed site would not conflict with the Green Belt objectives set out in PPG2.
3. The Council has under-estimated the amount of housing required on Green Belt sites to meet the districts housing requirements and consequently the Council needs to identify more housing locations and sites.
4. The Council's proposed residential sites are inappropriate as they constitute sites that conflict with PPG2 and the dispersed nature of these sites would result in unsustainable development away from public transport and key services that will lead to significant increases in car movements. Furthermore these sites would not assist in relieving the housing need in Rayleigh as identified by the Council.

SECTION 1: INTRODUCTION

1.1 This Regulation 25 Statement has been produced by Ransome and Company in response to the Rochford District's Council Allocations DPD: Discussion and Consultation document. We act on behalf of Mrs M. Bingley of 259 Daws Heath Road and Mr H. Johnson of 287 Daws Heath Road who seek to put forward land south of Wyburns Primary School, Rayleigh as a residential site allocation. The site location plan is attached to the statement in Appendix 1. This site is available, achievable and deliverable.

Appendix 1

1.2 Mrs M. Bingley and Mr H. Johnson previously submitted representations to the 'Call for Sites' consultation and requested to be contacted on future LDF consultations. It is noted that the Council misrepresented the sites put forward in terms of location and also failed to notify Mrs M. Bingley and Mr H. Johnson on the Council's LDF consultations. The Council has consequently been in breach of the Planning Regulations 2004 as amended. This matter is discussed in further detail in Section 2 of this statement.

1.3 This site should be considered alongside 'Land south of Rayleigh' which is put forward as a residential site allocation under a separate cover. The two sites are both highly sustainable and collectively could deliver important benefits to Rayleigh.

1.4 This Regulation 25 Statement puts forward land south of Wyburns Primary School as a site allocation within the Rochford Allocations DPD. This Statement is structured as follows:
Section 2 sets out the procedural matters that the Council has been in breach of during the LDF process.
Section 3 sets out the site context for land south of Rayleigh.
Section 4 describes the proposed site allocation at land south of Rayleigh in the context of the Green Belt.
Section 5 considers the Council's housing land supply.
Section 6 considers the sites the Council has suggested as site allocation options.
Section 7 sets out the overall conclusions of the Statement.

SECTION 2: PROCEDURAL MATTERS

2.1 Mrs M. Bingley and Mr H. Johnson submitted separate representations to the Council's 'Call for Sites' consultation in 2007. Both Mrs M. Bingley and Mr H. Johnson requested that they be contacted for future LDF consultations. Neither Mrs M. Bingley and Mr H. Johnson were informed of the Rochford Core Strategy Pre-Submission consultation and as such were not given the opportunity to make representations on the soundness of the spatial strategy set out in the Core Strategy. By not informing Mrs M. Bingley and Mr H. Johnson, the Council are in breach of the Town and Country Planning (Local Development) (England) Regulations 2004 as amended. The Core Strategy is consequently unsound on procedural matters. This matter is discussed in more detail below.

2.2 The Council have also misrepresented the representations submitted by Mrs M. Bingley and Mr H. Johnson. The two sites put forward as site allocations were not recorded accurately and in fact the wrong site was accredited to Mrs M. Bingley. For a matter of correctness both sites are now to be considered as one site and the site location plan is set in Appendix 1 of this report.

2.3 In respect to the procedural breach, Paragraph 24 of the Town and Country Planning (Local Development) (England) Regulations 2004 states that representations may be accompanied by a request to be notified about further LDF consultations and importantly the submission of a DPD to the Core Strategy, a request that was undertaken by both Mrs M. Bingley and Mr H. Johnson.
2.4 Paragraph 28 relates to the submission of the DPD. Part (e) of this paragraph states that the Council must give notice to those persons who requested to be notified of the submission of the DPD to the Secretary of State. The Council did not do this as they failed to notify Mrs M. Bingley and Mr H. Johnson.

2.5 In addition, as significant landowners with land that adjoins Rayleigh and that they have requested to be notified by the Council, Mrs M. Bingley and Mr H. Johnson should have been consulted as General Consultation Bodies under the Town and Country Planning (Local Development) (England) Regulations 2004. This point has been clarified in paragraph 25 of the Town and Country Planning (Local Development) (England) Regulations 2008 which states that a local planning authority must notify general consultation bodies who may have an interest in the subject of the proposed DPD. It is also stated that the local planning authority must consider whether it is appropriate to invite representations from persons who are resident and/or carrying out business in their area and invite each of those bodies to make representations to the DPD.

2.6 Paragraph 32 considers the handling of site allocation representations. The Council's 'Call for Sites' consultation constitutes a consultation under the planning regulations. Under part (2) of paragraph 32 it is stated that as soon as reasonably practicable after the consultation period the local planning authority must make a site allocation representation available for inspection. This site allocation must be sent to the DPD bodies and appropriate notifications, as listed in the regulations, must be made. Paragraph 33 states that any person may make representations regarding the site allocation put forward. The Council are in breach of the planning regulations under paragraph 32 and 33 as they have inaccurately recorded the sites about the sites put forward by Mrs M. Bingley and Mr H. Johnson.

SECTION 3: THE PROPOSED SITE AND SURROUNDINGS

3.1 The proposed site extends to 2.3 hectares and is located to the south of the urban area of Rayleigh. This site has the potential to deliver up to approximately 95 market and affordable dwellings. The proposed main access into the site would be from Daws Heath Road.

3.2 The proposed site is located just 0.9 miles from Rayleigh town centre and 1.4 miles from Rayleigh Train Station which provides convenient public transport connections to Southend-on-Sea, Stratford and London Liverpool Street.

3.3 The site is well located to the main centres of employment in Rayleigh being located in close proximity to the town centre and less than a mile by foot and car from Brook Street Industrial Estate.

3.4 The site adjoins the urban edge of Rayleigh to the south and east. The site abuts the rear boundary of Wyburns Primary School.

3.5 The boundaries of the proposed site ensure that this site is enclosed. The eastern boundary is characterised by a mature wooded area that prevents views into the site and would also create a natural and defensible boundary for a future development. The southern boundary adjoins Daws Heath Road, a road which is characterised by mature trees and hedgerows. The western and northern boundary is also characterised by a mature tree and hedge line. The site is enclosed by the mature landscaping along its boundary which prevents views into the site and provides natural screening.

3.6 The proposed site is currently used for residential purposes. The site has no beneficial agricultural function and no viable equestrian function.

3.7 There are no public footpaths or rights of way that cross this site and the site has no recreational value.

SECTION 4: THE GREEN BELT

4.1 The site on land south of Wyburns Primary School is currently designated as Green Belt in the Rochford Local Plan. It is considered that this designation is no longer relevant to this site. This matter is discussed in more detail below.

4.2 Very special circumstances to outweigh harm by reason of inappropriateness, and "any other harm" to the Green Belt needs to be demonstrated for development on Green Belt land. Paragraph 1.4 of PPG2 outlines the intentions of Green Belt planning policy and states that the most important attribute of Green Belt is its openness.

4.3 Appendix 1 of this statement provides an illustrative assessment of the level openness on land south of Rayleigh It is clear that this site is enclosed and that there is a very limited degree of openness and as such this site does not fulfil the requirements of PPG2. The proposed site does not have any public footpaths running through it and is enclosed by the adjacent Wyburns Primary School and the mature landscaping along the perimeter. There are no significant views across the site from a public viewpoint.

4.4 The boundaries of the proposed site on land south of Wyburns School would create a more permanent or robust defensible boundary for the Green Belt at this location. The eastern, northern and western boundary of the site contains a mature tree and hedge line that provides a defensible boundary. The southern boundary is characterised by Daws Heath Road. This road and the existing mature landscaping provides defensible boundary to the south.

