SH - Are these the options we should be considering for South Hawkwell?

There is no place in Hawkwell for any large number of additional residential properties. The main roads are already stretched to capacity with no possible means of improvement for more useage. If additional residential properties were to be built in Hawkwell the road structure in and out of the village would eventually come to a standstill. Do we really have to submit to using every single square metre of available land for residential building.

No development should be considered that impacts on greenbelt, woodland or Agricultural land.

SH1 is the best option. However in terms of infrastructure all these proposals will add to road congestion. Along Rectory Road there is a railway bridge with the road controlled by traffic lights. At the other end is a mini roundabout on one of the busiest 'B' roads in Essex. The bus service is poor. Rectory Road carries traffic to Clements Hall. Unless there is a Transport Plan to maintain traffic flow I am against any proposal?

All options require improvements to the highway capacity and infrastructure, but it is not clear how these could be achieved. In particular, traffic along Main Road is already significant and these proposals would disrupt traffic at the Rectory Road Junction. I disagree that the area is well served by schools and services. The nearest schools are a significant distance away and there are limited shops nearby. This would increase the amount of traffic trying to use already congested roads in the area. Details of improvements to roads in the area need to be agreed before any development is approved.

All sites are in the same location, the Christmas Tree Farm. Why is this and the surrounding area the only site being considerd? If these houses are to be forced upon us they should be on a small mixture of sites throughout the area, this is no place for a housing estate!!

All sites are in the same location, off Rectory Road.This road is the only link between Ashingdon road in the East and Main Road/Hall Road in the West,an official rat run.Add Cements Hall Sports Centre traffic and the local residents transport, you have a very busy minor road.No houses should be built in these four options.
The council should not be considering these options, but considering the large number of residents/council tax payers these options are traumatisng

I would like to register my objection to any residential development in South Hawkwell. Any size of development would destroy the character of the area, and be unsustainable with regards to infrastructure. No amount of new infrastructure can sidestep the fundamental point that South Hawkwell is too small to accept any more households. To do so would radically change the environment in which the current population resides, and cherishes. Not to mention the fact that infrastruture development is itself just that - development, further eroding the character of this green belt area. Green Belt development is easy, not appropriate.

These are not options, these sites are just a variation of one site, the Christmas Tree Farm. Mr Scrutton assured me that NO decision had been taken by the Council, if that is so why do we only have one opotion? If this is a consultation what exactly are we consulting on if we only have the Christmas Tree Farm and surrounding areas to comment on.

From Councillor John Mason, Ward Member for Hawkwell West as at 28 April 2010 on behalf of Rochford District Residents

The majority of residents who live in Hawkwell West Ward (the miss conceived description of this area in the LDF is South Hawkwell which is misleading) have already responded in significant numbers in all previous consultations that any site in South Hawkwell are unsustainable in terms of PPS3 and PPS12.

The Council has mostly not understood (or it has ignored for political reasons) this very sound analysis in spatial planning terms and that is to be regretted. It seems that the Council is unable to make changes unless another area "volunteers" to take the allocation. That is the Council's job. The Council also has some sort of quaint notion of dropping houses into most areas of the district without a recognisable strategy. This approach might make it easier to pilot a political solution through the administration's political party but it is not a spatial planning strategy.

THe Council clearly made a mistake in putting forward Hockley and Hawkwell as one settlement based on function because Hawkwell does not have a Town Centre functionality and Hockley clearly does. Hawkwell does not have a Town Centre nexus with Hockley. Hockley's Town Centre Plan is based on Hockley as its immediate surrounding and formative local area and not Hawkwell. With no attempt made by either the Council or Hockley to consult with Hawkwell this proves the point rather well. If no input is sought or offered then there is no nexus.

The Council made another mistake in putting forward South Hawkwell for a quantum of 330 without having considered PPS12. Once it had made a Sustainability Appraisal it decided that only 175 in was sustainable in South Hawkwell. But that was also a mistake because an objective review of sustainability by myself under PPS12 and put forward to the Council in the LDF showed that even this quantum was not convincingly sustainable especially for the purpose of sustainable development with affordable housing.

This matter will also be pursued by residents with the Inspector in the Public Examination who has indicated that she will consider whether there are any alternative and more sustainable Locations to those put forward in the Core Strategy Submission.

