NLR - Should other sites in this location be considered?

Only sites with existing industrial useage should be considered for residential development.

Smaller developments in these locations should be considered. To make up the resulting shortfall in the necessary number of dwellings that would result from this smaller sites from other areas around the edge of the current residential envelope should also be considered thus avoiding the need for huge new estates which will have a huge impact.

NLR 1-5 I cannot understand why building in flood zone 3 ihas been put forward, with regard to safe access and ingress, sequential test, transport, schools, and sustainability. What is very conscerning is, WHY ARE THESE SITES BEING CONSIDERED??.

When I trace the Site information Proforma information on other good sites they have not all been completed, therefore it is an unfair playing field. WHY IS THIS??

Here we have too many houses , additional traffic in one area,

This area could be extended further to the west without objections from many neighbouring housing. Its location would provide better road links than other areas

We object to the current residential allocations as we are not convinced that these are the most suitable sites for housing in accordance with Planning Policy Statement 3 (PPS3) Housig 2006. There are other sites which are equally if not more appropriate for residential development and these should be considered in place of some of the current options or as well as. This will enable a flexible approach to the delivery of housing and ensure that the Council meets its housing requirements.

Within the options for West Rochford, the Council acknowledges for Options WR2, WR3 and WR4 that the sites do not 'afford a good opportunity for the creation of a strong defensible green belt boundary'.

Appendix 1 refers to Land to the Rear of Southview Close (Call for Sites Allocations 43) and although this highlights that the site is well related to Rayleigh town centre and services it states that the site would not contribute towards a balanced approach to housing and there is a need to avoid the coalescence of Rayleigh with Eastwood. However, we disagree with this conclusion and would like to reiterate that land to the rear of South View Close is in a sustainable location, within walking distance of local schools, public transport and close to Rayleigh Town Centre, employment locations and other local amenities. The site does not clearly contribute to the five functions of including land within the Green Belt as set out in Planning Policy Guidance 2 Green Belts January 1995. The release of this site for housing will not lead to the unrestricted sprawl of large built-up areas. There is a stream running across the site which creates a natural barrier and could become the defensible boundary to the Green Belt, unlike the sites referred to above. The release of this site would therefore not undermine the Council's approach of protecting the town's identity and preventing coalescence with Eastwood. This land can contribute to housing units by 2015.

The Allocations Development Plan Document should therefore include South/South East Rayleigh as a general location with land to the rear of Southview Close allocated for housing.

The huge development of 550 houses should be allocated throughout the District much more fairly. To put this amount of housing here destroys the character and openness of the area - again part of your Policy.

Background

Countryside Properties have control of some 98 ha of land to the north of London Road, Rayleigh, which it is seeking to bring forward to meet the development proposals set out in the emerging Rochford Core Strategy (alongside adjoining owners, as appropriate).

Notwithstanding the matters of detail raised in these submissions, Countryside Properties are committed to working with the District Council towards the successful delivery of these proposals.

Over-Arching Representations (All Site Options)

The Site Allocations DPD sets out 5 potential land parcels on the western side of Rayleigh north of London Road, ranging from 23ha to 29ha, as possible locations for accommodating the 550 houses, primary school, youth/community facilities and play space proposed in the current draft of the Core Strategy. We assume the proposed Public Park would be accommodated on land outside the identified parcels, but with some open space accommodated within the allocated area (as implied by the notation used to describe each area in the published document).

In common with the representations made by Countryside Properties to the Core Strategy, there are we consider some important points to bear in mind in respect of all of the options being put forward, being:

(1) Flexibility - The need for flexibility in the area to be allocated, to cater for lack of delivery elsewhere and to reflect the fact that the proposed allocation is a "minimum";
(2) Site Area - Delivering even the minimum level of development as currently set out in the Core Strategy will require a greater land allocation that the Site Allocations options imply; and
(3) Long-term Green Belt boundary - In allocating new development land and amending the Green Belt boundary, the Site Allocations document will be setting a new, long term defensible Green Belt boundary, and under the terms of PPG2, this will require consideration of both potential development needs in the post-Plan period, and consideration of the most appropriate Green Belt boundary.

Before turning to consider site specific matters, we set out our comments on the above points more fully below.