4.5 Paragraph 1.5 of PPG2 lists five purposes of including land in Green Belts:
1. To check the unrestricted sprawl of large built-up areas;
2. To prevent neighbouring towns from merging into one another;
3. To assist in safeguarding the countryside from encroachment;
4. To preserve the setting and special character of historic towns; and
5. To assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

4.6 With reference to point 1 above, the proposed site is located adjacent to the southern edge of Rayleigh and adjoins Wyburns Primary School. It is considered that the containment of the site by Daws Heath Road and the mature landscaping along the boundary are important characteristics which ensure that development of the site would not represent unrestricted urban sprawl.

4.7 In defining Green Belt boundaries, PPG2 advises that such boundaries should be clearly defined, using readily recognisable features, such as roads and tree lines. It is considered that because the proposed site is enclosed by the mature landscaping, the site would have a robust and defensible boundary to the Green Belt, were residential development to be allocated at this site. The allocation of the proposed site for residential development would not make adjacent Green Belt land vulnerable to development.

4.8 Point 2 above states that the Green Belt will prevent neighbouring towns from merging into one another. With reference to the second purpose, a distance of 0.25 miles separates Rayleigh and Southend-on-Sea at the closest point. The eastern edge of this proposed site is 0.7 miles from the boundary of Southend-on-Sea and would not bring Rayleigh any closer to Southend-on-Sea. Furthermore, the dense and mature landscaping along the proposed sites eastern boundary together with the dense wooded areas between Southend and Rayleigh provides a robust barrier which prevents Rayleigh and Southend-on-Sea from ever merging.

4.9 Point 3 requires the Green Belt to assist in safeguarding the countryside from encroachment. The enclosed nature of the site would prevent encroachment. The loss of this site is essential for Council to meet its housing minimum housing targets.

4.10 Point 4 requires the preservation of the setting and special character of historic towns. The historic core of Rayleigh is centred along the High Street. Historically, Rayleigh has developed by building on open land to that surrounds the town centre, particularly in the post war years, such that the original historic core is surrounded by more modern development. In these circumstances, the application site does not perform a function in preserving the setting of the historic centre of Rayleigh.

4.11 Point 5 states that the Green Belt is required to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. This point is not applicable in this instance given the need for a release of Green Belt in Rochford District to meet housing targets.

4.12 Therefore it is considered that the site does not perform any of the Green Belt functions set out in PPG2. If the site were to be allocated for residential, the unrestricted sprawl of built-up area of Rayleigh would not follow, nor would Rayleigh and Southend-on-Sea merge. The mature wooded area to the east of the proposed site together with the mature landscaping along the boundary edge and the A127 carriageway to the south would act as a clear and defensible Green Belt boundary and development on the site would not encourage or justify further encroachment into open countryside.

SECTION 5: ROCHFORD'S HOUSING LAND SUPPLY

5.1 This section provides a brief overview of land supply in Rochford with a focus upon the national planning policy, Rochford Core Strategy Submission document and Rochford's Strategic Housing Land Availability Assessment (SHLAA).

a) National Planning Policy Context

5.2 Paragraph 2 of PPS3 states that a principal aim of this policy document is to create a step-change in housing delivery, through a new, more responsive approach to land supply at the local level. Paragraph 7 states that Local Planning Authorities will need to identify and maintain a rolling five-year supply of deliverable land for housing, particularly in connection with making planning decisions.

5.3 Paragraph 11 states that policies in development plan documents should be evidence-based and land availability should be assessed through a Strategic Housing Land Availability Assessment. In respect to the five-year supply, paragraph 54 states that Local Planning Authorities should identify sufficient specific deliverable sites to deliver housing in the first five years. It is stated that for sites to be considered deliverable, sites should:
Be Available - the site is available now.
Be Suitable - the site offers a suitable location for development now and would contribute to the creation of sustainable, mixed communities.
Be Achievable - there is a reasonable prospect that housing will be delivered on the site within five years.

5.4 Paragraph 55 states that Local Planning Authorities should also identify a further supply of specific, developable sites for years 6-10 and, where possible, for years 11-15. Strategic sites which are critical to the delivery of the housing strategy over the plan period should also be identified. Paragraph 56 states that to be considered developable, sites should be in a suitable location for housing development and there should be a reasonable prospect that the site is available for, and could be developed at the point envisaged.

5.5 Annex C of PPS3 provides further information on the evidence base required as part of the Strategic Housing Land Availability Assessments. It is stated that a Strategic Housing Land Availability Assessment should:
Assess the likely level of housing that could be provided if unimplemented planning permissions were brought into development.
Assess land availability by identifying buildings or areas of land (including previously developed land and greenfield) that have development potential for housing, including within mixed use developments.
Assess the potential level of housing that can be provided on identified land.
Where appropriate, evaluate past trends in windfall land coming forward for development and estimate the likely future implementation rate.
Identify constraints that might make a particular site unavailable and/or unviable for development.
Identify sustainability issues and physical constraints that might make a site unsuitable for development.
Identify what action could be taken to overcome constraints on particular sites.

b) Rochford's Core Strategy Submission Document

5.6 The East of England Plan requires a minimum of 4,600 dwellings to be provided in the District between 2001 and 2021. In addition, the Local Planning Authority is required to plan for delivery of housing for at least 15 years from the date of adoption of the Core Strategy. Therefore housing needs to be identified for the period to 2024.

5.7 The 2009 Strategic Housing Land Availability Assessment (SHLAA) examined the supply of housing land and, although identified some capacity from extant permissions and other appropriate sites, also ascertained that Green Belt would have to be reallocated in order to meet the requirements of the East of England Plan. It is stated that 2,745 dwellings are required on Green Belt land between 2006 and 2024. This is in addition to the 2,005 dwellings to be delivered on previously developed land.

5.8 The Core Strategy sets out the general locations for housing development. The Council state that the primary factors in determining the location of future housing include current infrastructure; access to services; facilities; housing demand/need; deliverability; public transport/possibility of reducing car dependency; opportunities to utilise brownfield land; community needs and physical constraints; need to protect areas of landscape value, ecological importance and high quality agricultural land. The Council states that it seeks balance the distribution of housing by focusing growth upon the higher tier settlements.

5.9 The population of Rochford District is unevenly distributed with the largest settlement being Rayleigh which, in 2001, was home to 30,196 people, 38% of the District's residents. As such the Council identified Rayleigh as a primary tier settlement as it contains a range services and facilities including good public transport accessibility. The Core Strategy however notes that their housing needs evidence indicates that 44% of the housing need in the borough originates from Rayleigh. This provides a strong basis in which to focus housing development upon Rayleigh.

5.10 Despite what is said in the Core Strategy, it is clear that Council has failed to consider a balanced approach to housing delivery. However the Council's proposed housing locations do not reflect this statement as the scattered approach around the district will deliver housing away from public transport and key services and will lead to unsustainable patterns of growth. The Council's own evidence states that 44% of the need for housing is focused on Rayleigh, yet Rayleigh will only deliver 19% of housing on Green Belt sites. Indeed 57% of the Green Belt housing site allocations is focused outside the primary tier settlements. This will result in increased car movements between the settlements and will have an unsustainable impact upon the existing infrastructure.

5.11 There is a need for the Council to identify and significant increase in the housing provision for Rayleigh to meet the socio-economic objectives set out in the Rochford Core Strategy Submission draft.

c) Rochford's Housing Land supply (2001 to 2024)

5.12 The Council's SHLAA noted that there is an inadequate housing supply in the district over a fifteen year period to 2024 and as such there is a requirement for the allocation of Green Belt land for residential development. The SHLAA identifies a requirement to allocate 2,477 dwellings on Green Belt land in the period to 2024.

5.13 The Rochford Annual Monitoring Report (AMR) 2008 to 2009 demonstrates that Rochford has failed to deliver 309 dwellings of the required 1,840 between 2001 and 2009. The Council's SHLAA also suggests that 1,658 dwellings will be delivered between 2009 and 2014/15. The Council will also have to deliver 3,759 dwellings between 2009 and 2024.

