Rochford Core Strategy Development Plan Document - Schedule of Changes

Whilst I am in favour of preserving sensible areas of green belt, there are some insignificent pieces of land still designated as green belt in Hawkwell which would be ideal for several affordable 3 bedroom homes without infringing on neighbours. There are many families in Hawkwell whose children wish to buy or live in homes near their parents. At present they have to move out of the area when they marry. I object to the rather dramatic phrase, 'intensification of smaller sites will be resisted, but limited infilling will be acceptable'. What are these definitions please.

Important to keep up employment opportunities

RE: Core Strategy Allocation Development Plan and Structure Plan

I wish to register an objection to the Hockley Parish Plan and the large-scale housing developments proposed in Hockley and the release of Green Belt/ Open Spaces.

My prime objection is to the release of any Green Belt within the Hockley area and the redevelopment of Hockley Town. It is clear that the residents of Hockley would prefer Hockley Town to be downgraded to a Village. There is no desire of the residents for any expansion of Hockley and specifically the redevelopment of the Town Centre.

With regard to the proposed expansion of residential dwellings and the release of Green Belt within the Hockley area, I write to voice my strong objections both on grounds relating to the loss of countryside, wildlife habitat and amenities for local residents, whether accessible or purely visual. The latter being significantly overlooked in planning terms but in reality being one of the most important Planning issues.

Pond Farm Nurseries, Folly Lane, Hockley
The proposal to develop this site is wholly unacceptable and unreasonable. The Local Authority has defended the release of this site from Green Belt for many years and indeed, on one occasion the Council almost bankrupted themselves in the High Court defending an appeal. To release this site now would make a mockery of all previous decisions and a total disregard of Council Tax payers' money in the previous defence of this Green Belt area.

The addition of any further traffic entering Alderman's Hill from Folly Lane, particularly during the rush hour, would result in gridlock. Already traffic is often backed up as far as The Gattons and on occasions, if there are road works, removal lorries, or any minor disruption on Aldermans Hill, by The Spa or either Greensward Lane and Main Road, Hawkwell, traffic often backs up as far as Hambro Hill. Similarly, evening traffic is as bad. Without improvements to the infrastructure I cannot believe that the Local Authority would consider releasing any Green Belt where traffic will enter Aldermans Hill, Greensward Lane or Main Road, Hawkwell.

In relation to the undeveloped part of Pond Chase Nurseries (Hockley West 1), I would advise that this land has remained virtually untouched for many years with only occasional human presence for the maintenance of some of the land surrounding the ponds. The two ponds are a haven for wildlife (one or which is currently being filled by the owner) with regular duck flights, kingfishers and herons. The pond is also inhabited by Smooth Newts, Palmate Newts and Great Crested Newts. This section of land also helps provide a corridor virtually through to Hockley Woods from the crouch for wildlife to travel.

The south facing slopes of the rear section of the site are a breeding ground for slow-worms with good populations of slow-worms being present throughout the site and in the neighbouring gardens. The ageing oak trees provide bat roosts and nesting grounds. There is a pair of Tawny Owls currently nesting on the site. This small area of lightly wooded ground and the adjoining densely wooded ground is a haven for wildlife. There are badgers' setts on both sites. The importance of this land to the local wildlife population cannot be ignored.

The proposed release of green belt in the structure plan is unacceptable and any pressure from central government to expand the housing numbers in the Borough must be strongly resisted. We are approaching a general election and there is a strong likelihood there will be a change in government and a change in policy. It is therefore essential, at this time, not to revise the Structure Plan in line with flawed Central Government policy.

It was clear from the meeting at Greensward Academy that the population of Hockley do not want any further expansion of the housing stock within the area. This is not NIMBY-ism this is a simply conclusion based on the realities relating to the infrastructure in the area and the realisation that any further expansion of Hockley is likely to significantly change the character of the "Town" forever. It is this character and feeling that Hockley is still a Village that makes it attractive to the people that live here.

As Planning Officers, you like Councillors are Public Servants employed to protect the interests of the residents of the area as far as planning issues are concerned. Expansion of the housing stock in Hockley does not in any way serve the interests of the residents. The development of Pond Chase Nurseries would cause the loss of jobs not an increase in the number of jobs (due to Pond Chase Nurseries currently being "a mini industrial estate" as well as a mushroom farm). The businesses occupying the premises at Pond Chase Nurseries would have to move from the area, taking the jobs with them. This will not serve the interest of the community, local shops and businesses.

I agree that the number of homes to be built should be reduced as Rochford is not a big town and the facilites such as the Rochford town square are limited and not well equipped enough to accomodate lots of new homes. I do, however, believe we should keep our green belt land as green belt and not allow it to be built on and over developed.
I would also like to suggest a leisure item; that a children's playground with swings and slides etc. is built in the park next to the Rochford Reservoir.

