Option E17

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

Development on this plot is highly undesirable as it would almost certainly result in the development of the entire north side of the London Road from the roundabout eastwards. The open aspects of farm land and the semi-rural nature of the area would be totally lost.

I strongly object to this location being used for industrial purposes. This would be an unnecessary loss of agricultural land and would totally spoil the gateway to the town and destroy the views across open country as far as Rettendon church. From the other direction the view of the town including the church and mill would be totally obscured and obliterated. It would increase traffic on the already congested A129 and would create an eyesore on green belt land.

What happened to the 'defensible buffer' for green belt land west of the proposed 550 dwellings? It has gone already!
To place an industrial site in this area would increase the traffic issue already seen on the A129. Heavy lorries could not be restricted from heading through Rayleigh Town Centre and would make the situation on Crown Hill even worse. They would, like the buses do now, find negotiating the mini-roundabouts difficult. The safety issues of encouraging more heavy goods vehicle in Rayleigh Town Centre via a steep hill need to be fully investigated.
The location on the A129 is not a good link to the A130 / A127. Traffic at the A1245 / A127 interchange is slow moving and long queues form due to the lack of Traffic Light control for the Southbound Carriageway of the A1245. There is already considerable congestion at the Hawk Hill interchange without adding more industrial traffic.

Any development here would be visually intrusive and cause severe harm to the Green Belt. There are no defensible Green Belt boundaries. It would involve the loss of good quality agricultural land. Any entrance or exit points to the site would be very close to the roundabout.

I strongly object to this location being used for industrial purposes. This would be an uncessary loss of agricultural land. I am concerned about the increased traffic on the already congested road network and the impact on the primary school and housing estates which are in close proximity. An industrial development would create an eyesore at one of the most pleasant gateways into the town. The views across open countryside extend to Rettendon Church, Rayleigh Windmill and Holy Trinity Church which would be totally obsured. This open countryside in green belt land must be preserved.

I strongly object to this site as it invades the promised green buffer .It is highly productive agricultural land .In these ever increasing food security times which are inevitable productive land must be protected and despoiled land used first .

I object MOST STRONGLY. You state land will be allocated SOUTH of the London Road. THIS IS ON THE NORTHERN SIDE.

This piece of land is wholely and completely within the land supposed to provide a green buffer between proposed houses and the A1245 (NLR1) and to ensure that no further building is done there. This is supposed to be within the "parkland" to be provided.

Residents in Battlesbridge could benefit from new employment opportunities created in this area at E13, 14, 15, 16 or 17. We raise no objections to these although we consider that E17 is too detached from other the existing employment area on the other side of the road.
If all the development (residential, employment and Gypsy and Traveller site) is promoted in the area west of Rayleigh/ south east of Rawreth, the cumulative impact on Battlesbridge would need to be carefully considered. Officers would not want to see any adverse impacts on this existing community.

This area of land has been allocated in the NLR1 to 5 options as the green buffer to stop the spread of housing, how can it therefore be proposed for industrial use

Industrial development here would obscure the pleasant rural views towards Rettendon and increase traffic, particularly close to the roundabout. Greenbelt and agricultural land must be preserved

Background

In accordance with their representations to the Core Strategy, Countryside Properties are supportive of the proposals for the provision of additional employment land to the west of Rayleigh, but we consider that such provision should be made to the north of London Road as part of a comprehensive mixed-use development, not to the south of London Road (or at Michelins Farm).

Representations

In our view, the most appropriate location for new employment development west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. In our original submissions to the Core Strategy, we advanced a number of arguments to support this position, including:

* It is inherently more sustainable in principle to provide for an integrated mixed-use scheme, rather than segregated residential and commercial areas;
* The viability of providing the new employment land is increased as part of a mixed-use scheme, since the costs of infrastructure (including roads, drainage, and utilities) is shared;
* There is more than sufficient land north of London Road to deliver a mixed-use scheme - there is less certainty that the scale of development required could be successfully provided south of London Road;
* To be attractive to new business, a high quality business park of sufficient size will be required - there is more land north of London Road to achieve this;
* There are advantages in terms of public transport accessibility/viability in serving a business location alongside a residential location (greater patronage and two-way passenger flows);
* It is difficult to see how the Green Belt boundary south of London Road could successfully be changed to allow for a large scale employment area, without either creating a ribbon of development along London Road, or an isolated incursion not linked to the existing community;
* Countryside Properties has particular experience in successfully delivering mixed-use schemes, including the creation of modern, flexible business space.

