Rochford Core Strategy Development Plan Document - Schedule of Changes

The Rochford I moved to in 1987 was a sleepy little town with Green Belt Land and a road that was not clogged with traffic all the time. The Rochford we see today is like a concrete jungle!! There have been so many developments over the years - in the centre of Rochford on the Ashingdon Road and Dalys Road when the hospital was knocked down.
The Toomey development has brought a lot of traffic into the area and congestion in the area goes from bed to worse. I dread to think what it will be like if the proposed plan for more houses in Hall Road does goes ahead. It is such a shame to see all the Green Belt being used for housing and surely there must be brownfield sites that would be suitable. I don't think demand for housing is as crucial as we are being told it is. There are plenty of houses empty in Rochford, and the agents don't seem to be selling now as I think the advent of the airport extension as driven people into different areas. That's another contribution to the grid lock if it comes - these roads were never meant for the volume of traffic we have now. The land in question is the best agricultural land in the area and it would be a crying shame for the land to be used for more houses. If 600 houses come here I am not looking forward to getting out of my drive, as already I have to wait some time before I can get out - with cars coming from the new houses it will be a total nightmare.

Although the original plans have been changed recently it still makes use of prime agricultural land - the first phase is concentrated on the centre of the district and the infrastructure is just not in place to take any more development. The first phase of the new plan will see Green Belt land used - 2nd phase also seems as though it will be more development in the centre of the district, and if in the 3rd phase other land becomes available Green Belt will be saved. THE GREEN BELT SHOULD BE LEFT ALONE - FULL STOP.

There are 500 houses proposed in the first ten years and another 100 in the following 5 years, as I see it, that was what the original plan was, the only difference being that it will be spread over a longer period of time, that is not a solution, just a way of appeasing the people who don't want any development.

The airport development looks like it's well under way irrespective of what the people in Rochford wanted. We were not consulted enough and things seem to take place by Eddie Stobart despite what people who have to put up with the inconvenience said. This will be another nail in the coffin of the place which was a fairly quiet and rural place to live and I feel sad to see this happening and worry for the future generation.

It doesn't seem to matter what the people say, and you begin to wonder if the letters are worth the paper they are written on, but we as residents are the ones who bear the inconvenience with the developing and we are concerned about the future. We are told to think about the environment and then we get a plan for an extended airport to add to the pollution and a 600 house proposal which will probably see 1 or 2 car per house.

I am concerned about the level of housing adopted in the Core Strategy Submission Document. The majority of new housing on major sites in the district in the last 25 years has been in West Rayleigh, which contains the area North of London Road, Rayleigh where 550 houses are planned on green belt land and a further 220 on Rawreth Industrial Estate as part of the Local Development Plan. A huge number of houses have been added to West Rayleigh without any change in the infrastructure that serves it, with the result that Rayleigh is over-developed in comparison with the rest of the Rochford District. The existing infrastructure of transport, education and health is already overloaded and will not be able to cope with the additional housing proposed in the core strategy document.

The Council's decision to continue with the housing target set in the East of England Plan, when it is no longer under any compulsion to do so, is disappointing and misses the opportunity to properly obtain evidence and consult the population over the future of Rochford rather than adhere to a centrally set target. It should avail itself of the opportunity to reduce the target to relieve pressure on housing hotspots such as West Rayleigh.

I recommend that the housing plans for the land North of London Road, Rayleigh be dropped because of the negative impact they would have on the social well being of the residents there. The transport links to the A127 and Chelmsford have in the past been used to justify the siting of so much housing in West Rayleigh. As a result, the main link roads in to Rayleigh in the High Road, London Road, Crown Hill and Rawreth Lane are in a state of grid lock every evening in the rush hour( or to be more precise the rush two and a half hours). Traffic on these roads is slow moving throughout the day and creates an oppressive atmosphere in the town. Some of the developments proposed in the core strategy for other towns will in any event add to the jams that occur in Rayleigh and further local housing in Rayleigh would take the roads to breaking point. Schools and doctors lists are full at the moment and these also would not be able to absorb further increases in the population.