According to the figures, Rochford and Hulbridge are still taking the bulk of the housing. There is no decrease from the original figure of 500 before the changes, which means most of these properties will have to be built on Green Belt land. The previous objections have not abated, ie: Flooding around Watery Lane area, generating far too much traffic in and out of the village, which already comes to a standstill at the end of Ferry Road during the school run. There are plenty of brownfield sites in and around the village that can be used.

Ref: Page 29-30.
There is insufficient housing stock now. The councils proposal to slow down new builds, and also not address the type of housing required does not appear to meet the needs of residents satisfactorily as it stands at present.
The current approach seems to be to have as many flats as possible densely packed together with minimal parking provision, and little other types of accommodation such as bungalows.

Ref: Page 39-40.
Will the council be taking a more reasonable approach to planning on the green belt designated areas now?
I think it is sensible if land is in a 'green belt zone' but it is not suitable for agricultural use (i.e it was formally used for industrial purposes rendering it unsuitable for agriculture, or its location or size makes it un-commercial to farm etc.) then it should be considered for say low density housing. This will increase the housing stock, prevent scrub/waste land being formed, reduce the pressure to build on quality farm land, and reduce the need to have so much high density housing built.

we object to any development,s within the area, re the village infastructure would not be suffice to such changes, all amenaties can barely offer a satisfactory service to people now, to use the old stick with the carrot, re more investment and amenaties gives a false sence regarding this matter, as you must be only to aware we are in resession, worldwide, and is it not the case that the government say to expand and spend more is clearly not the way forward, cut cut cut well surely this must apply here, there are no fund,s except those who will exploit this for their own financial gain and not be around to see the aftermath. Expand and develope the amenaties firstly school,s to be built,transport both public @ private, hospital,s are the next to be hit by the government cuts school,s have had their redevelopment funding withdrawn, with what funds are the local authoraties going to back these project,s

it is crazy to go this distance into the future and beyond what Prescoott wanted, if we keep legislating to build on greenbelt land eventually we will live in a concrete jungle and the beauty of the area will be gone forever, I say DO NOT ALLOW ANY BUILDING ON GREEN BELT, and certainly not the ridiculous amount of homes proposed.

I think that with some common sense there would be enough brown field areas which could be used.

Quote "As part of a flexible plan, monitor and manage approach, and reflecting the figures as maxima, the Council will adjust the numbers on the table in response to changing housing supply requirements. "

Sorry but the above rings alarm bells to me, it is vague, where's the upper limit?! It basically makes the listed figures irrelevant and leaves the way open for an unknown quantity of housing.

The plan to build a certain number of new houses (175) on green belt land in South Hawkwell is not feasible. You cannot expect to squeeze new houses into an area already saturated, with existing infastructure strained to its limits. These new housing numbers are target driven rather than a common sense planning approach. The recent planning application refusal by the Secretary of State which recognised what a disaster it would be to build a large number of houses concentrated in an area that is not accessable. This provides council with guidelines to reject any further similar applications.

We wish to register the following objections regarding the above consultation:
1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated; are contrary to government policy and alternatives not evaluated. There is no justification for this variance from government policy.
* There is no evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?
* Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites but the amended proposals still result in 67% of new dwellings being on greenbelt land (and any windfall sites will be too late to save green belt that has already been built on).
* The two proposed new industrial sites will also be on Green Belt land.
* The older component of our population is said by the Council to be a block on the release of "previously owned homes" but there are no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/Wardened Flats for over 55′s).

2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard. This lack of consultation and inconsistency means the proposals are unsound.
* There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
* Have the alternatives been properly evaluated and evidenced?

3. Lack of appropriate infrastructure and the distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and sustainable?

4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
ï‚· There is no evidence that the consolidated impact of all the various developments on highways has been assessed and no consideration appears to have been given to mapping highways improvements to the housing phasing. Access road improvements in the West have been delayed until end of programme, resulting in road chaos for years.
ï‚· As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments.
The highways plan is unsound and not sustainable.

5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter or a combination of both. It is wrong for the Core Strategy to only consider Flovial flood risk. The Core Strategy is therefore unsound.

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
ï‚· Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
ï‚· The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
ï‚· In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.

7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. Revised proposals have now been made on aspects covered by the DPD. Similarly, proposals for Hockley Village Centre have been repeatedly rejected but are still included. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.

I wish to register the following objections and comments regarding the above document:
1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from government policy.
* Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release. This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.
* The older component of our population is said in the Council Paper to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.
* The two proposed new industrial sites will also be on Green Belt land.
* There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?

2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
* There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
* Have the alternatives been properly evaluated and evidenced?
This lack of consultation and inconsistency means the proposals are unsound.

3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?

4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
ï‚· There is no evidence that the consolidated impact of all the various developments on highways has been assessed.
ï‚· Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.
ï‚· No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.

5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.
ï‚· Aviva Insurance were not content with the Environmental Agencies evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
ï‚· An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring reguarly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Flovial flood risk.
The Core Strategy is therefore unsound.

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
ï‚· Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
ï‚· The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
ï‚· In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.

7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.