In the light of the above, we do not support the potential employment sites E13, E14, E15, or E16, all of which lie to the south of London Road.

In addition to the general observations above, we note that in relation to the particular sites E13-E16 the following additional points:

* All of these options utilise to some extent of other land already in commercial use. This raises two significant questions: Is the land proposed genuinely available, given the existing uses, and is the land genuinely additional employment land, or simply a replacement of existing jobs?
On the first question, it appears to us that each of these options is based upon land in multiple ownership, and where there are existing businesses/tenancies which together may make the land impossible to bring forward in a comprehensive way.

On the second question, although the existing commercial uses may not be allocated for businesses purposes as such, there are long-standing commercial uses on the site that are an existing source of employment. All four options E13-E16 appear to be premised upon the loss of the existing commercial uses, and therefore any net increase in allocated employment land would need to take in to account the extent of existing land lost.

* Notwithstanding the above, none of the options presented are of sufficient scale to provide for the extent of employment land required under the Core Strategy. The four options vary between a minimum of 2.65 ha and a maximum of 5 ha. The Core Strategy identified a need for 2 ha for office use and 6 ha for the relocation of Rawreth Lane Industrial Estate, making a minimum of 8 ha. In our view (and notwithstanding our concerns regarding practicality), relocating Rawreth Industrial Estate would require more than 6ha - the existing estate is already over-crowded, as the extent of on-street parking demonstrates, allows no scope for businesses to expand, and the existing layout does not provide the quality of environment that the Council would rightly expect (and which new businesses would demand) from a new commercial park.

In our view, around 10 ha is a more realistic land-take for replacing Rawreth Lane Industrial Estate, making around 12 ha of land in total to be found west of Rayleigh to support the employment proposals of the Core Strategy. This scale of development cannot be found south of London Road (or at Michelins Farm).

E17 is the only option put forward to the north of London Road, and clearly therefore on the basis of the above, we feel this option warrants further consideration, albeit in isolation it would still not be large enough to accommodate the full employment land requirement (if Rawreth Lane Industrial Estate is to be redeveloped).

There is however potential to increase the size of site E17, whether by extension to the north (whilst still avoiding areas of flood risk), or by extension to the east, as part of or linking in with the proposed new residential neighbourhood. The potential to integrate with the proposed residential uses is a major advantage of land to the north of London Road, compared to the options proposed for south of London Road.

We note that the description of site E17 states that it is detached from any residential settlement, though it is not clear whether or not this is put forward as a point in its favour or against. It is of course a similar distance to Rayleigh as the most of the options south of London Road, but moreover has the potential to integrate with the proposed new residential development north of London Road, whilst still enabling good access to the highway network for commercial vehicles.

There is no reason why commercial uses should be separated from residential uses, and indeed planning policy at all levels extols the virtues of mixed-used development in sustainability terms. Our view is very strongly in favour of having commercial uses integrated with residential uses as part of a comprehensive mixed-use masterplan, that protects residential amenity whilst still promoting ease of access. Sites that are "detached" should not be favoured over sites that have the potential to create strong mixed-use neighbourhoods.

Turning then lastly to E18, we do not consider this to be a suitable site for commercial development.

Although it may be possible to enhance the existing sub-standard access to the site from the A127/A1245 slip road, the site is removed from the residential communities that the employment would serve, and there is no realistic prospect of accessing the site by public transport or by non-vehicular modes. This is an isolated site in the countryside, accessible only by car, where development would be contrary to advice in PPG13 regarding location of development attracting large numbers of trips and sustainable travel.

As an isolated development site in the heart of the countryside, development here would also have significant adverse impacts on the strategic purposes of the Green Belt, introducing an expanse of commercial development in a highly prominent location between the A127, A1245, A130 and Southend-Liverpool Street railway. This is not development that would be compatible with the retention of the site in the Green Belt, and it would therefore result in a release of Green Belt land in the heart of an area of strategic Green Belt significance.