If the Council feels compelled to retain the planned target of 3,800 houses for the district, I suggest the houses planned for London Road Raleigh be located elsewhere in the district in order to balance the over-development of Rayleigh in the last 25 years. The road links between the A127 and areas such as East Hockley, Hawkwell and Rochford, via Cherry Orchard Way, are just as good as those in Rayleigh, yet the number of houses in those areas in the last 25 years has been negligible in comparison with the number built in Rayleigh. These areas can be used as an equally effective link to the A127.

Another consequence of this over-development of Rayleigh is that the population is now the largest of all the towns in the district. The huge growth in population combined with a static infrastructure has lead to the highest crime figures in the district. There are vast swathes of undeveloped land elsewhere in the district where these houses could be located. Most of this is in the green belt but most of the land on which the current housing in West Rayleigh sits was in the green belt and this did not stop houses being located there. At page 30, the Core Strategy Plan Document rightly shows concern for concealed families, but the Rochford district is a relatively small geographical area and concealed families from Rayleigh could be re housed elsewhere in the district and still remain in close contact with their families in Rayleigh. In any event the age profile of Rayleigh means that there should be a steady supply of existing houses appearing on the market after 2021.

If the council persists with its plan to erect 550 houses North of London Road, Rayleigh the population of Raleigh will far exceed that of the town of Rochford. In that event I think the council's headquarters should be moved to Rayleigh to afford easier access for the largest centre of population.

Traffic will be a major problem to Rectory Road. A great deal more traffic is using Rectory Road than a few years ago. Another concern to me is the brook running at the rear of my house from Clements Hall to Winsor Gardens, it will not take the extra service water from more houses, as we were flooded in the past.

OBJECTION TO THE CORE STRATEGY {building}

We understand that you STILL want to press ahead with the building on GREEN BELT land in Hullbridge & actually want to INCREASE the numbers to 250 per year.
The infrastructure is not coping now, without the extra population.
Obviously you are aware {and want to get your hands on} the Government BRIBE to give the Council the equivalent amount of Council Tax for EACH property you build & should not ignore the THOUSANDS of people in Hullbridge who know the DEVASTATION this increase in population would cause to the local environment.
It should go without saying {if you had ANY sense} that ALL utilities & roads would be crippled.
As you should have gathered, I am opposed to this building scheme & know that the local councils have been instructed to REFLECT LOCAL PEOPLES ASPIRATIONS.

Mr Derek Gude.

Core Strategy Consultation October/ November 2010

We wish to register the following objections regarding the above consultation: The Core Strategy is unsound for the following reasons.

1. No justification of or consultation regarding how the proposed total of 3800 new homes has been calculated. Some councils have abandoned extensive redevelopment plans. The Council turned down some Members' proposal to review housing needs over time, instead of fixing these to 2031. Lack of consultation and inconsistency means Council's proposed housing numbers are unsound.
- There is now no proposed development for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38, p.30) Rayleigh has the greatest demand for housing at 44.4% of District total. There is something wrong here.

2. Development proposals for the first phase are concentrated in the centre of the district where 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 relatively small improvements provided by proposed developments.
- 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.
- 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 unsustainable.

3. Proposals to build on Greenbelt have not been properly evaluated: there is no evidence that the Council has undertaken a comprehensive assessment of the impact of Core Strategy locations. Amended proposals still result in 67% of new build being on Greenbelt.
- At 4.9, Tier Settlements, Hockley/Hawkwell and Rochford/Ashingdon are joined at Tier 1 with Rayleigh, always an urban settlement, with Rochford second. But Hockley, Hawkwell and Ashingdon are separated by Greenbelt. Numbers in H2 suggest a proportion of this will be eradicated and above 3 village settlements become a conurbation. There is no justification for this variance from government Greenbelt policy.
- The 2 proposed new industrial sites will also be on Greenbelt.

4. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing estimates of £50-75 million are not substantiated and might even increase, but anyway equate to £14/21 thousands standard charges per dwelling. Is this viable, particularly for 'affordable' housing and sustainable?