(1) The need for flexibility

Countryside Properties have highlighted in their representations to the Core Strategy the requirement in PPS12 for Development Plan documents to have flexibility, in order to respond to changing circumstances. Also highlighted was the fact that the RSS housing requirement is a "minimum", and that all strategic site allocations need likewise to be considered as a minimum if the requirements of the RSS in this respect are to be enacted at the local level.

The definition of the specific land allocation at the Site Allocations stage needs to have regard to that strategic context. It needs to ensure that there is sufficient flexibility within the allocated area to respond to potential changes in development requirements over the Plan period, including the possibility that additional land for housing (or indeed other development needs) may need to be delivered.

(2) Site Area

Even without the requirement for flexibility, we do not consider that the Options put forward have fully considered the land-take required for the scale of development envisaged.

Within the allocated area, there will be a requirement not only to provide the number of homes specified, but also to deliver the highway infrastructure necessary to serve the residential use, to deliver the appropriate social and community infrastructure necessary to support the housing proposed, the associated open space and strategic landscaping, and the drainage infrastructure and sustainable drainage systems necessary to create the quality of residential environment that both Countryside Properties and residents will expect to see.

We also note the requirement in the Core Strategy to provide additional employment land to the West of Rayleigh. For the reasons set out in our representations to the Core Strategy, and set out in our response to the site options presented in the Site Allocations DPD, the additional employment land proposed should be located north of London Road as part of a comprehensive mixed-use scheme.

In our experience of creating successful new residential and mixed-use communities, it is essential not to under-estimate the land required to deliver a quality scheme. In particular for and edge-of-settlement location, integrating a structural landscape framework to 'green' the environment and achieve a successful transition between town and country is essential.

The land west of Rayleigh is relatively free of physical or environmental constraints, but that does not mean that any Masterplan for the site can ignore such features as do exist - there is a public sewer, some specific areas identified as being at flood risk, the potential for existing sports pitches to be retained, the potential need for a buffer to the existing Rayleigh Industrial Estate (assuming it does not relocate), a nearby Listed Building, and existing trees and hedgerows. Any Masterplan will need to be sensitive to these existing features, even if they do not pose significant constraints, and this will inevitably have an impact on the disposition of development and therefore land-take.

At net residential densities of between 30 and 35 dwellings per hectare, 550 residential units would require around 16-18 ha. Allowing a ratio of 60% built area to 40% landscaping, formal open space, incidental open space, children's play space, and green routes (cycleways/pedestrian ways), would produce a gross housing area of 27-30 ha.

The provision of a primary school and other youth/community facilities could equate to around a further 2.0 ha (including parking and servicing etc). We note the site specific requirements for the primary school set out on page 110 of the document, and clearly these could impact on the extent of land required in practice.

Strategic road infrastructure (including bus priority measures) alongside appropriate surface water drainage would equate to around a further 2 ha (a spine road providing bus access at Rawreth Road and linking to London Road could have a distance, avoiding a straight route, or around 1.4km).

Even if no employment land is provided north of London Road, and even assuming no more than 550 residential units, the minimum land-take for the proposed development would in our view be in the order of 30ha, but more likely in the order of 35ha.

(3) Long Term Green Belt Boundary

The Site Allocations DPD provides the mechanism not just by which a specific land allocation will be made to meet the immediate development requirement set out in the Core Strategy, but also by which the long-term, defensible Green Belt boundary will be re-set. PPG2 provides the relevant guidance, and paragraphs 2.8, 2.12 and Annex B are particularly relevant.

Paragraph 2.8 notes that if boundaries are drawn excessively tightly around existing built-up areas, it may not be possible to maintain the degree of permanence that Green Belts should have, and that such an approach devalues the concept of Green Belt and reduces the value in Plans making proper provision for necessary development in the future.

Paragraph 2.12 in respect of Safeguarded Land confirms that any proposals affecting Green Belts must relate to a longer timeframe than for other aspects of the Plan, i.e. in this case, beyond 2025. There is a positive requirement (as opposed to an optional choice) on Local Planning Authorities to address the need for Safeguarded Land when reviewing Green Belt boundaries, and there is a need to be certain that Green Belt boundaries will not need to be reviewed at the end of the Plan period. The RSS provides a strategic context for this consideration, since H1 makes clear that the same rates of provision should continue after 2021.