In summary, in our view the most appropriate location for new employment land west of Rayleigh is to the north of London Road, as part of a comprehensive mixed-use scheme. The employment land provision could include all or part of E17, or alternative locations north of London Road.

There will be a substantial increase in traffic on to the A129 as an access on to the A1245 will not be viable. This is a valuable parcel of Green Belt which should be preserved.

The site is not large enough to make a workable industrial site. There would need to be access for large vehicles and this would not be able on the existing roundabout with the A1245 and the A129 in view of the fact that it is blocked morning and evening with existing traffic. Industrial sites also need unlimited working times. Consideration should be made for noise.

The Carpenters Arms Brook Main River is associated with this site. There are areas of Flood Zone 2 and 3 to the south. Please see our general comments.

Thank you once again for giving your presentation at the Hullbridge Parish Council Meeting on the 12th April 2010.

I have since read through the Local Development Framework Allocations DPD Discussion and Consultation Document and I am writing to give my personal news as follows:

While I have to object on grounds of lack of infrastructure and flooding I have considered the four options and I am giving my preferences.

If this development has to go ahead my first choice would be option SWH1.

My second choice would be SWH3 if the most westerly part could be used for public open space, solving the documents concerns about community cohesion.

I do not like option SWH2 due to the fact Watery Lane often floods. In addition to this there have been great problems with heavy goods vehicles using this road which is unsuitable for them. I fear widening any part of this road would encourage this to start happening again.

I like option SWH4 least of all because of the reasons for my dislike of option SWH2 plus it would be a creeping development towards Rayleigh.

In terms of flooding I think that it would be better to look for available land to the east at Hullbridge which is on higher ground.

With regard to other matters in the document affecting Hullbridge I would like to make the following submissions:

I like option E17 best for employment land.

Please can Kendel Park Hullbridge be added to the list of Wildlife Sites.

I am happy that the document protects Riverside Infants and Junior School (soon to become Riverside Primary). I would like to see further secondary school places added to the document.

I am also very pleased to see Hullbridge Community Association Community Centre safeguarded from development.

I came away from the recent meeting very surprised that the attempts of Rochford District Council to inform residents of this and previous consultations has had very little impact on local residents.

I am sorry if in my capacity of Chairman at Hullbridge Parish Council I have failed to assist you in this. If there is anything I can do to help prevent this happening again. Please let me know.

The proposed employment locations (E13, E14, E15, E16, E17, & E18) are all located within the Green Belt between Rayleigh and Rawreth. There are a number of concerns with this option:
* These locations would be difficult to access by public transport (would be further away from the train station than the existing industrial estate that they seek to replace), which means that it would be in not as sustainable location;
* The locations of new offices in the proposed location would not accord with the locational requirements detailed within the policies of PPS4.
* The proposed employment locations would be in an isolated location (Options E17 & E18 more so), within the Green Belt, which would make it difficult to establish a defensible boundary and also contribute to the coalescence of the neighbouring settlements, contrary to the provisions of PPG2.

As Rawreth Industrial Park is a sustainable location, a better approach would be to redevelop the industrial park with a commercial scheme with a design of unit that is flexible enough to accommodate a range of employment uses.

The idea of de-allocating land in a sustainable location in order that it can be allocated for housing and then identifying new employment sites in less sustainable locations than the existing site is a contradiction.

The preference for future employment and housing provision should be to take a co-ordinated approach to the release of Green Belt land, and the requirements for employment and housing land considered together to limit the potential loss of Green Belt to the most sustainable locations, accessible by a range of means (including public transport), and with defensible boundaries.

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

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

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

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

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

The full details of these surveys are attached.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

RE: ALLOCATIONS AND DEVELOPMENT MANAGEMENT DEVELOPMENT PLAN DOCUMENTS



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



Please find our comments summarized on the attached document.

I am writing with regard to The Allocations Development Plan Document for which the public consultation ends at 17.00 today.

I feel that whilst the consultation period has lasted 6 weeks from 17th March there has been extremely little publicity provided by The Council to ensure that all interested parties have the opportunity to respond.