5. The Core Strategy takes into account Environmental Agency estimate of Tidal flood risk, ignoring Surface Water flood risk. The majority of flooding in the area is caused by the latter, or combination of both. So Core Strategy is unsound.

6. Gypsy, Traveller sites: Core Strategy proposes 14 pitches by 2014, but no defined sites. Residents prefer:
- one site with good infrastructure: road, water, gas, electricity, sewerage, refuse/recycling collection, access to healthcare and schools.
- A suitable site must promote community cohesion for these people, or there will be inharmonious relations between them and the local community.
- If 'official' sites are proposed, following earlier recommendations, sites should be to west of the district. Loss of countryside, greenbelt, open spaces in/around Hockley is rejected, when known locations to suit both Council and Traveller needs are available.

7. The April 2010 DPD Allocations consultation is believed to have 'attracted' record responses, but has been ignored by the Council 6 months later. Revised proposals on the DPD are now made, but repeatedly rejected plans for Hockley Village Centre are still included. This shows the inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently its proposals are unsound.

Object to 50 houses being built in west Hockley. Most of the proposed sites provide extremely valuable links in the community allowing children and their families to experience the countryside while at the same time linkingHockley school to meadowfield nature entre and the church. These sites are used every hour of the day by walkers, children and their families etc.

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.

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 October/ November 2010

I/We wish to register the following objections regarding the above consultation: The Core Strategy is unsound for the following reasons.

1. No justification of or consultation regarding how the proposed total of 3800 new homes has been calculated. Some councils have abandoned extensive redevelopment plans. The Council turned down some Members' proposal to review housing needs over time, instead of fixing these to 2031. Lack of consultation and inconsistency means Council's proposed housing numbers are unsound.
- There is now no proposed development for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38, p.30) Rayleigh has the greatest demand for housing at 44.4% of District total. There is something wrong here.

2. Development proposals for the first phase are concentrated in the centre of the district where 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 relatively small improvements provided by proposed developments.
- 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.
- 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 unsustainable.

3. Proposals to build on Greenbelt have not been properly evaluated: there is no evidence that the Council has undertaken a comprehensive assessment of the impact of Core Strategy locations. Amended proposals still result in 67% of new build being on Greenbelt.
- At 4.9, Tier Settlements, Hockley/Hawkwell and Rochford/Ashingdon are joined at Tier 1 with Rayleigh, always an urban settlement, with Rochford second. But Hockley, Hawkwell and Ashingdon are separated by Greenbelt. Numbers in H2 suggest a proportion of this will be eradicated and above 3 village settlements become a conurbation. There is no justification for this variance from government Greenbelt policy.
- The 2 proposed new industrial sites will also be on Greenbelt.

4. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing estimates of £50-75 million are not substantiated and might even increase, but anyway equate to £14/21 thousands standard charges per dwelling. Is this viable, particularly for 'affordable' housing and sustainable?

5. The Core Strategy takes into account Environmental Agency estimate of Tidal flood risk, ignoring Surface Water flood risk. The majority of flooding in the area is caused by the latter, or combination of both. So Core Strategy is unsound.

6. Gypsy, Traveller sites: Core Strategy proposes 14 pitches by 2014, but no defined sites. Residents prefer:
- one site with good infrastructure: road, water, gas, electricity, sewerage, refuse/recycling collection, access to healthcare and schools.
- A suitable site must promote community cohesion for these people, or there will be inharmonious relations between them and the local community.
- If 'official' sites are proposed, following earlier recommendations, sites should be to west of the district. Loss of countryside, greenbelt, open spaces in/around Hockley is rejected, when known locations to suit both Council and Traveller needs are available.

7. The April 2010 DPD Allocations consultation is believed to have 'attracted' record responses, but has been ignored by the Council 6 months later. Revised proposals on the DPD are now made, but repeatedly rejected plans for Hockley Village Centre are still included. This shows the inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently its proposals are unsound.