1. Proposals to build on the Green Belt have not been properly evaluated; are contrary to government policy and alternatives not evaluated. No justification for this variance from government policy.
2. No justification or consultation regarding how proposed total of 3,800 new homes has been calculated.
3. Lack of appropriate infrastructure and the distributed approach negates economies of scale.
4. Development proposals for first phase are concentrated in centre of the district where infrastructure cannot cope with existing traffic
5. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited.

Why is it necessary to state Parish specific locations of development in the CS when that is the purpose of the Site Allocations, why not state the area of the district i.e, North, Central etc.,
Stating specifics so far out as 2031 allows for profiteering by land developers, also it is not consistent with the Key Diagram as changes to infrastructure (roads) are not specific.
The evidence base has not been updated to reflect the changes to government policy.
There is no changes to the councils strategy or evidence base to reflect the changes in the countries economy let alone the districts.

We wish to register the following objections and comments regarding the above document:
1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from government policy.
* Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release. This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.
* The older component of our population is said in the Council Paper to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.
* The two proposed new industrial sites will also be on Green Belt land.
* There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?

2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
* There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
* Have the alternatives been properly evaluated and evidenced?
This lack of consultation and inconsistency means the proposals are unsound.

3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?

4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
* There is no evidence that the consolidated impact of all the various developments on highways has been assessed.
* Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.
* No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.
* No consideration has been given to the impact on the road infrastructure by the proposed London Southend airport development which assumes Passenger numbers of 2000000 by the year 2020 plus significant increased freight movements. It is totally unrealistic to assume, that the increased traffic movements will not significantly impact the road structures of Hockley, Hawkwell, Ashingdon and Rochford.

5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring reguarly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Flovial flood risk.
The Core Strategy is therefore unsound.

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
* Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
* The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
* In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.
* The Government has made it clear that councils must make savings. Development of Gypsy sites should be given very low priority in the current economic climate against other council services. The changes do not consider this.

7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.

Policies H1 and H2 recognise the importance of ensuring the supporting infrastructure, particularly for larger sites, is comprehensively planned. However, Appendix H1 is vague in defining what level of highway capacity or public transport improvements would need to be provided before a particular development would be allowed to proceed. The policies should explicitly require the comprehensive plans to demonstrate that proposed infrastructure and service improvements are sufficient to ensure no reduction in the amenity available to existing residents and that those responsible for delivering the infrastructure are committed to delivery.

Rochford District Residents is a Registered Political Party

Wistaria Cottage
Englefield Close
Hawkwell
Essex. SS5 4LE

Mr. Shaun Scrutton
Head of Planning and Transportation
Rochford District Council
Council Offices
South Street
Rochford
Essex. SS4 1BW

Dear Mr. Scrutton

Public Consultation

Have your say on changes to the Core Strategy

The revocation of the East of England Plan has provided an opportunity to reconsider the Submission version of the Core Strategy.

Since then the "Cala Homes" case has been determined by the Courts.

This is my personal analysis of the position in Rochford District vis a vis the decision of the Courts for Cala Homes and, presumably, Colonnade, who named RDC into their action.

* The amendment to the Core Strategy represents, we were told by RDC at Full Council , was a real REDUCTION in the number of houses that were to be imposed under the RSS Housing Targets.

* The authority for the change or rather REDUCTION by RDC was cited as the revocation of the RSS in the Statement sent to the Planning Inspector in July.

* So if the authority for the change is not lawful yet then so is the proposition for the changes which are now being consulted upon.

* The publication of a Bill changes nothing, such changes can only lawful on Royal Assent and this will not be before the end of the Consultation (30 November 2010) or the beginning of the re-opening of the Public Examination which the Planning Inspector has indicated will be in January 2011.

* Technically it must be UNSOUND if the Amendments are considered by the Inspector before Royal Assent because conceivably in a democracy and the fragility of an untried Coalition the Bill may not be approved in the passage required through both the Commons and the Lords.

Mills and Reeve are a respected planning law firm.

Please consider my comments above in the light of their publications below.

http://www.plan-it-law.com/2010/11/cala-homes-dclg-reaction.html

http://www.plan-it-law.com/2010/11/cala-homes-restore-regional-spatial-strategies.html

I believe that much of what is said supports my own view in the particular context of RDC's current Consultation and it being within the process and period of a Public Examination.

In any event from the significant number of critical, objecting representations from professional developers, landowners and residents (stakeholders) both in Consultations and at the Hearings it was hoped that the amendment to the Core Strategy (CS) at this stage would fully respond to these concerns and change the CS in many significant ways.

The expectation for significant change is further evidenced from the Council itself !!

"Whilst the Government imposed numbers identified in the East of England Plan for Rochford were informed by consideration of projected need and demand, though accepting that Rochford is not an appropriate location for housing growth, it is not clear that full account was taken of the relationship between Rochford District and surrounding areas (particularly within the same housing market area), concerns with regard to sustainability, and the array of environmental and physical constraints the District is subject to. This point is further emphasized in the findings and conclusions in draft RSS31, which proposed a reduced annual provision for Rochford." [Source: Portfolio holder written briefing to Hockley Parish Council, October 2010]

(There is no formatting on the Council's online consultation system so I will have to extract pertinent phrases to create the necessary emphasis so that the Council and the Planning Inspector can follow the point being made.)

