Option WGW3

West Great Wakering 250 Dwellings:

Option WGW3 - (part - land lying to the south of High Street - north-west corner of WGW3) the identification of this land, owned by my client Swan Hill Homes Limited, is strongly supported. The land lies south of the High Street in Great Wakering and is well related to the existing pattern of settlement. To the south the site is bounded and enclosed by the existing fishing lakes and local wildlife site (also owned by Swan Hill Homes Limited). The existing lakes and associated land could be offered for transfer to the Council to provide open space uses as part of the housing development on the SHH land south of the High Street, in accordance with our client's 'Informal Submission' submitted to the Council in February 2007. This would contain the proposed housing development and partially screen it from view from the south.

To the west the site abuts the disused Star Lane brickworks, the Star Lane Industrial Estate and in the far north a telephone exchange. As such the western boundary of the site is well contained by existing built form. To the east, the site abuts a strip of open land running in a north-south alignment (i.e.
Option WGW3 (part)) beyond which lies existing liner housing along the western side of Alexandra Road.

It is therefore clear that the Option WGW1 site is well contained on all boundaries and enjoys a good relationship with the existing pattern of settlement in the village.

Technical studies undertaken on behalf of our client have confirmed that access can be obtained from High Street through land owned by our client and there are no other infrastructure constraints that cannot be readily addressed and resolved.

The WGW1 site, extends to 8.02 ha, has a capacity of around 175 dwellings and is readily available for development and if allocated could be brought forward to supply new housing within 12 months of the adoption of the Allocations DPD. The development would include a range of house types and sizes, including affordable housing. In addition, the development of the site would bring wider benefits to the local community by virtue of transferring the fishing lakes/local wildlife site into public ownership to be used as a local facility and open space resource.

The site was promoted for allocation in the Rochford District Replacement Local Plan, whilst not allocated in the adopted plan the Local Plan Inquiry Inspector noted in his report:

'The site has advantages from its position in relation to the residential and adjacent employment area
if there was a need to allocate Greenfield land for development and to add to the population of Great
Wakering.'

In relation to the Green belt status of the site both the draft Core Strategy and Allocations DPD acknowledge that Green belt land will need to be allocated to accommodate 2,745 additional dwellings up to 2025. Given those circumstances it is necessary to 'test' the impact on the Green belt of each potential site in order to determine which of the Green belt sites would have the least impact on Green belt objectives, in addition to being well related to an existing settlement and sustainable in its own right.

The 5 purposes for including land in the Green belt are set out in paragraph 1.5 of PPG2 Green belts:

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

It is therefore appropriate to 'test' the land south of the High Street against each of the 5 purposes.

To check the unrestricted sprawl of large built-up areas - housing development on the WGW1 site would be physically well contained by existing built form to the north, west and east and by the fishing lakes to the south. As such residential development on the site would not result in urban sprawl and would not therefore conflict with this purpose of including land in the Green belt.

To prevent neighbouring towns from merging into one another - housing development on the land south of the High Street would not cause any risk of the coalescence of any settlements (i.e. towns or villages) and as such would not conflict with this purpose of including land in the Green belt.

To assist in safeguarding the countryside from encroachment - housing development on this site would be physically well contained by existing built form to the north, west and east and by the fishing lakes to the south. As such residential development on the site would not result in any discernable encroachment into the countryside and would not therefore conflict with this purpose of including land in the Green belt.

To preserve the setting and special character of historic towns - this purpose of including land in the Green belt does not apply at Great Wakering. Notwithstanding, because the proposed development is well related to the existing pattern of settlement it would be well integrated with the village and
would also provide access to a new area of public open space including the fishing lakes to the south of the proposed housing site. Access to this area of open space would be provided direct from the High Street along the internal access roads serving the housing development. Therefore the proposed development would be integrated with the village and would improve the availability of useable accessible open space for the community.

To assist in urban regeneration, by encouraging the recycling of derelict and other urban land - whilst the land to the south of the High Street is currently an undeveloped green field site it is, in effect, enclosed on all sides, unused and under-used and its development for housing could make a useful contribution to meeting the district's housing requirement in a sustainable way and in a way which would bring wider public open space and environmental benefits to the local community. In addition, as the site is enclosed on 3 sides by existing development and is un-used and under-used land it would make a contribution, in its own way to the regeneration of the village, either individually or in combination with other adjoining sites (i.e. Option WGW3) and the Star Lane disused brickworks site and the Star Lane Industrial Estate (SHLAA sites EL3 (Appendix D).