It would have been a simple matter to include a flier with the Council Tax demands which were sent to all residents at the end of February to provide the relevant information. It is almost as though there has been a deliberate policy to keep the proposals under wraps.

The LDP comes under the East of England Plan of May 2008 from which I quote as follows:-

Overall Spatial Strategy SS2 states:-

"The target is for 60% development to be on previously developed land."

Green Belt Policy SS7 states:-

"The broad extent of green belts in the East of England is appropriate and should be maintained."

Paragraph 3.29 states:-

"The reviews will result in significant change locally but can be made without eroding the principles and overall functioning of the green belt."

Policy T8 Local Roads states:-

Local Authorities should manage the local road network in accordance with their local transport plan objectives to complement the aims of Policies T2 - T7 with the following priorities:-

"tackling congestion and its environmental impacts."

I would therefore suggest that proposals NLR1, NLR2, NLR3, NLR4, and NLR5 do not seem to comply with these objectives.

As a resident who unfortunately needs to use London Road Rayleigh (A129) on a daily basis I find it incredible that there is any proposed development which includes access via this road or indeed Chelmsford Road (A1245). The traffic is generally significant and at certain times totally excessive without considering what would happen if any of these proposals were to be adopted. There are frequent occasions when there is an "incident" on the A127 usually at Rayleigh Weir or Progress Road which means gridlock on that road leading to even more traffic using London Road as a "rat run." Rawreth Lane is also totally inadequate for any additional access without creating even more congestion.

The existing Green Belt and agricultural land would be irrevocably eroded and lead almost certainly to further future adjacent development meaning a complete eventual loss of such land in the area.

Rayleigh and Rawreth would more or less cease to be entities in their own right.

Access to Rayleigh Town Centre would be made even more onerous than currently. This could only lead to the centre becoming even less attractive to shoppers and become more and more run down in the longer term.

I would suggest that the land either side of the A1245 just north of the Rawreth Lane junction be considered. These are both existing brownfield sites with easy access to Battlesbridge Railway Station. Some of the traffic considerations would still apply but should be less onerous than your proposals.

Employment land Options E13,E14,E15,E16,E17.

All of the observations relative to the above Residential Allocation apply but are exacerbated by the fact that most of the resulting traffic would be HGV's resulting in even more congestion and damage to road structure. All in all these options are a recipe for disaster.

Option E18 would appear to be the most acceptable option with the following reservation. Access from this site would presumably need to be on to the A1245 which is dual carriageway. This would necessitate all traffic emanating from the site using the A1245 North up to the roundabout junction with the A129. This junction is already a source of much congestion.

Gypsy/Traveller sites.

Options GT1&2 are both on the site currently there but is this existing site not illegal anyway? I would suggest that enlarging the current site could lead to problems with exiting on to the southbound A1245.

Option GT3 is totally unacceptable given the proximity to existing housing and the access via London Road. Even though there may be a desire by the council to integrate travellers into the local community it is not something that even the travellers themselves wish to happen. Although an obvious statement their chosen way of life means they travel and as such tend to move frequently. This would naturally lead to frequent changes of occupants at the site and make any integration with the community very difficult.

Overall I do not believe that the Allocation DPD (certainly as it applies to Rayleigh West) is in the best interest of the residents of the area and that here will be considerable opposition to many of the proposals.

If there is a change of leadership in the Government on 6th May it is a distinct possibility that the whole East of England Plan will be scaled-down if not scrapped entirely and I certainly hope this is the eventual outcome.

Objection to Traveller Sites GT1, GT2 and GT3. See paper copy for details.

Objection to E17

A1245 and London Road could not take increase and heavy goods traffic;

Loss of Green Belt and

Loss of Agricultural land.

This prominent site presents a considerable frontage along both the A129 and the A1245. Its development for industrial/office use would be extremely detrimental visually. It would also lead to pressure in the future for release of adjoingin/nearby green belt land for development.

I therefore, object strongly to option E17 because it has no merit whatsoever. Development of this site would in the long run mark the beginning of the end for the green belt east of the A1245 in this part of Rawreth/Rayleigh. I am appalled that the local planning authority should even be considering it as an option.