"it is not clear that full account was taken of the relationship between Rochford District and surrounding areas"

This is evidence that a further full evaluation of the housing needs for the district was necessary to determine the total housing quantum required.

All the Council has done is essentially undertaken a review on the back of an envelope and just spread that total over a longer period without any acceptable evidence.

I recall that the Planning Inspectorate in guidance has reminded Inspectors that upon revocation of the RSS that Councils must still provide appropriate evidence to substantiate any amendments to the CS.

This was the reason that Councillor Hoy and I asked Council by Motion on 27 July to commission a local housing needs study.

This was rejected by Council citing that the evidence from the TGSE studies was to be relied upon and no additional study was necessary.

In the motion particular reference was made to the assessments of affordable housing in the SHMA 2008 and 2010 required for the district. Both the 131 pa and 196 pa assessments have now been rejected by the Council in favour of 60 pa.

Having read the Topic Papers and supporting studies prepared by the Council for the Planning Inspector I cannot see that there is acceptable evidence that the SHMA figures should be rejected and neither is there any acceptable evidence that the chosen figure of 60 will meet housing needs for affordable housing.

For these reasons the amendments to the CS are UNSOUND.

There is further evidence that I would wish to bring to the Council's attention which confirms that the Council's view that the Submission version of the CS even prior to amendment was UNSOUND. None of these concerns have been addressed in the amendment.

"Essex County Council commissioned Planning Consultants "Tribal" and "Tym & Partners" to carry out a sustainability study as part of their evidence base to EERA the result of which is unequivocal.

They said "With respect to the RSS Scenario", that is the one that we are working on now, "The sub area would struggle to deliver this, the problems would therefore only increase for the NHPAU range". Risk of flooding, risk of coalescence, heavy peak time congestion on rail lines, there are no sustainable transport options for any level of growth, even at RSS. Not my words but a statement direct from the experts." [Source: Portfolio holder written speech to Rochford District Council, 9 September 2009]

Whilst this undoubtedly is aimed at the previous proposed extension of 250 per year from 2026 to 2031 (now 190 pa and no growth) I contend that the warnings about "Risk of flooding, risk of coalescence, heavy peak time congestion on rail lines, there are no sustainable transport options for any level of growth" states that there were sufficient concerns from the Portfolio Holder about these factors that one might expect to see special consideration in the original CS and the amended position. I contend that the line between acceptable to unacceptable based on the difference between 250 and 190 pa cannot possibly be that sharp and defined and that these concerns show that the Submission version of the CS was already UNSOUND.

"It is clear to me that we do indeed need more homes, more jobs, more infrastructure, more of everything; I am however not comfortable with the statistics that we have had thrust upon us. That is my one and only concern."

This was said in the context of "A Conservative Government will abolish regional planning, revoke all regional spatial strategies (including regional building targets) and repeal the National guidance that relates to regional planning thus returning power to Local Communities."

To emphasise I would draw your attention to "I am however not comfortable with the statistics" and "That is my one and only concern" in the context of revocation of "all regional spatial strategies (including regional building targets)"

That is further evidence that the Council considers that the evidence behind the CS is UNSOUND.


I have the following additional reasons why the CS remains UNSOUND at this amendment.

1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy.


There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways.

a) Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release.

b) This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.

c) The two proposed new industrial sites will also be relocated to Green Belt land which in itself is the only way that any significant brownfield will be allocated for housing development. This is not a true release of brownfield because it is a policy which is a thinly veiled cynical sham. Adjusting the real position for this means that, effectively, 89% of all development proposed in this CS is on green belt.

d) The Locations East Ashingdon and West Rochford fall within the highest classifications of Agricultural Land, Grades 1 & 2.

e) A map showing agricultural land classification is available on page 61 of the Strategic Environmental Assessment Baseline Information Profile.

f) As such each have protection under PPS 7, paragraphs 28 and 29.

g) 28. The presence of best and most versatile agricultural land (defined as land in grades 1, 2 and 3a of the Agricultural Land Classification), should be taken into account alongside other sustainability considerations (eg biodiversity; the quality and character of the landscape; its amenity value or heritage interest; accessibility to infrastructure, workforce and markets; maintaining viable communities; and the protection of natural resources, including soil quality) when determining planning applications. Where significant development of agricultural land is unavoidable, local planning authorities should seek to use areas of poorer quality land (grades 3b, 4 and 5) in preference to that of a higher quality, except where this would be inconsistent with other sustainability considerations. Little weight in agricultural terms should be given to the loss of agricultural land in grades 3b, 4 and 5, except in areas (such as uplands) where particular agricultural practices may themselves contribute in some special way to the quality and character of the environment or the local economy. If any undeveloped agricultural land needs to be developed, any adverse effects on the environment should be minimised.

h) 29. Development plans should include policies that identify any major areas of agricultural land that are planned for development. But local planning authorities may also wish to include policies in their LDDs to protect specific areas of best and most versatile agricultural land from speculative development. It is for local planning authorities to decide whether best and most versatile agricultural land can be developed, having carefully weighed the options in the light of competent advice.

i) Where in evidence did the Council obtain "competent advice"? In the absence of this two Locations must be removed from the CS and as such it is UNSOUND.

j) The older component of our population is said in the Council Paper presented on 14/10/10 to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.