There is currently no reference in the Site Allocations DPD to the issue of the revised Green Belt boundary, but under the provisions of PPG2, the immediate land release and the long-term Green Belt boundary are not one and the same issue.

There are exceptional circumstances arising from the RSS development requirement to review the inner Green Belt boundary, but this should be a one-off review that re-establishes a permanent Green Belt for the future, which is capable of accommodating development requirements beyond the Plan period without needing to change. Irrespective therefore of whether or not the Core Strategy identifies a need for more than 550 units at West Rayleigh now, the revised Green Belt boundary should be capable of accommodating more than 550 units, should a need for additional units come forward either within the lifetime of this Plan, or beyond this Plan, to provide the permanence that PPG2 requires.

We feel the Site Allocations DPD needs to address the revised Green Belt boundary explicitly, and set out a proper consideration of the alternative options, having specific regard to the requirements of PPG2, including the need for safeguarded land.


Site Specific Representations (All Site Options)

It follows from the matters raised above that we do not wholly agree with any of the 5 options put forward in the Site Allocations DPD.

We agree that all of the 5 sites have potential for development, but given our comments above regarding likely land-take, we consider that a combination of the sites put forward, together potentially with additional neighbouring land, is likely to provide the right solution at the detailed master-planning stage.

In terms of some specific observations, we would offer the following:

* We do not disagree with the Council regarding the potential desirability of achieving a 'through' public transport route between Rawreth Road and London Road;

* There is a reference under several of the options presented to the need to avoid development in land at risk of flooding. Clearly we agree with the need for development to avoid flood risk areas, which in reality affects only a very small proportion of the site, and a sensible approach to Masterplanning will ensure that flood risk does not impose a constraint on the new development, and that there is no risk to existing development. The need to address flood risk and sustainable drainage within the scheme does however add weight to our argument that the size of the site allocation does require some flexibility, if the Masterplan is to be able to respond positively to existing site features (including but not exclusively flood risk);

* We do not consider that the existing pylon line forms a logical boundary to the development area. As we have set out in submissions elsewhere, these pylons can be re-laid underground (in whole or part, or take a new alignment) and therefore should not be regarded as a determining factor, either on site selection or Masterplanning;

* We do consider that the Core Strategy proposals for additional employment land west of Rayleigh should be accommodated to the north of London Road, as part of a comprehensive mixed-use scheme - we address this matter further in our representations on the employment land options;

* Finally, we note the reference to using a "Public Park" to provide a buffer between any future built development and the A1245. Countryside Properties agree that any development will need to provide appropriate open space, and that there may well be opportunities for greater public access and a Park between the built development and the A1245. This is a substantial area of land, and we do have some concerns that the reference to "park" may imply a substantially landscaped and formal area of open space. We are also unclear as to the extent of land which the Council might be considering for inclusion in the "park". In our experience, access to the countryside is an important source of informal leisure activity, and therefore retaining part at least of this land in agricultural use (perhaps with improved access) may provide both a better 'green' buffer and a greater recreational resource than an (underused) formal "park".

In terms of the individual options, our preliminary comments would be as follows:

* NLR1 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints, is suitable for residential development, and is deliverable. In isolation, it is not of sufficient size, nor does it have the benefit of a frontage to London Road, which it is assumed at this stage will be the primary point of access;

* NLR2 - This site is constrained by flood risk, and in isolation has no suitable access. It is not a realistic option for development, except as part of a wider scheme.

* NLR3 - This appears to be a logical area for inclusion as part of an allocation - the land is generally free of physical and environmental constraints (assuming the pylons are laid underground or diverted), and it is likely that the principle point of access to London Road will lie on this part of the frontage to London Road. The site is not of sufficient size on its own, and also would not provide for a public transport link to Rawreth Lane, and therefore we assume this site would need to form part of a more comprehensive allocation.

* NLR4 - Our comments in relation to this land are largely the same as for NLR1 - a minimum of physical/environmental constraint (small area of flood risk), but a developable and deliverable site. It is not large enough in isolation, and does not have a frontage to London Road where we assume the primary access will be taken. It appears as if the western boundary is based on the line of the pylons, but as stated elsewhere in our representations, we do not consider the pylons to form a logical boundary to the development area.