On that basis the unpalatable, but necessary responsibility, to suggest another better Location will no doubt be taken on from the Council by residents at the request of the Planning Inspector.

In this consultation on the Allocation of Sites residents are still overwhelmingly of the view that none of the sites,SH1,SH2,SH3,SH4 suggested are supported. I agree. Interestingly sites that have not been put forward nearby have been rejected for reasons that equally apply to the sites put forward and this provides no sense of confidence in the Council's presentation of options.

Indeed it raises in the minds of residents why there is one central site in each of the options put forward in Hawkwell? There is no real variation offered from simply, Rectory Road cloned times four!! This is not offering a real choice of options. It is a sham.

If the Council cannot leave Hawkwell West out of the Council's LDF proposals, regardless of public opinion, residents would like very real new efforts being made by the Council to re-consider all brown field sites including the Magee's site in Windsor Gardens. Whilst this site has issues residents consider that there are civil engineering solutions which could be deployed so that a brown field rather than a green field site is used in Hawkwell. If this is not possible then the Council should put forward a series of smaller sites which could be developed by local builders in seperate styles and locations.

If the Council insists that there are no other sites in Hawkwell apart from those put forward in this consultation,SH1,SH2,SH3,SH4 then residents have no choice but to put forward other sites outside of Hawkwell for consideration of being allocated the quantum of 175.

I have consulted with residents. They understand that I will put this alternative forward as a District Council Member for Hawkwell West before the outcome of the local elections are known. Residents recognise that there will be people and organisations that will brand this consultation response as NIMBYISM. It is not because having abrogated its responsibilities to respond appropriately to sound planning reasoning the Council has given residents no choice but to risk communities getting into direct conflict which each other on emotive issues which Members of the Council should have dealt with by mature and informed discussion.

Please note that residents wish the Council to put forward real alternatives in Hawkwell but if it cannot or will not then instead this radical alternative is presented as a responsible option because the Location of South Hawkwell is simply less sustainable than other alternatives.

Many residents of Hawkwell West have the informed view that both policies PPS3 and PPS12 require focus on less car journeys rather than more coming from new developments and that the availability of public transport hubs within a few minutes walk of new developments, especially with 35% affordable homes, is required.

So that defines where and how the best choice in spatial planning terms should be made by the Council.

Residents consider that such developments should be, rather than in South Hawkwell for example, closer to or even in existing town or larger village centres.
The proposal for 150 such dwellings in Hockley Town Centre makes sense. South Hawkwell does not by comparison on spatial planning attributes.

So where is the next best Location in terms of PPS3 and PPS12?

The present consultation on the Allocation of Sites DPD offers two sites, WR1 and WR2, in West Rochford, close to Rochford Town Centre, both of which can take 600 dwellings each. Indeed a major housing developer has submitted a planning application for 600 homes in this Location for WR1.

Moving the 175 allocation from South Hawkwell to West Rochford can easily be accomodated on two sites with a combined capacity for 1200 dwellings and still not over develop the area.

Indeed placing the Affordable element of 775 dwellings, calculated at 271 dwellings, would obviously be best placed near the Rochford Town Centre on site WR1. Paragraph 2 on Page 15 of the Consultation document sets out the Council's own reasons why this Location is so suitable for development. These reasons provide the impetus to continue to revitalise prosperity of the town of Rochford which has diminished so much over the last 40 years without strategic intervention.

In addition I would also point out some attributes that the Council has missed completely in its consultation presentation. The infrastructure already includes extensive cycle paths which extend into the Borough of Southend. Rochford is already a bus interchange for two routes to Southend and Rayleigh and is expected to have additional bus services to the new industrial area of the expanded Airport and the Airport itself. The B1013 link to the A127 will route traffic directly to this arterial route and take traffic away from the congested B1013 to Rayleigh via Hockley.

There is every reason to choose WR1 and additionally add a small part of WR2 to provide a Location for 775 houses instead of using the unsustainable Location of South Hawkwell. With a major developer having submitted a planning application for a quantum of 600 it is considered that 775 would be equally attractive, sustainable because it is a marginal increase and deliverable.

In principle I do not agree with any of the Options you have put forward because I disagree with the loss of any further greenbelt for development.

The additional housing needs of Hawkwell are far less than 175 and such needs can be easily accommodated on brown field sites rather than green belt. Furthermore, any of these options which are of a similar location i.e. incorporating the Christmas Tree Farm will only add to existing 'bottlenecks' and are totally out of character with existing properties.