5.14 It is considered that the land supply assessments used to indicate how these targets will be delivered is not based on a robust assessment and consequently it is clear that the Council cannot meet its housing supply requirements and that a significant dwelling shortfall will develop which will have significant implications for the future delivery of housing in Rochford.

5.15 It is considered that the Council's SHLAA and AMR do not provide an accurate assessment of the strategic housing land supply in Rochford and that in fact the future housing supply situation is worse than recorded. It is considered that the Council's SHLAA fails to take to account of:
Current housing market conditions in Rochford;
The time duration of the planning process i.e. from pre-application to completion;
The build out rates of housing sites; and
Site specific constraints.

5.16 The Council is unable to demonstrate a robust up-to-date five year supply of deliverable sites. The failure of the AMR to take account of these key matters is discussed below.

5.17 Rochford's annual East of England Plan housing supply requirement is to deliver 230 dwellings per annum. Between 2001 and 2009 this figure was met and exceeded on just two occasions, in 2005/06 and 2006/07. During this period Rochford was required to deliver 1,840 dwellings to meet the East of England housing supply requirement however just 1,531 dwellings were completed, resulting in a housing completion shortfall of 309 dwellings or a housing under-supply of 1.34 years.

5.18 The Council's housing trajectory set out in AMR states that over the next 5 years, annual housing per year will exceed 218 dwellings per annum. This level of growth is optimistic and does not reflect market trends in Rochford. It is a forlorn hope that housing supply could match its pre-credit crunch delivery rates over the five years given that during the pre-credit crunch years prior to 2007/08 Rochford was only able exceed its annual target on just two occasions. The Council has not provided any information that can justify how the housing market will be able to absorb the increased housing delivery that exceeds historical delivery records during a period when financial credit was more readily available.

5.19 The Council initiated a consultation titled 'Call for Sites', asking landowners and developers to put forward sites for consideration. This exercise was undertaken between January 2007 and April 2009. The Council's SHLAA states that these sites were assessed for their availability, suitability and achievability. However the land south of Rayleigh was not assessed and therefore it is clear that the Council is misleading in its assessment.

5.20 The SHLAA states that there is capacity within the District to accommodate 1,273 dwellings between 2009 and 2024 from outstanding planning permissions and other appropriate brownfield sites. This leaves an outstanding balance of 2,477 dwellings to be built by 2024 on land which is currently allocated as Green Belt.

5.22 The Council's SHLAA document and its AMR have failed to take account market factors that affect the delivery housing when consider housing supply to 2024. In particular the Council has not taken account the time delays caused by the planning system and the ability of the housebuilding industry to build out sites.

5.23 The Callcutt Review of Housebuilding Delivery (2007) was commissioned by the Secretary of State for Communities and Local Government to asses housing land supply in the UK. In consideration of timing from planning application submission to project completion, the Calcutt Review it was considered that the average time taken between planning application submission to construction completion is as follows:
Schemes of 15 to 49 units - 35.3 months
Schemes of 50 to 149 units - 39.4 months
Schemes of 150+ units - 44.6 months

5.24 This assessment does not include pre-application preparatory work which is cited in the Callcutt Review as taking 15.4 months on average for all schemes and 25.1 months for schemes of 150+ units.

5.25 The AMR and the SHLAA also do not make an accurate assessment of build out rates for specific sites and it is apparent that these documents do not understand the market forces that dictate the build-out rates. It is clear that in their assessment the Council has used an arbitrary figure that is not based on substantiated evidence. The 'Housing Markets and Planning Analysis Expert Panel - Factors Affecting Housing Build-out Rates: A report by Professor David Adams and Dr Chris Leishman' (the Housing Build-Out Rate Report) sought to determine the speed at which approved housing sites are developed.

5.26 Paragraph 2.4 of this report states that the research results suggest that the average optimal sales rate is about 59 units per annum for greenfield houses and 67 for brownfield apartments. Paragraph 2.5 states that most builders generally appear to set a target of between 40 and 80 units built and sold from each outlet annually. Paragraph 6.2 states that a typical strategy of most companies was to aim for a build and sales rate of about one unit per week on greenfield sites and slightly higher than this on brownfield sites and that this rate reflects the institutional structure of the British housebuilding industry in which fierce competition for land requires controlled and phased release of new development to ensure that the ambitious development values necessary to capture land in the first place are actually achieved when new homes are eventually sold.

5.27 Whilst the SHLAA has only recently been published, it is considered that it is not robust as the site assessment has not sufficiently taken into consideration the deliverability of sites as there is no technical evidence that demonstrates an understanding of the relationship between local housing markets and housing supply.

5.28 The AMR and SHLAA assessment of sites are optimistic and simplistic in their assessment of construction start dates and build-out rates. The housing land supply in Rochford is in fact worse than that set out in the AMR and SHLAA documents. Based on the assumptions using well founded national research it is clear that the Council has over estimated to the delivery of at least three sites identified within their SHLLAA and AMR. These sites are addressed below:

North London Road - The Council's AMR states that construction will start at this site in 2016/17 and that 550 dwellings will be delivered by 2019/20. The Council's projected delivery rate exceeds that cited by Government research. Assuming that the start date is correct it likely that site would take up to 9 years to deliver with 60 dwellings delivered per annum. At least 120 dwellings would be delivered in the period post 2024.
West Rochford - The Council's AMR states that construction will start at this site in 2012 and that 600 dwellings will be delivered by 2016/17. The Council project that 200 dwellings will be delivered in 2013/14 and that build out rates exceed 100 in four of the five years. This assumption is unrealistic and does not take account of the ability of the construction industry to deliver new dwellings. The start date is optimistic as it takes at least 2-years on large sites exceeding 150 dwellings from planning to start date. The first dwellings that would be completed, assuming a planning application is submitted in 2010, in 2013. Given the current stage of this DPD consultation it is unlikely that this site have a start date pre-2016. It is also highly optimistic that 600 dwellings would be delivered within 5-years as stated by the Council. Government research indicates that it would take up to 10 years to deliver this site. It is likely that the majority of this site will be delivered at the end of the 15-year period and that at least 120 dwellings will be delivered post 2024.
South West Hullbridge - The Council's AMR states that construction will start at this site in 2019/20 and that 250 dwellings will be delivered by 2021 and a further 250 dwellings to be delivered post 2021. If the start date is correct then this site will only be able to deliver 120 dwellings by 2021 and 260 dwellings post 2024.

5.29 The housing supply over estimation amounts to at least 500 dwellings or an undersupply of over 2-years of housing. It is clear therefore that Council needs to identify more housing sites. It is necessary for the Council to allocate more residential sites to ensure that sufficient sites are available to meet the minimum housing requirements set out in the East of England Plan.

SECTION 6: THE COUNCIL'S PROPOSED OPTIONS

6.1 This section considers the options for residential development put forward by the Council in the Site Allocations Issues and Options consultation. The comments in respect to these sites are follows:

a) North of London Road, Rayleigh

6.2 My clients support the principle of a release of Green Belt land in Rayleigh to support residential development to meet the East of England Plan requirements however my clients objects to Options NLR1, NLR2, NLR3, NLR4 and NLR5.

6.3 This site is characterised by its open undulating landscaping that makes it a visually prominent site at the edge of Rayleigh. This site has a number of constraints such as the pylons that cross the site and part of the site being within a flood zone. The removal of the pylons to allow residential development will be a costly undertaking that would reduce the potential community benefits that the Council seeks from this site.

6.4 Furthermore the site conflicts with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Rayleigh in a visually prominent location.
The open nature of this location will set the precedent for further development to take place to the west of Rayleigh. This will create the risk of materially reducing the gap between Wickford and Rayleigh. Consideration should be given to recent development to the east of Wickford as gap between the settlements is eroding.
This location constitutes good quality agricultural arable land that is characterised by its undulating form. Development at this location would prevent the safeguarding of the countryside from encroachment.

