Do you agree with the areas identified in EDU1-19?

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

Sport England is supportive of protecting the district's schools from development as they provide many facilities that meet the wider needs of the communities where they are located as well as the needs of individual schools. In particular, schools provide indoor and outdoor sports facilities that make a major contribution towards meeting community needs. Consequently, there protection is justified especially if supported by an evidence base such as a playing pitch assessment which demonstrates the role that such facilities play in meeting community needs.

All of these existing educational facilities need to be protected from development that would undermine their important function, planning must allow them to develop appropriately where required and allocation of land for these existing educational facilities must be ensured.

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.

Various questions and comments received.

For further details see paper copy.