North of London Southend Airport

We write on behalf of C and S Associates, owners of land which comprises part of the Brickworks site, Cherry Orchard Way, Rochford.

The Brickworks site falls within the proposed area of the London Southend Airport & Environs Joint Area Action Plan (JAAP) and has been identified as an 'area of change' (site i) in the Preferred Options JAAP. Currently the Preferred Options JAAP proposes to designate the site for B1 (offices), and, consequently, to remove its current green belt designation.

Page 89 and Figure 3.1 of the Allocations DPD Discussion and Consultation Document sets out that the extent of land allocated for employment north of London Southend airport will be determined through the London Southend Airport and Environs Joint Area Action Plan (JAAP) and not in the Allocations DPD.

Our clients are happy for the Brickworks site, Cherry Orchard Way, to be allocated through the JAAP process. However, should the boundary of the JAAP area alter at any stage or this document not go ahead for any reason the Allocations DPD will need to be revisited as the area is suitable for development. For example, development of the Brickworks Site will bring many benefits. The site is previously developed land and currently lies derelict and detracts from the surrounding landscape. Redevelopment will enhance the area and enable the clean up of the site which is likely to incur significant costs

We support you in seeking high environmental standards.

The site is bounded to the north by the Noblesgreen Ditch Main River and the Eastwood Brook Main River runs through the site. There are areas of Flood Zone 2 and 3.

Please see our general comments.

The importance of London Southend Airport is recognised with regards its contribution to the areas economic activity, both in terms of aviation and non-aviation employment and provision needs to be made in order to facilitate its growth.

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.

Response of Essex County Council

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

SUMMARY REVIEW OF HISTORIC ENVIRONMENT CHARACTERISTICS

A. Residential Land Allocations

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

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

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

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

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

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

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

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

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

B. Brownfield Sites

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

C. New Employment Land Allocations

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

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

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

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

Objection to 100 new houses either north or south of Brays Lane on the grounds that we are aware already of further planning applications for 550 houses in Rawreth, 500 houses in South West Hullbridge, 500 houses in south east Ashingdon, 175 houses in south Hawkwell and the Coombes Farm Project, then a further large site at Hall Road which is going to include a school, why we need a new school being built when Watermans School only currently has around 40 pupils, does not make sense, surely there is ample capacity for additional children at Watermans. The expansion of King Edmund School is obviously to take in the children from the new housing estates listed above.

Our main objection is the fact that there has not been any recommendations regarding a new road to reduce the traffic which currently uses Ashingdon Road. The above new housing sites would all converge onto the existing road which cannot cope with the volume of traffic as it is.

Additional to all this is of course the expansion of Southend Airport, which we do not object too, we are fully aware that this project will create new jobs, but this also will create even more traffic.

We would welcome a new road to co-exist with the existing shingdon Road to make all our lives a bit easier, but cannot see how you can progress with the above without creating the infrastructure to compliment the projects.

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.