6.5 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside and consequently there are no easily defined boundaries. The built edge of Rayleigh would be very prominent from the Green Belt at this location.

b) West Rochford

6.6 My clients do not object to the principle of a release of Green Belt land at Rochford to support residential development to meet the East of England Plan requirements however my clients object to identification of land west of Rochford and Options WR1, WR2, WR3 and WR4 as a suitable option.

6.7 This site is characterised by open agricultural land that forms the gateway into Rochford from Hockley and Hawkwell. Neither of the options would be appropriate and constitutes urban sprawl that conflicts with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Rochford in a visually prominent location that links Hockley, Hawkwell, Rochford and Southend-on-Sea.
The proposed options will result in the development of land that provides an important gap that prevents the coalescence of Rochford with Hawkwell and Southend-on-Sea.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.8 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

c) South Hawkwell

6.9 My clients object to the principle of a release of Green Belt land at Hawkwell as development at this location will result in unrestricted development that threatens to create a sense of coalescence with Rochford, particularly given that the Council proposes development to the west of Rochford. Consequently my client objects to Options SH1, SH2, SH3 and SH4 as a suitable option for residential development.

6.10 This site is characterised by its wooded character that provides an important green lung for this part of Essex. Each of the proposed options will result in the destruction of an important wooded area. It is considered that this location cannot support the quantum of development suggested within the Issues and Options consultation document.

d) East Ashingdon

6.11 My clients object to the principle of a release of Green Belt land at Ashingdon and all the proposed options as this location is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh, the primary settlement in Rochford District.

6.12 Each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.13 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open Page 14 Rochford Allocations DPD: Regulation 25 Statement Land South of Rayleigh
countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.14 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

e) South West Hullbridge

6.15 My clients object to the principle of a release of Green Belt land at Hullbridge as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District and development at Hullbridge would fail to meet the housing need that exists in Rayleigh. The quantum of development at this location is broadly similar to that proposed for Rayleigh, however the Council's own evidence demonstrates that 44% of the identified housing need in the borough comes from Rayleigh. The Hullbridge options therefore constitute a mismatch between location and the need and demand for housing. My clients consequently object to options SWH1, SWH2, SWH3 and SWH4.

6.16 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Hullbridge at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.17 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.18 This Green Belt location is also constrained by its location in proximity to the River Croach and the impact of flooding.

6.19 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

f) South Canewdon

6.20 My clients object to the principle of a release of Green Belt land at Canewdon as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District. My clients consequently object to options SC1, SC2, SC3 and SC4.

6.21 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Canewdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.22 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.23 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

g) South East Ashingdon

6.24 My clients object to the principle of a release of Green Belt land at Ashingdon as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed and that development at this location would have a detrimental impact the character of the countryside. My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District. My clients consequently object to Options SEA1, SEA2, SEA3 and SEA4.

6.25 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.26 This location would also conflicts with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.27 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

h) West Great Wakering

6.28 My clients object to the principle of a release of Green Belt land at Great Wakering as it is not a primary tier settlement and would conflict with the objectives of the Council's Core Strategy Submission document. My clients also do not consider that this location can support the quantum of development proposed and that development at this location and that the proposed quantum of development is disproportionate when considered against the size of the settlements in Rochford District and against the locations of identified housing need. West Great Wakering is remote from the rest of the district and has poor transport links. Residential development at the quantum proposed would result in a significant increase in the number car trips in this part of South East Essex, My clients consider that residential development should be concentrated on Rayleigh the primary settlement in Rochford District which has the greatest proportion of identified need and has good public transport access. My clients consequently object to options WGW1, WGW2, WGW3, WGW4 and WGW5.

6.29 Furthermore each of the proposed options would result in the development of open countryside and as such would conflict with the objectives of the Green Belt as set out in paragraph 1.5 of PPG2. The conflicts can be described as follows:
The development of this site will result in the unrestricted sprawl of Ashingdon at this prominent location.
The open nature of each option would fail to prevent the safeguarding of the countryside from encroachment.

6.30 This location would also conflict with paragraph 2.9 of PPG2 which states that Green Belt boundaries should be clearly defined, using readily recognisable features such as roads, streams, belts of trees or woodland edges where possible. This location constitutes open countryside with no easily defined boundaries. Development at this location would create a built edge at this prominent Green Belt location.

6.31 The quantum of development proposed is inappropriate as this location is away from the main public transport routes, key employment areas and key services and as such would result in a significant increase in car movements across the district.

SECTION 7: CONCLUSIONS

7.1 We request that land south of Wyburns Primary School be allocated as a residential site within the Site Allocations DPD. This statement has demonstrated that:
1. The proposed site is well located to Rayleigh and would meet the Council's housing objectives and will assist in delivering housing to meet the Council's identified housing need in Rayleigh.
2. The proposed site would not conflict with the Green Belt objectives set out in PPG2.
3. The Council has under-estimated the amount of housing required on Green Belt sites to meet the districts housing requirements and consequently the Council needs to identify more housing locations and sites.
4. The Council's proposed residential sites are inappropriate as they constitute sites that conflict with PPG2 and the dispersed nature of these sites would result in unsustainable development away from public transport and key services that will lead to significant increases in car movements. Furthermore these sites would not assist in relieving the housing need in Rayleigh as identified by the Council.

HAWKWELL PARISH COUNCIL: RESPONSE TO ALLOCATIONS DPD DISCUSSION AND CONSULTATION DOCUMENT

1 INTRODUCTION:

Hawkwell Parish Council is still of the opinion that a new village should be created in South West Rayleigh to enable the benefits of easy access to the highway network to be realised and where all the infrastructure could be provided in a phased way without compromising existing settlements.

We consider that a Local Development Framework should be a document that sets out the strategy for spatial planning in the district. Whilst we understand that the Planning Authority has a statutory obligation to undertake a call for sites we are firmly of the opinion that such an approach mitigates against a truly strategic approach with the result that around 200 sites have now being put forward. We note that the DPD asserts that, of the 3,790 dwellings that have to provided according to the East of England Plan, some 2745 of these dwellings will be on green belt. The maths is simple, that means over 72% of the dwellings will be on green belt which is contrary to the stated policy of using brown field sites for the majority of these new dwellings. With such a gross distortion of the guidelines established by government a truly strategic approach (ie a new settlement) is all the more essential.

However, bearing in mind the above view, the Parish will respond to the proposed site allocations on the basis of preference for those which will do the least damage and provide the best defence to the remaining greenbelt. In this respect sites in Rayleigh, Rawreth area NLR5 seem the most suitable option.

2 RESIDENTIAL:

West Rayleigh

NLR5 is probably the best option because it has a strong defensible boundary and a bus service could be provided between London Rd and Rawreth Lane.

West Rochford

600 dwellings and a school in this location would destroy the rural nature of Hall Road. It would reduce and indeed almost remove the differentiation between Rochford and Hawkwell and is a prime example of urban creep. It will contribute to congestion as traffic tries to access the A127 via the B1013 Cherry Orchard Way. The loss of high quality agricultural land is always regrettable, especially in view of recent comment in the popular press on the need to protect prime agricultural land for food production in the coming years. Option WR1 is possibly the least damaging if the hedge line is protected along Ironwell Lane and Hall Road and access to Ironwell Lane by motor vehicle is prohibited.

West Hockley WH2

This option is preferred because it has previous industrial use and can be accessed off Folly Lane.

South Hawkwell 175 dwellings

The Parish Council maintains that this location is unsuitable and does not meet the sustainability requirements. Of these options, SH2 is the least damaging because it retains the wooded area behind Thorpe Close.


SH3 or SH4

These options must not be entertained because they encompass land between Rectory Road and Hall Road as well as Hawkwell Nursery site. The Jewson's site as a brown field site should, with resolution of access problems, take some of the allocation for South Hawkwell.