* NLR5 - Our comments in relation to this land are largely the same as for NLR4 - although this option does have a frontage to London Road, it would necessitate disruption to the existing playing fields, and we feel that there are better options for accessing London Road. Again, the site is not large enough in isolation.

To Whom It May Concern

I am writing to you as I strongly object to the proposed plans to build a further 550 houses on what is currently green belt land and an additional 220 on the Rawreth Industrial Estate.

Rayleigh has seen a surge of new houses built in the last 20 years, particularly in West Rayleigh and the Rawreth area, whilst there may have been a need for this, the promise of additional amenities has never materialised into anything more.

Our schools are oversubscribed; doctors and dentists have long waiting lists; and traffic and parking in the area is horrendous. Not to mention the fact that our children have nowhere to play safely anymore.

If these proposals go ahead and these houses are built, the existing and new properties are likely to be affected by flooding. There will be nowhere for the water to run; some houses in the area are already affected by this.

Employment in the area will also be affected. With the impending closure of Eon on London Road as well as HSBC in Southend, there are an additional 1000 unemployed people now looking for work in this area. How is bringing more people into the area going to help reduce the unemployment figure?

I believe that green belt land should be left exactly that. There isn't enough farmland and countryside left in this area, and once building works start it may not stop.

I understand the reasons why the Rawreth Industrial Estate needs moving, pollution, noise etc but for the same reasons I do not believe that by moving them to London Road this problem will be solved.

Some of the suggestions that have been raised previously include using the land on the junction of the A1245 and the A127. This is further away from residential areas and schools therefore a safer option for residents and less traffic congestion as well as providing easier access to the main roads.

With regards to the 550 new houses, maybe the site on the A1245 would be a better choice as it will not affect the green belt land but be built on what is currently brown belt land.
When making this decision, please seriously consider the impact on the current community and surroundings; and ensure ample facilities are provided time.

To Whom It May Concern

I am writing to you as I strongly object to the proposed plans to build a further 550 houses on what is currently green belt land and an additional 220 on the Rawreth Industrial Estate.

Rayleigh has seen a surge of new houses built in the last 20 years, particularly in West Rayleigh and the Rawreth area, whilst there may have been a need for this, the promise of additional amenities has never materialised into anything more.

Our schools are oversubscribed; doctors and dentists have long waiting lists; and traffic and parking in the area is horrendous. Not to mention the fact that our children have nowhere to play safely anymore.

If these proposals go ahead and these houses are built, the existing and new properties are likely to be affected by flooding. There will be nowhere for the water to run; some houses in the area are already affected by this.

Employment in the area will also be affected. With the impending closure of Eon on London Road as well as HSBC in Southend, there are an additional 1000 unemployed people now looking for work in this area. How is bringing more people into the area going to help reduce the unemployment figure?

I believe that green belt land should be left exactly that. There isn't enough farmland and countryside left in this area, and once building works start it may not stop.

I understand the reasons why the Rawreth Industrial Estate needs moving, pollution, noise etc but for the same reasons I do not believe that by moving them to London Road this problem will be solved.

Some of the suggestions that have been raised previously include using the land on the junction of the A1245 and the A127. This is further away from residential areas and schools therefore a safer option for residents and less traffic congestion as well as providing easier access to the main roads.

With regards to the 550 new houses, maybe the site on the A1245 would be a better choice as it will not affect the green belt land but be built on what is currently brown belt land.
When making this decision, please seriously consider the impact on the current community and surroundings; and ensure ample facilities are provided time.

Dear Sir
With regards to options NRL1, NRL2, NRL3, NRL4 and NRL5 we have lived on the London Road for 29 years. During that time we have seen the completion of the Little Wheatley Estate and its extention, the 'Bird' Estate and a development at the top end of Victoria Avenue. We are now faced with continuous traffic and severe hold-ups each morning and evening with not a lot of let-up during the day. If any of these developments go ahead there will be an additional 500+ cars trying to get to Rayleigh either through London Road or Rawreth Lane with the same result - gridlock!!
I understand there are 'brown' sites north of Rawreth Lane which have been offered by Rawreth Parish Council. Why can this not be a viable proposition?
Why does it appear to be that every housing development for Rochford District Council has to be placed west of Rayleigh?
The plans show a light industrial estate on the London Road and our objections regarding traffic are as above. A site adjacent to the A127 and A1245 has been suggested and this would surely be a better solution.
If there has to be a travellers site in the area can it not be amalgamated with the illegal one that is near Rawreth Lane on the A1245.
the final thought on this is that you are taking agricultural land which is needed and where will we be once it has all gone?
Trust you will consider our feelings on this.