In summary it can be seen that the allocation of the land south of the High Street would not conflict with any of the 5 purposes of including land in the Green belt. As such there is a clear case for the land to be released from the Green belt and it does not perform any material or meaningful Green belt function.

Option WGW3 extends from the south of the Star Lane Brickworks and will reduce the openness between Great Wakering and Southend. The proposed site only adjoins the built up area on part of its northern boundary and it is open in aspect to the east, south and west. By virtue of its location it will have a significant impact on the landscape and the openness green belt.

The site also adjoins Star Lane Pits to the north. This is a Local Wildlife Site identified in the Rochford District Local Wildlife Sites Review (2007) which forms part of the Local Development Framework evidence base. The ecological impact of siting development close to this Local Wildlife Site should be carefully considered.

Option WGW3 comprises 3 separate plots. The plot south of the Star Lane former brickworks site is not supported as this would intrude damagingly into open countryside, would be remote from local services, would severely harm the openness of the Green Belt, would fail to provide a defensible southerly or easterly boundary to the Green Belt, and would result in the coalescence of settlements, contrary to PPG2. The remaining plots under WGW3 (i.e north of the Star Lane Industrial Estate and west of Alexandra Road), are both strongly supported for the reasons given in respect of Option WGW1.

Option WGW2, this option has two separate unconnected parcels, which do not follow existing field boundaries so it would be difficult to create defensible boundaries, contrary to PPG2.

Option WGW3, this option has three fragmented parcels around the settlement. Two of the parcels relate well to the existing settlement, however, the largest southernmost parcel is detached from Great Wakering and would extend further south than the existing settlement, very close to the boundary with Southend. This option would not have defensible boundaries and would result in coalescence with the built-up area of Southend, contrary to PPG2.

Option WGW4, this option involves a single parcel to the south of the brickworks, which is detached from the existing settlement and would extend further south than the existing settlement, very close to the boundary with Southend. This option would not have defensible boundaries and would result in coalescence with the built-up area of Southend, contrary to PPG2.

Option WGW5, is located adjacent to the existing settlement but extends further west, which raises concerns with sustainability in terms of accessing facilities and services and the creation of a defensible Green Belt boundary.

The preferred option is WGW1 as this is developed in one location and is close to the High Street, and as such would add to the cohesion of the existing settlement.

Paragraph 5.2 of PPS12 states that DPDs should adhere to the same advice on justification and effectiveness as applies to Core
Strategies. Paragraph 4.36 is particularly cited and this states that the "most appropriate strategy should be adopted when
considered against reasonable alternatives".

It is considered that the emerging DPD does not accord with the advice since some of the options are simply not realistic when
considered against normal land use criteria for selecting sustainable urban extensions. Whilst not necessarily endorsing the strategic location, the following sub options are not seen as realistic and should be discounted

- WR2
- WR4
- WH1
- SC1
- SC2
- SEA2
- SEA3
- WGW2
- WGW3.

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



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



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

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

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

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



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



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



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



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



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



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



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





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



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



The following questions also need to be answered:-



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



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


Where are the existing pitches?



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



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



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



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





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





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





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



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



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



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



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





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



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



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





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



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



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



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



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



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

RE: ALLOCATIONS AND DEVELOPMENT MANAGEMENT DEVELOPMENT PLAN DOCUMENTS



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



Please find our comments summarized on the attached document.

RE: ALLOCATIONS AND DEVELOPMENT MANAGEMENT DEVELOPMENT PLAN DOCUMENTS



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



Please find our comments summarized on the attached document.

The Lakes (Public Open Space)

Improve the access from Exhibition Lane to cope with prams and pushchairs etc.
Create some grassed areas and a play are for small children to play.
Regenerate the small lakes and improve the swims.
Create a new access road to the existing parking area.
Enlarge and improve the existing car park.

Industrial Estate.

Relocate to the south and enlarge a little.
Use land for housing

Existing Brickworks

Use for housing.

Field south of brickworks

Use for housing.
Create a barrier of green between the Industrial Estate and the New Housing.

Problems

How will the existing school cope with the influx of children from the new estate?

There is already a problem with parents transporting their children to and from school at the moment, how will the area cope with a considerable increase of traffic in the surrounding area?

Google map supplied, see paper copy for details.