East Ashingdon 100 dwellings and land for extension of King Edmond School

Kind Edmond School would be large enough if a secondary school was provided in Great Wakering. This would save long journeys for the children (some 600 bussed every day causing increased traffic and pollution to local roads). However, Option EA is the least damaging as it limits development to one side of Brays Lane.

South West Hullbridge 500 dwellings

Option SWH1 is probably the least damaging.

South Canewdon 60 dwellings

SC6 is the most suitable providing a defensible boundary can be maintained.

South East Ashingdon 500 dwellings

All of the sites are unsuitable because they have an impact on Oxford Road.

SEA1 could be accessed off Oxford Road, The Drive and Ashingdon Road which will cause further traffic problems in these locations. West Great Wakering Option WGW5 would be most suitable.

Rawreth Industrial Estate

It is possibly better relocated and replaced by housing.

Stambridge Mills

This site would benefit from being zoned for housing providing public access is maintained to the waterfront.

Star Lane Industrial Estate and Star Lane Brickworks could accommodate housing although it is well located as an industrial site.

Eldon Way/Foundry Estate

Eldon Way should stay as local employers convenient for the station and has leisure uses. The Foundry Site could well be relocated and developed for housing, it would be a natural extension to the flats either side of Railway approach.


Gypsy and Traveller site locations

Option GT3 is the most suitable as it is closer to shops and schools.

3 ADDITIONAL EMPLOYMENT LAND:

West Rayleigh E18

Seems the most suitable because of its Highway location.

South of Great Wakering

Option E22 offers the least disruption to residents and has less impact on Poynters Lane.

4 ENVIRONMENTAL ALLOCATIONS:

The Parish Council agrees that areas shown on figure 4.3 and listed in table 41 should be allocated wildlife sites. Also agree that figure 4.4 should be allocated as the upper Roach Valley.

We also agree that the Coastal protection Belt should be shown as figure 4.5.

5 COMMUNITY FACILITIES:

Education

The Parish agrees in principle with the approach that a new Primary School be provided within future residential locations.

If the proposed site west of Rochford is on the eastern side of the new development it would appear to be far too near Rochford Primary we would question the need in this location.

Of the options presented Option KES2 is the most suitable however we maintain the view that if a new Secondary School were built in Great Wakering there would be no need to extend Kind Edmonds School and a large number of children would have their journey to school substantially reduced .

Open Space

We agree with the open space being protected through OS1 and consider that sites must be allocated rather than to left to determination by the vagary of negotiations with developers. We are again offended by the continuance of the Planning Authority to regard Hawkwell as a sub set of Hockley (there is no mention of Hawkwell in figure 5.1) - Glencroft is in Hawkwell, it is leased and managed by Hawkwell ( as are Spencers and Magnolia) and to state on page 127 that it is in Hockley undermines our confidence in the knowledge of the author of the detail of the layout of the district and the importance of community identity in such an important document.

Community Facilities

We believe community facilities proposed in (Option CF1) and illustrated and listed in figure 5.2 must be safeguarded. However we note that no account has been taken of the other community facilities that exist in the district (eg we draw specific attention to Hawkwell Village & Ashingdon & East Hawkwell Village Halls - both charitable trusts) that make significant contributions to community in the district, these too must be safeguarded.

6. TOWN CENTRES:

Rayleigh Town Centre Option TC1

Existing town centre boundary to be maintained.

Rochford TC4 is less restrictive but also allows customers to move around a smaller area.

Hockley Option TC8 seems the best option providing a more contained area.

We support the view that Hockley should be re-allocated as a District Centre.

Option TC12 Rayleigh

There must be a distinction between primary and secondary shopping frontages to maintain a vibrant town centre.

Rochford TC13

The distinction between secondary and primary should be maintained. The mixed-use development must be included in the primary shopping area because it contains the Supermarket.

Hockley TC15

We support this option as it utilises the existing primary shopping frontage to form primary shopping area.


7 OTHER ISSUES AND NEXT STEPS:

Hawkwell Parish Council wishes to be represented at The Examination in Public.

Once again we would take the opportunity to remind you that we are still awaiting a response to questions we have previously raised on various planning matters e.g. HAAP and JAAP.



We would also like to make the following comments in respect of the above document:-



2 Residential pg 4 - how are these figures arrived at ( I understand by another Conservative controlled quango)? How can it be blithely stated that 250 houses are to be built per annum post 2021, surely at some point building will have to cease otherwise there will be no room?

No mention is made of the number of dwellings that have already been built in the area since 2006 and the fact that some of these are still for sale long after completion (e.g. Follygate development on Aldermans Hill near Folly Lane in Hockley)? What are these numbers and why aren't they shown?

How have the figures for each location been arrived at? Seems very arbitrary

The council seems to show a lack of appreciation for quality of life for existing residents and just seeks to cram in more and more development - bewildering having seen this morning that whole estates new properties in Northern Ireland are being demolished because their housing boom never quite materialised and surely something that nationally needs to be properly considered?



Pg 5 - I refer you back to our comments on the HAAP (attached). Why is the council so obsessed with supporting the overdevelopment of the area and concreting over everything, especially as the road infrastructure cannot support large numbers of houses along the B1013. The HAAP is still at consultation stage and I believe 95% of respondents rejected the Council's proposals for redevelopment as unsuitable.



Pg 6 - It could alternatively be stated that the Council rejects proposals for significant redevelopment as the infrastructure is incapable of receiving the necessary upgrade. In recent years RDC has lost a Hospital and a Secondary School (Park in Rayleigh) to housing development, even with significant redevelopment Southend Hospital will not be able to cope and the roads in the region (especially the B1013) will be at capacity.



Pg 8 - Rawreth - there is already a green buffer - undeveloped land! - Development will lead to the joining up of Rayleigh to Rawreth, something that the Council has always previously sought to avoid - the merger of separate community areas. A theme repeated on pages 16 & 18, which effectively will merge Rochford and Hawkwell.



Pg 19-24 West Hockley development - As mentioned above the Follygate development has I am certain only been completed since 2006 and comprises 14 flats. If there is a need for 50 dwellings in this area at least 14 have already been built reducing the required number to 36 (and that's without other developments that have taken place along the B1013 in West Hockley where single properties have been demolished to be replaced by 2 or 3 new ones). So it is difficult to justify squeezing any more properties in this area, particularly as significant development in this area takes no account of the poor road access (Folly Lane is often congested and Fountain Lane is one-way) and will also increase traffic onto the B1013, where it is not unusual to have tailbacks from the Spa to Folly Lane. Congestion problems are often exacerbated by horse riders travelling between the stables beyond Church Road and the Hockley Woods Bridle Way. Option WFH4 also makes no mention of the impact this will have on either the small woodland nor pupils at Hockley Primary School as lessons are disrupted by ongoing building works.



Pg 28 South Hawkwell SH3, as with Rochford there is a danger of the merger of two distinct areas Rochford and Hawkwell



Hullbridge and Canewdon - Both areas have particularly poor public transport links and are low lying - has the reality of this been properly considered? Council are apparently committed to getting people using public transport to cut down carbon emissions etc and to be located near their places of work, but, particularly with 500 properties in Hullbridge, this would clearly run contrary to this policy. Nationally recommendations are being made to avoid development of flood plains and yet construction appears to be welcomed on areas below 10m



West Gt Wakering WGW3 & 4 - As with many of the above points the potential merger of areas and use of low lying land with poor public transport.





Overall preference should be given to redevelopment of industrial sites which have closed. The danger is however that RDC's pursuit of Brownfield sites leads us to situations where agricultural land is used for something like a Christmas Tree farm and is then able to be classed as a Brownfield site (see Hawkwell) or worse a company decides to shut a perfectly good functioning site in order to sell the land for housing (Eon call centre in Rayleigh - significantly another site that hasn't apparently been taken into account since a number of properties have already been built in that location).



Gypsy and Traveller sites pg 62 - Again no explanation as to how these figures have been arrived at; or indeed, why.