Hawkwell already suffers from a lack of infrastructure which this proposed development would only serve to exacerbate it. We should only build the minimum number of properties necessary to meet the requirements of Hawkwell.

To add all the proposed additional traffic and to the already overloaded Rectory Road and B1013 road system which provides busy access to Clements Hall is only worsen an already bad problem !

The Hawkwell Residents Association has discussed the RDC Core Strategy Allocations document and wishes to object on the grounds of unsoundness or legally non compliant due to the following points:

It makes no sense to locate the proposed 175 homes in one of four locations that are all off of Rectory Road, which has an inadequate roundabout at one end and single file under a narrow railway bridge via traffic lights at the other.
Producing a heavy weight document that prevented printing and general distribution was an unfair method of consultation.
This document does not fully take into consideration the impact of the JAAP report and the reports for the proposed redevelopment of Hockley, Rochford and Rayleigh.
The stated government policy of using 60% brown field sites first before green field seems to have been reversed, with many potential sites for building being of a green field nature.
If the 175 homes were to be located in one place it will change the nature of the village. We believe it would be better to spread them throughout the Hawkwell area. Consideration should be given to the proximity of shops and schools as due to the lack of public transport additional car usage would result.
That comprehensive consultation has not taken place with ECC, other district councils, local parish / town councils, residents associations and other interested parties in and around our district.
The additional homes will put an enormous strain on the infrastructure of our area, particularly the road system, which has not been addressed in the document.
Loss of Green Belt in our area, which would change our village into a town.
Additional vehicles on the roads from the building of the new homes, the additional residents, their delivery services and visitors and the proposed airport expansion traffic.
Additional demand on our doctors and dentists.
Additional demand on schools and social services.
The number 7 and 8 bus has now been reduced to mainly one bus an hour and there is now no evening number 8 service.
Additional demand on gas, electric, telephone, water, sewers and surface / storm water drainage.
Moving Eldon Way and the Foundry Estate to a green belt site at the airport area will increase mileage for employees and the lack of public transport will limit employment to car users. We believe cycling would be a poor and unrealistic substitute.
ECC have stated that the B1013 is now running at 72% capacity. The Core Strategy proposal would bring the traffic to an unbearable level. No details and estimated costs are given of the many road improvement we believe would be necessary as listed below.
This area is enclosed by the River Crouch, the sea and the Thames and is only properly accessed from the west. For this reason we believe the sensible place to locate additional homes would be in the western part of Rochford district.
We believe that no major infrastructure improvements have been carried out in the Hawkwell area for more than 30 years. We also believe that the following infrastructure improvements in the Hawkwell / Hockley area, that are not included in the Core Strategy document, should be addressed before any additional homes are built:

1. Replacement of Rectory Road Railway Bridge for two-way traffic.
2. Computer controlled traffic lights at the Rectory Road / Hall Road junction.
3. Upgrade Rectory Road and widen road and footpath at the Christmas Tree Farm area.
4. Upgrade the B1013 Hall Road and provide missing and upgrade existing pavements.
5. Proper main road street lighting for the B1013 Hall Road and B1013 Rayleigh Road.
6. A cycle path route from Rochford through Hockley to Rayleigh.
7. A new pelican crossing in B1013 Main Road near Tudor Way.
8. Return to two buses an hour in both directions for the 7 and 8 services between Southend and Rayleigh and the return of the 8 evening bus service.
9. Improvements to all services including gas, electric, telephone, water, sewers and surface / storm water drainage.
10. Increase capacity at all the local Schools in the area.
11. Increase capacity at all the local Doctors and Dentists and hospital services in the area.
12. Increase ambulance, fire and police emergency services.
13. Provide and run a youth club in the Hawkwell area.
14. To provide and run allotments in the Hawkwell area.
15. To extend the existing Cherry Orchard Park to Mount Bovers Lane and Hockley Woods.
16. Replace the existing Hockley Spa roundabout with a wider traffic light junction complete with pedestrian cross lights.
17. Install a double mini roundabout at Station Road and Station Approach junction with Spa Road for Hockley Station.
18. Install a mini roundabout on the B1013 at Folly Lane.
19. Make up / Upgrade Plumberow Avenue through to Lower Road in Hockley complete with pavements, main road street lighting and a mini roundabout at the Lower Road junction.
20. Upgrade Watery Lane / Beeches Road in Hullbridge from Lower Road complete with pavements, main road street lighting and a mini roundabout at the Lower Road junction.

