Stambridge Mills

Stambridge Mills is within a flood zone. Residents of any future development would have difficulty obtaining household flood insurance. With the ever rising levels of the flood plain, this must be a primary consideration when planning residental developments.

By building on brown field sites the environmental impact of development would be lessoned.

As a local resident, I agree that the old Mill site would suit a limited housing development, subject to care regarding the flood plain. Too many dwellings would cause traffic problems on Stambridge Road and more particularly Rochford town centre, due to the limited road size/capacity. Increased noise from the proposed airport expansion, might also put off potential buyers. I hope that development of this site would not increase the likelihood of the Coombes Farm land being released. We need our green spaces in Rochford!

Stambridge Mills page 56: This site is said by RDC to be deliverable in the next 3 years. It is located within flood zone 2 and 3 of the River Roach and must be subject to sequential testing as per PPS25. It has been acquired by Inner London Group who specialise in local authority partnerships, healthcare, key worker and other homes provision. However, there are no proposals for the site via a planning application or a site allocation.

Suitability - The Environment Agency claim in their objection at to the Submission Core Strategy, that the site is in a flood zone 3. PPS25 expects the sequential test to be carried out. The test is that it must be demonstrated that there are no reasonably available sites in areas of lower flood risk probability that would be appropriate to the type of development proposed. Stambridge Mills fails as a consequence since the site allocations document includes many other site development options that are sequentially preferable.

The Environment Agency object in the Core Strategy Examination that the site cannot fulfill the Exception Test in their submissions on the Core Strategy. Rochford Dc maintain that it is a site that is exceptionally required. However, in PPS25 policy terms it should not be necessary to move to the exception test as part of the assessment since there are more acceptable sites elsewhere which are sequentially preferable. If it were necessary to move to the exception test it would be only appropriate to accept development in Flood Zone 3 if there was a clear sustainability benefit taking into account the need to avoid social and economic blight. Stambridge Mills has a severe visual impact but that is not relevant. The aim of reducing the impact on the Green Belt is also irrelevant in the context of the PPS25 sequential approach. Stambridge Mills is separated from the built up area of Rochford by open agricultural fields designated as Green Belt. There are no sustainability reasons for encouraging the development of high density housing in this location. The site cannot integrate with the residential area and most journey's would be by car. Stambridge Mills is separated from the nearby main employment area to the south by the water course. PPS3 and the preference for brownfield land is not cart blanche for all brownfield sites to be brought forward irrespective of the environmental harm and this is noted at paragraph 38 and reinforced at paragraph 41 of PPS3. Stambridge Mills should not be included as a development option and reference of it should be removed.

Stambridge Parish Council supports this site as being suitable for housing allocation.

The site is located within Flood Zone 3 and is physically remote from the existing urban area/nearest settlement including public transport network. The redevelopment of the Mill would be contrary to PPS3 and PPS25. There are alternative sites available in the District that are sequentially preferable and are also more sustainable. The Council's evidence base does not support the use of the exceptions test in this instance. The site is neither developable or deliverable for housing. This objection is supported by the Environment Agency.

Whilst I accept this is a brownfield site and therefore potentially less damaging as a site for housing development, I fear this would be the first step to developing the coombes farm area and the impact this would have both on the environment, local residents and infrastructure. Consideration should also be given to the potential flood issues of a site so close to a tidal river.

Background

Both the Core Strategy and the Site Allocations DPD identify Stambridge Mills for re-allocation to residential uses. For the reasons set out in the submissions made by Countryside Properties to the Core Strategy (re-iterated below), we do not consider that the site is necessarily suitable, desirable or deliverable for residential development. We consider that the site can remain as an important source of local employment, and this should be reflected in both the Core Strategy and the Site Allocations DPD.

Representations

The Council will be well aware of the objections made by various parties to the Core Strategy proposal to redevelop this site on Flood Risk grounds. We do not consider that the exceptions test in PPS25 is passed in this case, since there are options for development on land outside flood zone 3 (we do not agree with the approach put forward by the Council in Core Strategy Topic Paper 1, that defence of the Green Belt is an adequate rationale to build homes on land at risk of flooding).