The following questions also need to be answered:-



Why can't Travellers use commercial pitches like everyone else?



What would happen if the Council didn't allocate any additional pitches?


Where are the existing pitches?



How are Travellers allowed to exploit planning laws on illegal pitches and have access to public utilities (surely the council should be able to prevent the Utility companies from providing such services without planning permission)?



What fees does the council obtain from Travellers using pitches - e.g. Council Tax ?



How have the sites listed been selected? GT4 is particularly close to an historic site and



Why hasn't consideration been given to the strip of land beside the airport, identified in the JAAP as having little use and already fulfilling the function of serving a travelling community being the site of the circus every year?





Office space - pgs 81-88. Again not apparent how these figures are arrived at, there seems to be a fair amount of vacant sites including office space around the district. On the one hand seem to be saying that Eldon Way in Hockley is under pressure for alternative use because sites can't be let and on the other that you need to build more sites - can only be one or the other not both. Also don't believe that this takes account of Eon closure - if you refuse planning permission for the site then there is clearly a large amount of vacant office space in Rayleigh!





Pg 90 - Southend Airport - We refer to our previous objections to development of this site attached





4 pg 98 - what is "minimum" development - undefined and irrelevant term - refer to my previous comments on the Core Strategy (attached)



Pg 108 Upper Roach Valley - Certainly the area without development should be as wide as possible. However given the proximity of other woodland e.g. Betts Wood and Folly Wood - can they not be incorporated? Is it not possible to extend the area bordering Hockley and Rayleigh across the farmland to the Railway line or indeed the east side of Hockley to ensure that buffers are maintained between Hockley/Hawkwell and Rayleigh to the West and Rochford to the East?



Pg 111 - interesting selection for a school given that Southend Council have agreed that as many flights as possible should take off in this direction. As objectors to airport expansion we would support a school being sited here if this would prevent airport expansion and aircraft being directed over residential areas of Hawkwell and Hockley as seems to happen at present



Pg 111-115 - Whilst not knowing any of these areas in any great detail concern would be that expansion of the schools and access would lead to pressure to develop other adjacent sites , which were previously inaccessible, putting further strain on Green Belt.



Pg 116 - 125 - Not sure what the document is driving at here. If the suggestion is that none of these education sites should be used for anything other than the existing function and not be sold off then this is of course sensible. Although, this overlooks the fact that many of them are locked in residential areas and cannot expand. Indeed spare land adjacent to Fitzwimarc School was sold some while back and the front playground has now been lost to car parking. It would be more sensible therefore for the council to propose protection of the areas immediately adjacent to schools to enable them to expand if and when necessary rather than use existing space for non-educational purposes e.g. car parking. The current proposals are just a continuation of the lack of foresight that has seen school sites developed and then pressure to build new ones or expand existing sites e.g. loss of Park School in Rayleigh.





Pg 125-127 - Have to question what the protection actually offers - there doesn't seem to be a great deal of protection offered by Green Belt status and we would welcome additional protection. The map however makes it almost impossible to see the full extent (or limitation) of the proposals. From the areas known to us would suggest that Land South of Nelson Gardens, Hockley Woods and Turret House Open Space should all link up and provide a buffer stretching from rear of Wellington Road where it adjoins B1013 right over to Albert Road and all the way up to and beyond Hockley Woods, but this isn't apparent from the map.



Would also question why so little consideration is given to area between Hockley and Hullbridge, around Betts Wood, Folly Lane etc, all open land and part of public footpath network and currently affording good views across open land. Similarly Gusted Hall area?, Belchamps? Etc all omitted



Pg 130 Leisure Facilities - Less than 7% population within 20 minutes of 3 different leisure facilities. Although no definitions are given of "leisure facilities" I'd really question the accuracy of this statement. Leaving aside "fringe" activities such as snooker; bowling and fishing there are least 3 Sports Centres in Rayleigh, Hawkwell, Wakering, (plus just outside district Thundersley; Eastwood etc) offering a variety of activities and most of the population live within 10 minutes drive of these. There are numerous footpaths and cycleways, local gyms and dance studios, football pitches and children's play areas in every town (including adjacent to the sports centres) and a number of community and church halls offering leisure activities for adults and children e.g. Judo





Pg 135 - As with above these need to form part of the leisure strategy - certainly our local community centre (Hockley) is under-utilised and from knowledge of Grange that too wasn't used enough. But why are other sites omitted? Why are the sites listed given preference over many other community sites e.g. Hockley Public Hall; Castle Road Hall and why isn't more consideration given to encouraging schools to use their facilities outside of school hours/term?



With or without protection the fear is that the Council will offload these to "Developers" as with Clements Hall and the real likelihood is that sites such as Grange and Hockley Community Centre will then be deemed "uncommercial" and closed by any developer before being redeveloped as housing



Pg 136 Town Centres - There appears to be a lack of recognition that traditional town centres are declining anyway and therefore if there is housing pressure this could be accommodated by contracting the retail area.



Incidentally with regard to Rayleigh and Rochford there was a recent article in the Evening Standard that referred to studies demonstrating that one-way systems exacerbate the decline of town centres as drivers pass through too quickly and are discouraged from stopping.



For Hockley - again contraction of the area to the West needs to be considered, this area has suffered in every recession and shops here have stood unoccupied for years (e.g. Old Post Office Bathroom Store and could provide housing. However other business are (hopefully surviving). One of the main problems in the centre is lack of parking (the car park is located too far from the shopping area and now that there are good leisure facilities (e.g. bowling alley in Eldon Way access from the High St could be easier (many of the stores have parking to the rear and with the loss of Alldays there is an opportunity for another access point). Foundry contains many vacant office sites that could be better utilised, particularly if there is housing pressure. Full consideration should be given to reallocating it as a District Centre, but this shouldn't mean that it is neglected.



We've previously commented on HAAP and Rayleigh development and would repeat those comments for town centre development.

Objection to housing in Canewdon. See paper copy for details.

Support on development in Canewdon, comments on development in Canewdon. See paper copy for details.

Support on development in Canewdon, comments on development in Canewdon. See paper copy for details.

Response of Essex County Council

Essex County Council welcomes the production of an Allocations DPD by Rochford District Council. The setting out of site specific options for development at the general locations identified within the Core Strategy Submission Document will positively assist realisation of the Core Strategy and the Vision for the District. The inclusion of options not just for residential and business development but also for community facilities and environmental designations is particularly supported as providing a firm basis for the holistic and sustainable approach to the future of the District. Similarly, the stated intent (Page 6) to ensure delivery of required infrastructure alongside residential development is fully supported.

The scope and coverage of the Allocations DPD is broadly supported but the general approach to site assessment, selection and definition could benefit from some further considerations, as follows,

1. as presented, many of the site specific options for development suggest artificial and/or straight.site boundaries. The definition of boundaries of the sites eventually selected should be based on and incorporate existing boundaries, in order to,
* respect the often ancient field patterns;
* existing hedges and other vegetation can provide a screen to the development or a feature at the periphery of the development;
* avoid odd parcels of land remaining which are too small to function independently;
* preserve often important wildlife habitats.

2. new single-form entry primary schools will be required to serve proposed residential at two locations - the site North of London Road, Rayleigh, and the site to the West of Rochford. Chapter 5 (Community Facilities) lists site characteristics for school provision at each of these sites (Pages 110 and 111). Essex County Council does not agree to these lists of characteristics. The criteria for identification and selection of school sites are much broader.

Essex County Council has produced an 'Education Contributions Guidelines Supplement' to its 'Developers Guide to Infrastructure Contributions (2010 Edition)' - both of which were subject to a public consultation exercise closing in February 2010. The 'Education Contributions Guidelines Supplement' (copy attached to response) sets out the detailed requirements for provision of new school sites. In the context of the statements on pages 110 and 111 of the Allocations DPD particular attention is drawn to the procedures and requirements for identification and selection of new school sites as set out in Appendices D, E and F. Within Appendix D particular attention is drawn to the section of the Checklist addressing the question of 'suitable safe access' to the site to emphasise that the design of the school and its relationship to the proposed and existing residential areas should facilitate provision of the best and safest walking routes to schools. The Supplement should be referenced within the Allocations DPD and other relevant documents within the Local Development Framework.