I wish to object on the grounds of unsoundness or legally non compliant due to the following points:

It makes no sense to locate the proposed 175 homes in one of four locations that are all off of Rectory Road, which has an inadequate roundabout at one end and single file under a narrow railway bridge via traffic lights at the other.
Producing a heavy weight document that prevented printing and general distribution was an unfair method of consultation.
This document does not fully take into consideration the impact of the JAAP report and the reports for the proposed redevelopment of Hockley, Rochford and Rayleigh.
The stated government policy of using 60% brown field sites first before green field seems to have been reversed, with many potential sites for building being of a green field nature.
If the 175 homes were to be located in one place it will change the nature of the village. We believe it would be better to spread them throughout the Hawkwell area. Consideration should be given to the proximity of shops and schools as due to the lack of public transport additional car usage would result.
That comprehensive consultation has not taken place with ECC, other district councils, local parish / town councils, residents associations and other interested parties in and around our district.
The additional homes will put an enormous strain on the infrastructure of our area, particularly the road system, which has not been addressed in the document.
Loss of Green Belt in our area, which would change our village into a town.
Additional vehicles on the roads from the building of the new homes, the additional residents, their delivery services and visitors and the proposed airport expansion traffic.
Additional demand on our doctors and dentists.
Additional demand on schools and social services.
The number 7 and 8 bus has now been reduced to mainly one bus an hour and there is now no evening number 8 service.
Additional demand on gas, electric, telephone, water, sewers and surface / storm water drainage.
Moving Eldon Way and the Foundry Estate to a green belt site at the airport area will increase mileage for employees and the lack of public transport will limit employment to car users. We believe cycling would be a poor and unrealistic substitute.
ECC have stated that the B1013 is now running at 72% capacity. The Core Strategy proposal would bring the traffic to an unbearable level. No details and estimated costs are given of the many road improvement we believe would be necessary as listed below.
This area is enclosed by the River Crouch, the sea and the Thames and is only properly accessed from the west. For this reason we believe the sensible place to locate additional homes would be in the western part of Rochford district.
We believe that no major infrastructure improvements have been carried out in the Hawkwell area for more than 30 years. We also believe that the following infrastructure improvements in the Hawkwell / Hockley area, that are not included in the Core Strategy document, should be addressed before any additional homes are built:

1. Replacement of Rectory Road Railway Bridge for two-way traffic.
2. Computer controlled traffic lights at the Rectory Road / Hall Road junction.
3. Upgrade Rectory Road and widen road and footpath at the Christmas Tree Farm area.
4. Upgrade the B1013 Hall Road and provide missing and upgrade existing pavements.
5. Proper main road street lighting for the B1013 Hall Road and B1013 Rayleigh Road.
6. A cycle path route from Rochford through Hockley to Rayleigh.
7. A new pelican crossing in B1013 Main Road near Tudor Way.
8. Return to two buses an hour in both directions for the 7 and 8 services between Southend and Rayleigh and the return of the 8 evening bus service.
9. Improvements to all services including gas, electric, telephone, water, sewers and surface / storm water drainage.
10. Increase capacity at all the local Schools in the area.
11. Increase capacity at all the local Doctors and Dentists and hospital services in the area.
12. Increase ambulance, fire and police emergency services.
13. Provide and run a youth club in the Hawkwell area.
14. To provide and run allotments in the Hawkwell area.
15. To extend the existing Cherry Orchard Park to Mount Bovers Lane and Hockley Woods.
16. Replace the existing Hockley Spa roundabout with a wider traffic light junction complete with pedestrian cross lights.
17. Install a double mini roundabout at Station Road and Station Approach junction with Spa Road for Hockley Station.
18. Install a mini roundabout on the B1013 at Folly Lane.
19. Make up / Upgrade Plumberow Avenue through to Lower Road in Hockley complete with pavements, main road street lighting and a mini roundabout at the Lower Road junction.
20. Upgrade Watery Lane / Beeches Road in Hullbridge from Lower Road complete with pavements, main road street lighting and a mini roundabout at the Lower Road junction.

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.

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.