Even if an exception can be justified under PPS25, 250 homes at a density of just under 140 dph is a very high density for a site in such a relatively remote and unsustainable location (page 120 of the Core Strategy gives the site area as 1.8ha). It is difficult to see how this intensity of development is justified, when the recommended density for town centres is only 75+ dph.

If retained, therefore, the quantum of development proposed needs to reflect the relatively isolated and unsustainable location of the site.

Stambridge Mills lies within Flood Zone 3a and is justified on the basis that this is sequentially preferable to green field sites which lie within Flood Zones 1 and 2, on the basis that PPG2 sets out that development is inappropriate in the green belt.

However, paragraph D5 of PPS25 sets out that:

"Only where there are no reasonably available sites in Flood Zones 1 or 2 should decision-makers consider the suitability of sites in Flood Zone 3..."
There are clearly other sites available in Flood Zones 1 and 2 and these should be considered sequentially preferable.

On its own, Stambridge Mills is divorced from Rochford and would represent an isolated development.

The allocation of Stambridge Mills for residential development is strongly supported. The site is identified as an appropriate location for residential development under Policy H1 of the Core Strategy Submission Document. It is considered that the approach of prioritising the re-use for housing of previously developed land is sound. It is consistent with PPS3, will reduce the need to release Green Belt land, and will allow for the removal of contamination, the re-use of existing on-site materials, and the environmental and ecological enhancement of the site and its surroundings.

The site is available, suitable and achievable, as required by PPS3. It is in the single ownership of the Inner London Group (ILG), and is available for immediate redevelopment subject to the need for planning permission and site clearance. Alternative industrial use would not be viable or environmentally acceptable. Residential development will comply with wider sustainability objectives through the retention and conversion of various existing structures at the site, and the re-use of on-site materials for the construction of the improved flood defences. It will also contribute to the supply and choice of new homes in the Rochford area, will reduce pressure for the release of Green Belt land, and will offer substantial visual amenity benefits. A strongly defensible Green Belt boundary will be achieved. The site is also located within reasonable distance of the retail, employment and service facilities in and around Rochford town centre. As part of the proposals for the site, ILG intend to offer a package of accessibility enhancements including footpath and bus service improvements.

ILG have prioritised the site for development. The emerging proposals have been the subject of supportive feedback from the Inspire East Design Review Panel. Natural England has also been fully consulted, and has confirmed that the proposals do not give rise to any substantive objection on ecological impact grounds.

The site lies within Flood Zone 3a on the Environment Agency (EA) Flood Maps, and current flood defences in the vicinity do not provide adequate long-term protection for the site or the adjoining care home and residential uses. As required by PPS25, a Flood Risk Sequential Test has been undertaken (both by ILG and by the Council). The Council has confirmed that the Sequential Test has been passed.

ILG have engaged in detailed and constructive discussions with the EA relating to the resolution of flood risk issues arising at Stambridge Mills, and have commissioned specialist advice on flood protection matters, and a full Flood Risk Assessment (FRA) has been submitted to the EA and the LPA.

Although the site is currently at risk from flooding, it is proposed that its development will be accompanied by substantial new flood defence works, and the raising of all residential accommodation above the 1 in 200 year flood level. The detailed design of these defences has been agreed with the EA. A significant aspect of the proposed strategy is the benefit provided to the wider community. The combination of improving the existing defences and constructing counter-walls to higher ground will not only protect the proposed development and ensure dry access is maintained in times of flood, but will also protect Broomhills Care Home and residential properties on Mill Lane. In addition, the proposed defences will protect Stambridge Road from flooding; this road provides an important transport route to the villages to the east of Rochford.