Core Strategy Consultation October/ November 2010

I/We wish to register the following objections regarding the above consultation: The Core Strategy is unsound for the following reasons.

1. No justification of or consultation regarding how the proposed total of 3800 new homes has been calculated. Some councils have abandoned extensive redevelopment plans. The Council turned down some Members' proposal to review housing needs over time, instead of fixing these to 2031. Lack of consultation and inconsistency means Council's proposed housing numbers are unsound.
- There is now no proposed development for Rayleigh over the first 15 years yet, according to the published Core Strategy (para 2.38, p.30) Rayleigh has the greatest demand for housing at 44.4% of District total. There is something wrong here.

2. Development proposals for the first phase are concentrated in the centre of the district where 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 relatively small improvements provided by proposed developments.
- 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.
- 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 unsustainable.

3. Proposals to build on Greenbelt have not been properly evaluated: there is no evidence that the Council has undertaken a comprehensive assessment of the impact of Core Strategy locations. Amended proposals still result in 67% of new build being on Greenbelt.
- At 4.9, Tier Settlements, Hockley/Hawkwell and Rochford/Ashingdon are joined at Tier 1 with Rayleigh, always an urban settlement, with Rochford second. But Hockley, Hawkwell and Ashingdon are separated by Greenbelt. Numbers in H2 suggest a proportion of this will be eradicated and above 3 village settlements become a conurbation. There is no justification for this variance from government Greenbelt policy.
- The 2 proposed new industrial sites will also be on Greenbelt.

4. Lack of appropriate infrastructure and distributed approach negates economies of scale. Existing estimates of £50-75 million are not substantiated and might even increase, but anyway equate to £14/21 thousands standard charges per dwelling. Is this viable, particularly for 'affordable' housing and sustainable?

5. The Core Strategy takes into account Environmental Agency estimate of Tidal flood risk, ignoring Surface Water flood risk. The majority of flooding in the area is caused by the latter, or combination of both. So Core Strategy is unsound.

6. Gypsy, Traveller sites: Core Strategy proposes 14 pitches by 2014, but no defined sites. Residents prefer:
- one site with good infrastructure: road, water, gas, electricity, sewerage, refuse/recycling collection, access to healthcare and schools.
- A suitable site must promote community cohesion for these people, or there will be inharmonious relations between them and the local community.
- If 'official' sites are proposed, following earlier recommendations, sites should be to west of the district. Loss of countryside, greenbelt, open spaces in/around Hockley is rejected, when known locations to suit both Council and Traveller needs are available.

7. The April 2010 DPD Allocations consultation is believed to have 'attracted' record responses, but has been ignored by the Council 6 months later. Revised proposals on the DPD are now made, but repeatedly rejected plans for Hockley Village Centre are still included. This shows the inadequate consultation during the entire process and means the Core Strategy is undemocratic and consequently its proposals are unsound.

The proposed changes to the Core Strategy are self-evidently in conflict with the subsequent reinstatement of the RSS. However, the Council's continuing commitment to the prioritisation of housing development on the specific previously developed sites under Policy H1 is fully supported. Nevertheless, the reinstatement of the RSS will require, at least in the short term pending formal abolition, a reversion to the previous minimum housing target of 250 dwellings per annum, and a shorter timescale for delivery to 2026.

It is noted that the Council continues to recognise that the release of some green belt land will inevitably be required. In this context, objection is maintained to the exclusion of west Great Wakering (specifically south-west Great Wakering) from Policy H2 as an appropriate location for development prior to 2021. South-west Great Wakering represents a more sustainable location for development than, for example, Ashingdon and Canewdon, both of which are earmarked for new housing prior to 2021.

Development of the land to the east of the Star Lane Industrial Estate and former brickworks at Great Wakering would represent a logical and sustainable extension to the settlement which would relate well to the brownfield plot included under Policy H1. It would assist in visually and functionally linking the brownfield plot to the main settlement. Development in this location is deliverable in the short-term, and would bring forward infrastructure and other benefits for the settlement of Great Wakering. It would also represent an unobtrusive extension of the residential envelope because, unlike many other proposed releases in the district, existing physical features would provide a highly defensible revised green belt boundary.