3. provision of Early Years and Childcare facilities is not discussed by the Document. Clear statements should be included that the two potential new primary schools would also need to incorporate Early Years and Childcare facilities. The District's Core Strategy (Policy CLT2) also requires provision of new Early Years and Childcare facilities in Hockley. Although it is not currently envisaged that a site could be identified in the Allocations DPD the requirement could be usefully identified in discussion of Hockley Town Centre (Page 144).

4. the proposed allocation of sites for education use is noted. However, allocation of such sites, and other County Council or public service sites, should not be applied such that it seeks to preserve existing uses on sites in perpetuity, thereby restricting the service provider's ability to expand/relocate the facility to better cater for future needs. Should a public service site cease to be required for its current purpose, its future use should be determined on the merits of the site and its location. Public service sites become surplus because local demand for the service has fallen to uneconomic levels or the facility has been replaced by more suitable facilities elsewhere. The Allocations DPD, and other documents within the Local Development Framework, should acknowledge that there will be circumstances when a better option for the community would be redevelopment of a public service site and re-investment of the proceeds elsewhere as part of a strategic programme of infrastructure replacement.

5. Section 4, Environment, of the Allocations DPD would benefit from an additional section that discusses the Historic Environment of Rochford District. Essex County Council would welcome early discussion with the District Council with the aim of producing jointly agreed text for such a section.

6. it should be noted that the County Library Service's medium-term plans include moving the existing library from its existing premises in Great Wakering. This may offer the opportunity for a joint project associated with the proposed enhancement of the Leisure Centre in the village, dependent on detailed location, access and other considerations.

7. the selected sites will generally be associated with greenspace creation. Information on greenspace deficiencies in the area is available in the 'Analysis of Accessible Natural Greenspace Provision for Essex, including Southend-on-Sea and Thurrock Unitary Authorities', which may be found on the Essex Wildlife Trust website.

8. the emphasis of the Document on provision of Sustainable Urban Drainage systems is welcomed, but it should be linked to broader support for the use of associated Green Infrastructure and greenspace creation.

9. the Allocations DPD should acknowledge and note the proportion of the development requirements that will be provided on existing development or brownfield sites.

In respect of the proposed site specific options and environmental designations Essex County Council has the following observations,

A. King Edmund School education site - there is an identified need to provide additional land to accommodate expansion of the school to meet additional demand and to secure improved vehicular access to the school via Brays Lane. Options KES2 and KES3 are preferred by Essex County Council because each presents an opportunity to contribute to both identified needs. Improvements to King Edmund School will need to be linked with adjacent proposals for residential development at the East Ashingdon location. Options EA1 or EA3 are preferred because of the opportunities they present to enable the improvements to the school, which Option EA1 does not. Essex County Council would welcome early discussion with the District Council to ensure the suitability of the detailed site specific requirements for improvement to King Edmund School and residential development at the East Ashingdon location. It should be noted that provision of access from King Edmund School to Brays Lane should be of a standard sufficient to accommodate cars and all associated vehicles serving the school.

B. the proposed environmental designations discussed in Chapter 4 (Environment) are supported. The proposed definition of a boundary for the Coastal Protection Belt is particularly supported as assisting realisation of Policy ENV2 of the Core Strategy and reflecting the currently saved Policy CC1 of the Essex and Southend-on-Sea Replacement Structure Plan (2001). Also, the designation of Cherry Orchard Jubilee Country Park and the Upper Roach Valley is supported. However, the Allocations Document should also include the proposed Stonebridge Park, which is highlighted in the Parklands Vision as a potential sub-regional park centred around Great Wakering.

C. further detailed consideration would be required of the potential employment/ business density of the site and its transport and access requirements of Option E18, Michelins Farm (an option for 8.6 hectares of employment uses, Page 88) should the District Council wish to proceed with allocation of the site. The A1245 is classified as a Main Distributor in the Route Hierarchy and direct access from this class of road is normally prohibited. In addition, the distance on the A1245 between the A127 Fairglen junction and the railway line acts against achievement of the required technical specifications for a new junction. Any changes to the Fairglen junction to provide an access to the site would require comprehensive realignment of the northern western sector and, in addition, the existing roundabout contains a pumping station. Direct access to the A127 and A130 is also prohibited due to the classification of those roads and would need third party land.

D. Assessment of the preferred site options should also include specific consideration of their Historic Environment Character in terms of known and potential features and their contribution to the cultural and historic landscapes of the District. There should be a programme of archaeological evaluation to ensure that the cultural heritage potential of each site is taken into account at an early stage in selection of preferred site options and taken forward in subsequent work on the preferred sites. A summary description of the historic environment characteristics and the requirements for archaeological investigation of the residential, brownfield and new employment locations presented in the Allocations DPD is set out in the Annex to this response. The summaries have implications for choice of sites within the locations at West Hockley, South West Hullbridge, South Canewdon and West Great Wakering (residential) and at South of Great Wakering (employment). Essex County Council would be willing to contribute further detailed evaluation of the historic environment characteristics of each site to inform further stages in preparation of the Allocations DPD.


ANNEX TO ESSEX COUNTY COUNCIL RESPONSE TO ROCHFORD ALLOCATIONS DPD, DISCUSSION AND CONSULTATION DOCUMENT (REGULATION 25) FEBRUARY 2010

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

1. North of London Road Rayleigh - the Rochford Historic Environment Character (HEC) project identifies the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to any of the four options suggested, given the sites' adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

2. West of Rochford - the Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HEC Zone 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeological potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered

3. West Hockley - this proposed location lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HEC Zone 33) identified in the Rochford Historic Environment Character project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (WH1-5) suggested for land West of Hockley, although options WH2 or WH5 be would preferred due to previous development, they would entail the least impact on any surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the area and the woodland setting.

4. South of Hawkwell - within the Rochford HEC the proposed development south of Hawkwell lies within the HEC Z one26, Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites' historic environment character and potential there would be no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

5. East Ashingdon - the site lies within HEC Zone 13, characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie close by. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (EA1-4) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

6. South West Hullbridge - the HEC Zone 36 for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is close by. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. Whilst there would be no objection to the options outlined for South West Hullbridge, there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

7. South Canewdon - the HEC Zone 12 shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of options SC2, 3 and 4 but little to the south, further away from the historic core, in the area of SC1. There would be no objection to the options outlined for South Canewdon, but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

8. South East Ashingdon - the location lies within HEC Zone 13 characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. There would be no objection to the options (SEA1-3) but there would be a requirement for a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

9. West Great Wakering - options for West Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. There would be no objection to the options (WGW 1-5), although those incorporating, or part incorporating, former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW4 and 5) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

B. Brownfield Sites

1. Stambridge Mills - the location survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. There would be no objection to the redevelopment of the Stambridge Mills site, but there would be a requirement for a historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

C. New Employment Land Allocations

1. West of Rayleigh - the Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits (HEC Zone 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

2. Michelins Farm - the Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HEC Zone 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

3. London Southend Airport and Environs - within the Rochford Historic Environment Character report the relevant character zones (HEC Zones 17 and 18) identify the areas at this location that not already developed as having a high potential for the survival of historic environment assets. The area is one which, although partially disturbed through construction of the airport and modern industrial buildings, retains a significant archaeological and more general historic environment potential. In addition to known sites, such as the medieval church of St. Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds in the area of the on- going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WWI and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

4. South of Great Wakering - options for south of Great Wakering lie within HEC Zone 7, an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying. Due to quarrying, option E22 (south of Star Lane brickworks) and options E23 and& E24 (south of Poynters Road) have no historic environment implications and option E19 would have the least impact of the remaining options. Otherwise non- quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.