2. No justification or consultation regarding how the proposed total of 3,800 new homes been calculated. The Council turned down a motion from two Members in this regard.

There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.

3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?

4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.

a) There is no evidence that the consolidated impact of all the various developments on highways has been assessed.

b) Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.

c) No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.

d) The Core Strategy only takes into account Flood risk identified by the Environment Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.

e) Aviva Insurance were not content with the Environment Agency's evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.

f) An additional point that is not captured by either the Environment Agency or Aviva is there is no need to report flooding occurring regularly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Fluvial flood risk.

g) The Core Strategy is therefore unsound.

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.

a) Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.

b) The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities local community would transpire.

c) In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.

7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the Council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.


Sincerely


Councillor John Mason
Party Leader
Representing Hawkwell West Ward

I wish to object to the building of 3800 new homes by 2031. Shortly after the General Election Eric Pickles, Communities Secretary, stated that the East of England targets would be abolished, and Planning would be in the discretion of the Councils.

Rochford District Council do not have to adopt the Regional target. They are at liberty to produce a study based on local needs only, which would markedly reduce the number of homes to be built.

Eric Pickles has now said he wants homes to be built all over England, and the Government will pay to the Councils the equivalent of Council Tax for every home built. (Thus for every new home the Council receives two lots of Council Tax). This may translate into Councils not building receiving less central grant from the Government.

Notwithstanding this 'bribe' Rochford District Council should reflect the people's wishes, and produce a core strategy based on local needs, not on mass migration from London. To do otherwise is undemocratic, particularly as no mention of the building programme was mentioned in the Conservative Manifesto. Also in the Guidance for Local Planning Authorities following the revocation of Regional Strategies the Chief Planning Officer states that Local Planning Authorities should reflect local people's aspirations. It also states that the Government is committed to the protection of the Green Belt.

The arguments against such a mass building programme are substantial. England is now the most densely populated country in the EU apart from Malta. The South-East simply has no further room. France has four times the space with a similar population. 2800 homes are to be built on Green Belt. Planning Policy Guidance 2 says Green Belt should only be built on in exceptional circumstances, and that Green Belt should be permanent. Inspector Christine Thorby rejected the Colonnade Appeal because of harm to the Green Belt, and did not take into account the Rochford Core Strategy, as it was only a draft document.

There is no corresponding infrastructure for these new homes. Our roads are already badly congested. Southend Hospital now does not have the Maternity Ward facilities to cope. There are not local jobs available. Health Care and Schools could not begin to cope with 3800 new homes. There are no plans to build new hospitals, schools or health Services. There is no money. Our current national debt is £1 trillion, and there are no prospects of recovery for a generation. In a drought our water may be in short supply. Our social cohesion will also be badly affected by such mass development. We have no more room!

In short this prospect of 3800 new homes is madness, and condemns our children and grandchildren to congested misery.

There cannot be exceptional circumstances to build 2800 new homes on Green Belt in Rochford District when local people are overwhelmingly against it; and where because of the density of the population, let alone the parlous state of the country's finances, there is no prospect of corresponding infrastructure. In short there is no more room!

In The Guidance for Local Planning Authorities following the revocation of Regional Strategies the Chief Planning Officer states that Local Planning Authorities should reflect local people's aspirations. The local people do not want these homes!

I am a solicitor - advocate well versed in court procedure involving oral examination. It would give me an opportunity to emphasise and amplify my representations seeking change.

I am pleased to learn that fewer dwellings are to be built as this was a worry to me bearing in mind the impact on infrastructure. The 'plan, monitor, manage' approach is an excellent idea, as is obviously targetting brownfield sites initially.

However, the revision of the Green Belt boundary is of concern and i would very much appreciate it if you could keep me informed when the new boundaries have been decided upon. I would also like to know what Gypsy and Traveller sites are decided upon.

Thank you for your letter of 18th October 2010 and your email notification of the proposed changes to the Core Strategy. Having perused the proposed changes we would really appreciate some clarification and guidance, important to us as a Land Trust, prior to making representational comments on the changes as requested.

Points for clarification

1. We refer to Councillor Lucas-Gill's press statement which aptly highlighted the current, acute deficit of available land for affordable housing (see copy attached).