It is noted that the strategy recognises the need for a flexible approach, and that under Policy H3 some locations may be brought forward from post-2026 allocations if pre-2026 allocated sites are not delivered. This flexibility is welcomed but does not overcome the fundamental objection to the proposed timing (post-2026) of development at west Great Wakering under Policy H3.

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.

I object to any more development in North Rayleigh. This area has already had the majority of new housing in the last Twenty years and the roads are at peak capacity, with long queues along Rawreth Lane and A129 London Road every day already. Turning Right out of Downhall Road is very difficult at most times of the day.

The location of the new houses would be about 2 miles from the train station, so most people would drive to the station and the car park is almost full now, these cars would end up parking in the surrounding roads.

Allocating building areas in 15 years time should be done nearer the time when demand is known.

The key aim of the changes to the Core Strategy now proposed by the District Council is to respond to recent announcements of Government policy changes by providing a greater degree of certainty over a longer period and to reduce the amount of land released from the Green Belt for development. Essex County Council continues to support the approach taken by Rochford District Council throughout preparation of the Core Strategy to meet the development needs of the District whilst maintaining the quality of its environmental assets and respecting the distinctive qualities of the different settlements and parts of the District. The County Council fully supports the maintenance of a strong policy approach to protection of the Green Belt and of the quality of environmental assets in the District whilst making adequate housing and employment provision within the District.

The most important change to the Core Strategy arising from the Schedule of Changes is a reduction in the number of dwellings to be provided in the District from 250 to 190 per annum. The submitted Core Strategy was based on the requirement to be in conformity with the approved East of England Plan (May 2008) which required Rochford District to provide a minimum of 250 additional dwellings a year from 2006. In support of the District Council's now proposed rate of future housing provision of 190 dwellings a year between 2011 and 2031 the County Council notes that,

* it is the Government's firmly stated intention that the approved Regional Spatial Strategy will be revoked following enactment of the forthcoming Localism Bill - which would enable the District Council to prepare a review of the Core Strategy that proposes a provision 190 dwellings a year;
* the current proposal of the District Council to provide for 190 dwellings a year between 2011 and 2031 is in accord with the Draft Review of the Regional Spatial Strategy that was submitted to the Secretary of State by the former Regional Assembly in March 2010. This is in line with advice in the set of 'Frequently Asked Questions' that accompanied the Secretary of State's decision to revoke Regional Spatial Strategies in July 2010 that, 'Authorities may base revised housing targets on the level of provision submitted to the original Regional Spatial Strategy examination (Option 1 targets), supplemented by more recent information as appropriate.'
* the scale of housing provision now proposed by the District Council would:
o be sufficient to meet the District Council's assessment of future housing needs;
o recognise the need for future development in the District to respect the significant environmental designations and assets of the District;
o be in general accord with recent housebuilding rates in the District which have averaged 180 dwellings a year between 2001 and 2010.

The District Council also proposes other amendments to the treatment of future housing provision in the Core Strategy which,
* lengthen the plan period from 2026 to 2031;
* adopt a flexible 'plan, monitor, manage' approach to housing provision; and,
* treat housing provisions at named locations as maxima rather than minima.

Taken together this group of amendments should enable the housing provisions now being proposed by the District Council to continue into the long term. This will give the degree of certainty to both residents and the development industry that the Core Strategy is intended to provide. At the same time, the 'plan, monitor, manage' approach will allow for future development needs to be met in a flexible manner that allows for properly co-ordinated provision of development and infrastructure.

Within Policy H2 (Extensions to residential envelopes and phasing) and Policy H3 (Extension to residential envelopes post-2026) the District Council has generally retained unchanged the originally proposed locations and scales of development. Rather, the main effect of the proposed reduction in the District's overall scale of development is to amend the timing of anticipated release of locations on the edge of settlements - generally by not requiring their release as soon as previously anticipated.