Having satisfied the Sequential Test, the Exception Test has been applied, and can be readily passed. Criterion a) is complied with because the scheme will reduce the need to release Green Belt land to meet housing needs, and will offer the opportunity for a substantial enhancement of the landscape in the area immediately to the east of Rochford. The re-use of existing resources, and the removal of contamination, will also bring about clear-cut sustainability benefits for the community. Furthermore, the scheme will offer specific benefits to existing residents in the immediate area through the improvements to existing flood defences. Criterion b) is complied with because the site constitutes previously developed land in its entirety. Furthermore, the site meets the PPS3 definition of "developable" . Criterion c) will be complied with because the FRA demonstrates that the proposed improvement and extension of the existing tidal flood defences will render the development safe from flooding, will not increase the risk of flooding elsewhere, and will provide enhanced protection from flooding for the existing care home and other residents in the vicinity of the site. Discussions with the Emergency Services, relating to issue of safe access and egress in the highly unlikely event of the breach of the flood defences, are ongoing.

The allocation of Stambridge Mills is therefore consistent with the requirements of PPS3 and PPS25, and is fully supported.

We have commented on this specific site as part of our representations to the Rochford Core Strategy. We have nothing more to add to those representations and the further representations made to the Inspector.

Please see our previous response to the Core Strategy and also our general comments to this DPD.

Stambridge Mills has very restricted road access and any addition to the traffic load having to exit via East and South Streets Rochford should not be considered !

This is an existing employment site, which is in a fairly isolated location within the Green Belt and as such it would be difficult to create a defensible boundary if this site is developed for residential.

In addition, this site is subject to a high risk of flooding (Zone 3), and its redevelopment for residential would replace a less vulnerable use (employment) with a more vulnerable use (residential).

The preference would be to safeguard the site for employment and see it redeveloped for light industrial use.

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

1 INTRODUCTION:

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

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

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

2 RESIDENTIAL:

West Rayleigh

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

West Rochford

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

West Hockley WH2

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

South Hawkwell 175 dwellings

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


SH3 or SH4

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

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

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

South West Hullbridge 500 dwellings

Option SWH1 is probably the least damaging.

South Canewdon 60 dwellings

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

South East Ashingdon 500 dwellings

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

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

Rawreth Industrial Estate

It is possibly better relocated and replaced by housing.

Stambridge Mills

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

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

Eldon Way/Foundry Estate

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


Gypsy and Traveller site locations

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

3 ADDITIONAL EMPLOYMENT LAND:

West Rayleigh E18

Seems the most suitable because of its Highway location.

South of Great Wakering

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

4 ENVIRONMENTAL ALLOCATIONS:

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

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

5 COMMUNITY FACILITIES:

Education

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

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

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

Open Space

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

Community Facilities

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

6. TOWN CENTRES:

Rayleigh Town Centre Option TC1

Existing town centre boundary to be maintained.

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

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

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

Option TC12 Rayleigh

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

Rochford TC13

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

Hockley TC15

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


7 OTHER ISSUES AND NEXT STEPS:

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

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.

Response of Essex County Council

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

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

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

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

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

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

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

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

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

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

B. Brownfield Sites

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

C. New Employment Land Allocations

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

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

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

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

Suggest a new development in West Rayleigh to accommodate Rochford's housing allocation should be provided in a new village to take advantage from the highway network of A127, A130 and A1245 where all the infrastructure can be provided in a phased manner without compromising existing settlements.

Various comments received, for further details see paper copy.

Rochford Site Allocations DPD

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

Section 2: Residential

Residential Land Allocations

North of London Road Rayleigh

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

West Rochford

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

West Hockley

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

South Hawkwell

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

East Ashingdon

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

South West Hullbridge

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

South Canewdon

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

South East Ashingdon

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

West Great Wakering

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

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

Brownfield Sties

Stambridge Mills

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

Section 3 Economic Development

Additional Employment Land to be Allocated

West of Rayleigh

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

Michelins Farm

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

London Southend Airport and Environs

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

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

South of Great Wakering

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

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