2. Councillor Hudson, Portfolio Holder for the Core Strategy has stated that the total allocation of greenbelt land for the next twenty years will only be one percent of the nine tenths Green Belt land within the Rochford District. It has also been stated that the drainage and triple road junction of Lower Road, Watery Lane and Hullbridge Road currently needs redesigning, in conjunction with the proposed new development. Under the proposed changes it appears that these much needed improvements have been deferred until 2026-2031.

Acknowledging the years of planning and consultation work, we consider it is only reasonable and fair that the Council should more clearly identify the actual sites in this locality, selected from the Preferred Options for future development, before compromising our Trust to possible unnecessary time consuming representations.

With all due respect, we would appreciate hearing your considered response regarding the above somewhat misleading and contradictory statements.

We look forward to hearing from you. Please note our new Email address if preferred.

I HAVE ALREADY MADE MY FEELING KNOWN THROUGH THE LOCAL RESIDENTS QUESTIONS/ANSWERS DOCUMENT WHICH I AM AWARE ARE IN YOUR POSSESSION. HOCKLEY DOES NOT HAVE THE INFRASTRUCTURE TO SUPPORT MORE HOUSES

Hockley and Hawkwell are 'lumped' together as one but are seperate and different areas.
Alternatives to use of Green Belt and gardens have not been evaluated contrary to Government policy.
The figure of 175 houses for Hawkwell to include 60 affordable houses has never been properly explained.
Likewise no justification for the 3,800 homes across the District.
Infastructure issues have not been addresed.
Impact on highways has not been properly assessed.
No explaination as to how the CS would deliver social, economic and environmental benefits to.
Preferred Options provide only one variation of one site for Hawkwell and all on Green Belt.

RDC should respond to the 941 representations that were made on the core strategy (Sept - November 2009), and not ignore the representations made by the public. RDC have also submitted a document entitled Statement of community involvement as part of their evidence base.
Page 10, box 3 is this is entitled "How the council will encourage the involvement of all communities in planning". It says:
- Providing feedback as to how people's views have been taken into account and have influenced the decision making process.
- Having officers available to speak to during office hours who can provide information and answer questions on planning.
Not one word of the draft core strategy was changed as a result of the 941 representations that were made before it was submitted to the secretary of state. RDC have also produced a document entitled "consultation statement" as part of their evidence base. Not one of the 941 representations made are responded to in this document either. The inspector has indicated that it is for RDC to respond to representations made, not the inspectorate. RDC has indicated that it will not respond to the representations that have been made either.
The core strategy that has been submitted to the secretary of state has not been developed by RDC using their own statement of community involvement policies and is therefore unsound.
Providing RDC with feedback on this document appears to be a completely pointless exercise as RDC will not provide a response. What is the point of spending our local council tax encoraging the local community to contribute only to ignore the feedback that has been provided? I have raised this as a formal complaint with RDC.
I believe that RDC ignoring the representations that have been made is a disgrace, and makes a mockery of any fine words detailed in the statement of community involvement. RDC have produced a plan that they want, and will implement it, regardless of any representations that are made by the public. Local democracy in action.

I agree that there is a requirement to some green belt land to build the housing that is required. I do not agree that the core strategy represents the best way of acheiving this. George Orwell himself could not have created a finer example of double speak in action. Preffered locations, deemed as the most sustainable, regardless of the fact that vast amounts of concrete are to be laid onto the green belt before a single home is provided, regardless of the fact that other green belt sites exist where this would not be the case. Large financial investment will be required for the "preffered locations" to make them suitable (providing essential services, removing pylons, making good flood plains etc) rather than considering sites where existing infrastructure can be re-used without the need for this massive (largely unquantified) investment. Productive agricultural land is deemed as the most suitable location, as opposed to gardens in the built area. A low number of massive expansions to the residential envelope of our towns are preffered but this supposedly does not result in additional urban sprawl, will not result in the merging of Rayleigh and Rawreth, is prefferable to using a larger number of smaller "green belt" sites around the edge of settlements. They exist, I know because I submitted one for RDC's consideration. The planning department decided to visit it 1 day AFTER the draft strategy was released for public consultation. Hows that for evidence that all alternate options have been explored!
The emperor has no clothes. The secrets out. Job well done!

Core Strategy Consultation Oct/Nov 2010
I/we wish to register the following objections and comments regarding the above document:

1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from government policy.
- Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release. This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.
- The older component of our population is said in the Council Paper to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.
- The two proposed new industrial sites will also be on Green Belt land.
- There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?

2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
- There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
- Have the alternatives been properly evaluated and evidenced?
This lack of consultation and inconsistency means the proposals are unsound.

3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?

4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
* There is no evidence that the consolidated impact of all the various developments on highways has been assessed.
* Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.
* No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.

5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring reguarly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Flovial flood risk.
The Core Strategy is therefore unsound.

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
* Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
* The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
* In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.

7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.

Core Strategy Consultation Oct/Nov 2010

I/we wish to register the following objections and comments regarding the above document:

1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from government policy.
- Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release. This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.
- The older component of our population is said in the Council Paper to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.
- The two proposed new industrial sites will also be on Green Belt land.
- There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?