The approach of the District Council in the Schedule of Changes retains the previous balanced distribution of additional housing locations through the District based on their accessibility to jobs, services and facilities (some of which lie outside the District) and the need to protect the valued environments within the District. The County Council continues to support this approach.

The proposed scale and phasing of development at each of the identified locations in Policy H2 and Policy H3 should be capable of being supported by County Council service groups, provided that adequate and timely funding is available. The proposed reduction in the overall housing provision of the Core Strategy, together with the now prospective later release of individual locations for housing development, should further assist accomplishment of this objective. This is particularly so in respect of the changes now proposed to the timing and scale of development at the proposed locations at North of London Road, Rayleigh and at South East Ashingdon. The County Council will continue to work with the District Council to ensure that future infrastructure and facilities would serve, and give benefit to, the existing adjoining community as well as to the new development.

Paragraph 10.1 of the submitted Core Strategy noted the regional transport policy context together with the role of the Local Transport Plan. With the proposed demise of the Regional Spatial Strategy, the District Council proposes deletion of the paragraph, apart from the final sentence that refers to the current LTP. In order to provide adequate long term guidance the County Council recommends that paragraph 10.1 should be further amended by,

Addition of a further sentence to Paragraph 10.1, to become the final sentence and to read,
'Essex County Council is currently developing a new Local Transport Plan (LTP3) that will take effect from 2011.'
Reason:
'To provide clarification of the future policy context for transport provision in Rochford District.'

Policy/Para: 4.4
The fundamental problem with all of these housing development strategies is that it is looking for expansion that many residents do not want to see happen. Rochford and the surrounding areas have already grown enormously over the last 15 years and more. The fear is that Rochfrod, Ashingdon, Hawkwell and Hockley will soon be one big suburb of Southend rather than a small town or village of character and history. I know of many families who have moved out of the area as it has been over developed already since when they first lived in the area. I myself live in Hockley and cherish the village feel of the community and the surrounding green areas.
This area, by definition of its geography, has a limited capacity for growth and there cannot possibly be a supporting infra-structure without robbing the countryside. By all means, redevelop existing brown sites but please know when to say "enough is enough" when it comes to all of the surrounding green belt.

Under the consultation process, I would like to register a point of view and an objection to the LDF map as it is laid out. My family have part ownership of a small parcel of land (0.58Ha) adjacent to the East end of Sandhill Rd. (Please refer to map section outline blue)

It can clearly be seen from the map that the Tudor Mews development is included within the Green Belt area (map section outline red). Although this was a farm yard some fifty years ago it was semi industrialised through most of the 1960s to the time it was redeveloped. It would appear to stretch the imagination that this area still constitutes green belt.

The small parcel of land to the West of Tudor Mews and East of Sandhill Rd is effectively boxed in on three sides (East, West and South) by residential development. I would also point out that this land historically was once part of the Eastwood Lodge Estate (as was most of the NW side of Eastwood) and was set out as plot land.
By the nature of the soil it was never productive farm land and the last true agricultural use was for outdoor pigs. Certainly, as small annexed area, this land is unlikely to have any economical agricultural use. With development on three sides this small area cannot be described as an area of landscape value.

Sandhill Rd is now currently being adopted and surfaced. There is a sewage service running through the said land; it is close to local schools and bus routes.

It is hard to see what purpose this land serves in the Green Belt envelope when development of the North end of Eastwood Rise/adjacent roads and Tudor Mews has taken place on considerable scale. By virtue of having developed land on three boundary sides this land contributes little towards preserving landscape quality and it would not seem to have a function as a green link or corridor. It could also be argued that this small parcel of land falls into the greenbelt as a result of local authority boundaries rather than on its own merit.
The land does not form a boundary with Edwards Hall Park owned by Southend Borough Council.

I would suggest that this land is suitable for the development of a small quantity of modest family homes with a minimum amount of impact on the local infrastructure and with no loss of productive farm land.

Please see page 5 of the attached document.

Policy H2

Comments in respect of land put forward to the west of Canewdon.

Page 6 of report.