Objection to housing in Canewdon. See paper copy for details.

Objection to housing in Canewdon. See paper copy for details.

Objection to housing in Canewdon. See paper copy for details.

Comments development in Canewdon. See paper copy for details.

Objection to the housing in South Canewdon.
See paper copy for details.

Objection to the housing in Canewdon.
See paper copy for details.

Rochford Site Allocations DPD

Outlined below are the Historic Environment and management (HEM) Teams comments on those options set out in the Rochford site allocations DPD. These are mainly focused upon section 2 the residential allocations and brownfield sites and section 3 new employment sites. Section 4, Environment, requires the addition of an appropriately worded section to cover the Historic Environment of the Rochford Area. This could be provided by the HEM team if required.

Section 2: Residential

Residential Land Allocations

North of London Road Rayleigh

The Rochford Historic Environment Character project identifies that the options NLR1-4 for land north of London Road as lying within an area characterised by an historic dispersed settlement pattern retaining good potential for below ground deposits (HECZ 34). Whilst there would be no objection to any of the four options suggested, given the sites adjacency to known heritage sites, the historic environment character and potential any future large scale housing development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

West Rochford

The Rochford Historic Environment Character project identifies the site West of Rochford as lying within an area of high potential for surviving below ground deposits in un-quarried areas (HECZ 18). The limited archaeological knowledge of the site probably relates to a lack of fieldwork than to a genuine lack of early settlement as extensive evidence of prehistoric occupation lies to the south of the site at Westbarrow Hall. The area around the scheduled Rochford Hall should also be considered one of archaeolgocial potential, as the postulated location of medieval settlement. Whilst there would be no objection on Historic Environment grounds to any of the four options (WR1-4) suggested for land West of Rochford, given the sites adjacency to known heritage sites and its archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

West Hockley

This proposed site area lies with an historic landscape of dispersed settlement which dates to the medieval or earlier periods and within a zone (HECZ 33) identified in the Rochford Historic Environment Character (HEC) project as retaining a high potential for historic environment assets. There would be no objection on Historic Environment grounds to any of the five options (HW1-5) suggested for land West of Hockley, although options WH2 or WH5 would be preferred due to previous development, they would entail the least impact on nay surviving remains. The other options would however require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered. Consideration should also be given to the landscape character of the are and the woodland setting.

South Hawkwell

Within the Rochford HEC the proposed development south of Hawkwell lies within the (HECZ 26), Land between Hockley and Ashingdon. This area of predominantly rural landscape slopes down to the Crouch Estuary between Hawkwell and Ashingdon, is noted for its dispersed settlement and the number of find spots, particularly of prehistoric material and its potential for archaeological sites despite little formal investigation having been carried out. Having considered the sites historic environment character and potential we would have no objection to the options (SH1-4) but given the sites archaeological potential any future housing development would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

East Ashingdon

The site lies within Historic Environment Character Area (HECA 13) characterised by its landscape of dispersed and polyfocal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies less than a 1km to the north while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm lie closeby. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. We would have no objection to the options (EA1-4) but would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

South West Hullbridge

The Historic Environment Character Zone (HECZ 36) for land west of Hullbridge states that whilst archaeological deposits are rare, prehistoric sites are present within the inter tidal zone and in general the area has potential for deposits to survive. Two known undated earthworks at Maylons and South of Maylons lie within the proposed area while a medieval moated site is closeby. Options SWH1 and 2 have the greatest impact on the earthwork sites, Options 3 and 4, less impact. We would have no objection to the options outlined for South west Hullbridge, but would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

South Canewdon

The Historic Environment Character Zone (HECZ 12) shows that Canewdon is an example of a late Saxon/early Medieval settlement focused on the church hall complex but surrounded by a wider dispersed pattern of manors. On comparison with similar settlements it is reasonable to assume that archaeological remains survive within and in the proximity of the historic settlement particularly those historic assets associated with the coast and historic core. Some archaeological finds have been unearthed immediately north of option SC2-4 but little to the south, further away from the historic core, in the area of SC1. We would have no objection to the options outlined for South Canewdon, but would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

South East Ashingdon

The site lies within Historic Environment Character Area (HECA 13) characterised by its landscape of dispersed and poly-focal settlements, church/hall complexes and historic farms. The medieval church/hall complex of Ashingdon Hall/St Andrews Church lies nearby while a number of halls, moated sites and farms including Apton Hall, Little Stambridge Hall, Moated site of Rectory Hall and Doggetts Farm are in close proximity. Roman material has also been identified to the west of Doggetts Farm. The zone is also noted for the many archaeological sites of a multi-period date and the potential for archaeological survival due to lack of development. Although there is limited archaeological knowledge within the limits of the proposed site, the area has been identified as being sensitive to change. We would have no objection to the options (SEA1-3) but would require a programme of archaeological evaluation to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

West Great Wakering

Options for West Great Wakering lie within Historic Environment Zone Area (HECZ 7) an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying.

We would have no objection to the options (WGW1-5), although those incorporating or part incorporating former extractions such as WGW1-3 will have the least impact upon the historic environment. Otherwise non-quarried areas (most of WGW 4 7 5 ) would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

Brownfield Sties

Stambridge Mills

Stambridge Mill survives as a complex multi-period site comprising a wide range of buildings, structures and earthworks which together chart the development of an historic milling site dating from the 18th century or earlier. In a wider context it sits within an industrial backdrop of quays and wharfs and a prehistoric landscape, with important Bronze Age and Iron Age settlement recently unearthed at nearby Coombes Farm. We would have no objection to the redevelopment of the Stambridge Mills site, but would require historic building survey to record the complex prior to any demolition and an archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

Section 3 Economic Development

Additional Employment Land to be Allocated

West of Rayleigh

The Rochford Historic Environment Character project identifies that the options for land West of Rayleigh lie within an area characterised by historic dispersed settlement retaining good potential for below ground deposits *HECZ 34). Whilst there would be no objection to the options for a new employment park, options E13 and E15 would have the least impact on the historic environment. Any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

Michelins Farm

The Rochford Historic Environment Character project identifies that option E18 for employment land at Michelins Farm lies within an area characterised by multi-period settlement, as revealed during the recent excavations along the A130, with a good potential for below ground deposits (HECZ 40). Whilst there would be no objection to option E18 any future development would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage.

London Southend Airport and Environs

Within the Rochford Historic Environment Character report the relevant character zones (HECZ 17 & 18) identify the areas not already developed has having a high potential for the survival of historic environment assets.

The area is one which although partially disturbed through construction of the airport and modern industrial buildings retains a significant archaeological and more general historic environment potential. In addition to known sites such as the medieval church of St Lawrence, moated sites, post-medieval tile kilns and brickworks, further finds, in the area of the on-going airport railway terminal and to the west of the site indicate extensive prehistoric activity. Furthermore the airfield was established by the RFC during WW1 and was later requisitioned to become RAF Rochford, part of the Fighter Command during WWII. The airfield was heavily defended and still contains a large number of extant features relating to the security of the airfield. Any future development proposals would require a programme of archaeological evaluation to ensure that the cultural heritage potential of the area is taken into account at an early stage and to make sure that opportunities for pro-active assessment, management and enhancement are fully considered.

South of Great Wakering

Options for south of Great Wakering lie within Historic Environment Zone Area (HECZ 7) an area notable for its multi period landscape dating from the Middle Bronze Age. Brickearth quarrying has had a significant impact upon the historic environment although there remains a high potential for archaeological remains in those areas not previously subject to quarrying.

Due to quarrying options E22, south of Star Lane brickworks, and E23 & 24, south of Poynters Road have no historic environment implications and E19 would have the least impact of the remaining options. Otherwise non-quarried areas would require a programme of archaeological evaluation to ensure that the cultural heritage is taken into account at an early stage.