2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
- There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
- Have the alternatives been properly evaluated and evidenced?
This lack of consultation and inconsistency means the proposals are unsound.

3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?

4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
* There is no evidence that the consolidated impact of all the various developments on highways has been assessed.
* Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.
* No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.

5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring reguarly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Flovial flood risk.
The Core Strategy is therefore unsound.

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
* Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
* The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
* In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.

7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.

We have lived in Hockley for 40 plus years and moved within its boundaries 6 times. Up to recent years we have enjoyed living in this village. We have followewd the recent proposals for building new homes with puzzlement. Why use the precious green-belt sites, when brown-field are available and how will the out-dated road system cope?
We are concerned that the local shops and services are running down and once lost, who knows whether it could be turned around?
We have read the following with care and consider that it sets out not just our concern, but the concerns and questions and objections that people, our neighbours, are experiencing.

Please listen to the people who live in Hockley and consult us, we know the problems we foresee.

I/we wish to register the following objections and comments regarding the above document:

1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from government policy.
- Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release. This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.
- The older component of our population is said in the Council Paper to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.
- The two proposed new industrial sites will also be on Green Belt land.
- There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?

2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
- There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
- Have the alternatives been properly evaluated and evidenced?
This lack of consultation and inconsistency means the proposals are unsound.

3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?

4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
* There is no evidence that the consolidated impact of all the various developments on highways has been assessed.
* Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.
* No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.

5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring reguarly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Flovial flood risk.
The Core Strategy is therefore unsound.

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
* Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
* The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
* In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.

7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.

I/we wish to register the following objections and comments regarding the above document:

1. The Core Strategy is unsound because proposals to build on the Green Belt have not been properly evaluated and are contrary to government policy. There is no sufficient justification for this variance from government policy.
- Para 4.23 of the published Core Strategy states that the Council will prioritise the redevelopment of brownfield sites to minimise green belt release. This is still not the case in the amended proposals under consultation, which results in 67% of new dwellings being sited on greenbelt land and any windfall sites will be too late to save green belt that has already been built on.
- The older component of our population is said in the Council Paper to be a block on the release of "previously owned homes" and yet the Council has no proposals to release the blockage by requiring the provision of smaller homes in developments like Coachman's Court (Rochford, Sheltered/wardened Flats for over 55′s). If this were part of the Core Strategy then much less green belt would need to be released.
- The two proposed new industrial sites will also be on Green Belt land.
- There is no actual evidence that the Council has undertaken a comprehensive and detailed (in planning terms) comparative assessment of the impact of the CS Locations, in that they are identified for places of housing growth, in terms of the impact on green belt, the effect on the landscape and highways. Were the alternatives put forward under the "Call for Sites" properly evaluated and evidenced?

2. No justification or consultation regarding how the proposed total of 3,800 new homes has been calculated. The council turned down a motion from two members in this regard.
- There is now no proposed development proposed for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38 page 30), the greatest demand for housing is in Rayleigh at 44.4% of the District's total. There is something wrong here.
- Have the alternatives been properly evaluated and evidenced?
This lack of consultation and inconsistency means the proposals are unsound.

3. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing 'back of a fag packet' [RDC/ECC quote] estimates of £50-75M are unsubstantiated (and could increase) but still equate to £14/21K standard charges per dwelling. Is this viable, particularly for "Affordable Housing" and the plan sustainable?

4. Development proposals for the first phase are concentrated in the centre of the district where the infrastructure, based on historical country lanes, cannot cope with existing traffic - there are a number of bottlenecks across this part of the District and being systemic in nature will not be improved by the relatively small improvements provided by the developments proposed.
* There is no evidence that the consolidated impact of all the various developments on highways has been assessed.
* Proposed phasing will focus initial developments in the centre of the district (Hockley/Ashingdon/ Hawkwell/Rochford) but delay access road improvements in West of district until end of programme resulting in road chaos for years.
* No consideration appears to have been given to mapping highways improvements to the housing phasing. As with other environmental issues, the capacity of the highways network should be assessed formally with consideration of the cumulative effects of other developments. The highways plan is unsound and not sustainable.

5. The Core Strategy only takes into account Flood risk identified by the Enviromental Agency which is flovial based (tidal) and does not take into account Surface Water flooding risk. This is despite the fact that majority of flooding in the area has been caused by the latter and a combination of both.
* Aviva Insurance were not content with the Environmental Agencies evaluation they conducted their own that included Surface Water and number of claims for an area. This was because flooding was and still is a major concern to their revenue stream so they needed to identify properly all types of flooding risks.
* An additional point that is not captured by either the Environmental Agency or Aviva is there is no need to report flooding occuring reguarly in a field, only local people know about this. It is wrong for the Core Strategy to only consider Flovial flood risk.
The Core Strategy is therefore unsound.