To whom this may concern

Following review of construction planning for the Rayleigh area I wish to object in regards to building on green fields between London Road and Rawreth Lane.and in respect of small scale travellers sites options GT1, GT2, GT3 and GT7.

I understand the need for additional housing in the local however to consider building on green field sites is not a viable option - loss of these sites will create a green belt which will be, over time diminished until no such belt exists.

I note that there are two areas of land which have good access to Battlesbridge Rail station which are deemed as brown field sites. These areas should be considered above all other areas for development.

Also, I am hearing conflicting information in regards to the NPower Building on London Road. I understand that this is deemed to be 'commercial' land however if and when NPower do vacant, the site should either be demolished and transferred to residential use or demolished and smaller commercial units (restricted to ground and one upper floor) to be used for offices / light industrial only.

New modern employment land is needed, agreed. Surely common sense is that this is developed on the plot of land near the A127 with the best road connections (with A127 and A13) otherwise the A1245 and in particular London Road around the Richlee Motor Garage will become even more congested. This area of land I understand at this time is used for tyre storage - it seems every other day there is a fire on site belching black smoke across the roadways.

A travellers site on the A1245 (old A130) would be most viable option for small scale development on a quality scale which meets the needs of the traveller community. A site on London Road would add to further congestion and perhaps to some less open minded locals would not be welcoming at all to potential new residents.

My family and I moved to Essex (Rayleigh) six years ago from London, and have been very happy. We moved like most families for a better way of life, although we have now heard that some of that happiness is going to be spoilt due to plans to have the following built:

- AN INDUSTRIAL ESTATE

- NEW HOUSES

- TRAVELLERS SITES

The Industrial estate will surely cause more traffic along what is already a really busy road!

More houses will also create more traffic, and when in the past new houses have been built no more local facilities (drs, schools, shops) were built!

Surely there are other sites where travellers can be sited!

Lastly surely land that is not green should be build on first? There is some land that is close to Battles bridge Rail Station that could be used!

I therefore would like to make my above concerns heard, and that the items listed should not go ahead.

Thank you for your time in reading this

I am writing to strongly protest about the planned building of 550 new homes on agricultural green belt land north of London Road, Rayleigh.

I believe, once we encrouch on these areas we will loose our unique (and cherished) identities as individual communities and end up as one large cosmopolitan area merging Rayleigh, Rawreth and Wickford. There are other options.

I believe the proposal to re-locate the Rawreth Industrial estate and make the site a residential area makes absolute sense as this site is next to a current residential area. The re-employment of the Industrial estate to the junction of the A1245 and A127 being the most practical option. I would suggest that the current EON site, which will no longer be in use after June 2010, could also be redeveloped into a residential site as this currently sits within a residential area. The previously used land on the A1245 in Rawreth is also an option.

Within Rayleigh itself, for every one house that is demolished three or four are erected in its place. In the past the council have justified this by stating that it will help avoid having to use green belt land to meet housing requirements. Another concern is the impact on the current infrastructure. Can our roads, railway station, schools, doctors, dentists cope with such a large number of additional residents?

Given the above, I do not believe the council are justified in proposing housing development on the green belt.

With regards to the Traveller/Gypsy site and new housing proposals. We object to your proposals. Why built on green belt, playing fields and flood plain. Disrupting peoples lives when it is unnecessary

Having failed to evict the travellers from the site at the junction of Rawreth Lain and the A1245 why not make that one legal and find a smaller site outside Rayleigh to for fill requirements. Or does Rayleigh get what Rochford doesn't want?

The Industrial Site could be situated on the junction of the A127 and A1245 this area is already an industrial area and would give good road links for companies . As a bonus this would clean up this site which looks like a tip.

The houses could be built on brown land adjacent to the A1245 which Rawreth Parish Council says can be used and it would accommodate all the housing required.

Additional site put forward land to the rear of 122 to 130 Rawreth Lane.

For further information and plan see paper copy.