6. Gypsy sites - the proposals provide for 14 pitches by 2014 but no indication is given of where these should be sited. This issue has caused a lot of concern to many residents who favour a single, manageable site in a location with good road access and all appropriate services and the proposals are unsound and, probably, unsustainable.
* Gypsy/Traveller sites must be positioned in locations that have the best access to transport links and services. It is essential that any gypsy/traveller site developments are matched by appropriate infrastructure such as established road networks, water / gas / electric supply, mains sewerage, access for refuse / recycling collection, and access to healthcare and schools.
* The choice of a suitable site(s) must ensure that such communities can be appropriately integrated, and promote the right level of community cohesion for these people. Inappropriate location of Gypsies and Travellers would not bring about desired cohesion, and if a poor choice is made by the Council this could lead to exactly the opposite and disharmonious relationships between communities and the local community would transpire.
* In the light of the above, and in line with previous recommendations, if it is decided that Gypsies and Travellers must be accommodated on 'official' sites, then such sites are best suited to the west of the district. Any loss of countryside, greenbelt and open spaces in and around Hockley is considered unacceptable when there are known alternative locations that would be better suit mutual Council and Traveller needs.

7. The last consultation on the DPD Allocations was in April and is believed to have 'attracted' a record level of responses but has not even been considered by the council 6 months later. This reflects the generally inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently the proposals are unsound.

I wish to register my protest to Rochford District Council`s proposal to allow the building of an additional 2,850 new homes in the Rochford District within the next 15 years.

I am not surprised that a government inspector has directed the Council to further examine their consultation process as to whether the Council`s intentions towards future housing development, really reflect the views of responsibility and obligation to future generations and are in agreement with the majority of the people living in this area, who are supposed to be represented by those that they voted into office. There is a difference between consultation and "consultation and agreement".

1.Prior to the election, the Conservative Party claimed that it would bring "Power back to the People" in local government. If Rochford District Council pursue the policy to add a further 2,850 homes in an already over populated and congested area, not only would it be a betrayal to the people that elected them but also to the Conservative Party. One must question just whose views does the present Core Strategy Plan represent?

2.To proceed with such a short sighted plan without any proposals to build new roads, relieve existing bottlenecks and upgrade existing rail links with future investment, is pure negligence on the part of our planners. What plans are proposed to accommodate another 5000 cars on our roads and in our Streets? Not even the hint of a suggestion of a motorway link from the new London Southend Airport to Stratford in time for the Olympic Games.

3.To proceed with such a shortsighted plan when there is no money to build extra hospitals, improve health services in the community and build extra schools in the area, is unthinkable.

4.What evidence is there that the Council have examined and reported on all brownfield sites in the area, before deciding to encroach into green belt land. Is it really necessary to propose two new industrial areas on greenfield sites? Are our present planners the best people to protect and conserve our environment?

5.With so much unemployment being created by the Spending Review Cuts, where is the wealth and prosperity being created to enable the population to buy these new houses?

6.I would feel more confident that the Core Strategy Plan made sense, if the planning authority could confirm that Essex and Suffolk Water, Anglian Water Authority, the Environment Agency, the Fire Fighting Services and police authority have given assurances that they have no objections to the extra demands to be made on their services.

People should go abroad more often to see how far Britain is lagging behind the rest of Europe when it comes to investing in the environment to improve the quality of life for it`s citizens.

It would be criminal negligence by the planning authority to saturate this area with a further 2,850 homes and proceed with the Core Strategy Plan in it`s present form without any investment being made on the environmental impact and demands that will be made on the essential services, necessary to guarantee an acceptable quality of life.

Conclusion

1. My protest concerns the sheer numbers of 2 850 houses to be built in the next 15 years within the Rochford District Council area in the present economic climate, together with the impact that the Spending Cuts Review with have for some considerable time on the future of our local environment and the quality of life in this area. It would seem illogical to go ahead with a plan of expansion on this massive scale when Rochford District Council like all other public bodies are being required to scale down and make economies. The two concerns must be linked

2. With lack of funds being available for improving the national and local road networks and rail links:
With lack of funds being available to build new hospitals and schools and expand care in the community organisations;
With lack of funds being available to increase the capacity of water and sewage treatment works;
With lack of funds being available to meet the increase demands on the police and fire fighting authorities;
What are future generations going to think about this local authority if we inflict this nightmare scenario upon them?

3. My protest also concerns the lack of protection being given by the planning authority to green field sites to the detriment of amenities available for future generations.

Think again Sean Scrutton. Is this how you want to be remembered by future generations?

I look forward to receiving a reply together with your comments on the future of this region.

Core Strategy - Proposed Changes

Thank you for consulting The Coal Authority on the above.

Having reviewed your document, I confirm that we have no specific comments to make on this document at this stage.

We look forward to receiving your emerging planning policy related documents; preferably in an electronic format. For your information, we can receive documents via our generic email address planningconsultation@coal.gov.uk, on a CD/DVD, or a simple hpyerlink which is emailed to our generic email address and links to the document on your website.

Alternatively, please mark all paper consultation documents and correspondence for the attention of the Planning and Local Authority Liaison Department.