Policy H2

Comments in respect of land put forward to the west of Canewdon.

Please see page 6 of report.

Topic Paper 4, p.3 - paragraph 3.1

Comments in respect of land put forward to the west of Canewdon.

Please see page 7 and 8 of report.

Policy H3

Comments in respect of land put forward to the west of Canewdon.

Please see page 9 of report.

Topic Paper 5, p.1 - Paragraph 1.7

Comments in respect of land put forward to the west of Canewdon.

Please see page 10 of the report.

Topic paper 5, p.2 - Paragraph 1.9

Comments in respect of land put forward to the west of Canewdon.

See page 10 of the report.

When considering expansion consider the present congestion already in this area, walk along ashingdon road, it carries heavy vehicles to/from the port mixed with commuters and school traffic there's no alternative its too busy and there's no real intention of improving the infrastructure, please stop this madness.

Response on behalf of West Rochford Action Group to
Proposed Changes to Core Strategy Submission Document, October 2010
Public Consultation Period 18 October 2010 to 30 November 2010

Smart Planning represent West Rochford Action Group (WRAG). Their original validly made objections were given the references 16161 & 6163. WRAG were represented by Smart Planning on Day 2 of the Examination on May 12 2010 for which written submissions were produced, and we subsequently made representations, in a letter dated 28 June 2010 to the Council's Audit Trail of activity.

This current response should be read in conjunction with all the responses made to date and with which these comments are consistent.

The first obvious observation is that the proposed changes were made before the successful challenge by CALA Homes (South) Ltd to the Secretary of State's abolition of Regional Spatial Strategy. This matter ought to be dealt with in accordance with the subsequent advice produced by the Planning Inspectorate for Inspectors. The evolution of this position is not however fundamental to WRAG's objections which deal with matters of principle rather than the precise quantum of development.

The proposed changes do not address WRAG's original objections in part or in full and indeed, the proposed changes replicate fundamental errors in the manner in which broad locations for housing have been identified, assessed and chosen.

There remains no cogent analysis of the loss of best and most versatile land. 'Competent advice' has still not been sought on this matter. There is still no cogent analysis of the importance and sensitivity of the cultural heritage, landscape and townscape of the west side of Rochford. There is still no sensitivity analysis in relation to the historic green belt boundary on the west side of Rochford and its analogy to a walled town.

On each of these three key points, the proposed changes still do not undertake any kind of sensitivity analysis or comparative exercise to determine preferred locations for development for example via scoring on a matrix of sustainability indicators. The LPA continue to fail to provide robust and credible evidence as to why west Rochford has been preferred over other locations when in fact it possesses such high environmental qualities that should presume against any such allocation. This remains a fundamental flaw in the Core Strategy Submission Document (CSSD) as proposed to be amended.

As before, WRAG objects to the revised policy H2 - Extensions to residential envelopes and phasing were it indicates 500 houses to be provided in west Rochford (2011-2021) and a further 100 (2021-2026).

Topic Paper 3 - Housing
The LPA has reassessed Housing Need locally, the detail of which is presented in the proposed changes documentation. The new assessment of housing need (Section 3 of the Topic Paper) has failed to distinguish the local origins of that need (even though such data appears to exist). The absence of a distinction between the urban centres of Rayleigh and Rochford will lead to an unsatisfactory displacement of those in affordable housing need from Rayleigh to Rochford as previously set out in WRAG's written submission (Section 5.0) to the Core Strategy Examination. The proposed changes do not relate the origin of housing need to the ability of the subject town/village to accommodate that need in an environmentally sustainable manner.

Section 4 of the Topic Paper refers to 'Environmental and Physical Constraints within Rochford District'. Paragraph 4.4 states that '...the Sustainability Appraisal concludes that the policies proposed in the Core strategy represent the most sustainable approach to distributing the quantum of development...' WRAG has demonstrated, and it is a matter of fact, that the LPA has no basis for coming to this conclusion because they have not, created a robust and credible evidence base and then undertaken a comparative exercise. WRAG's response to the LPA Audit Trail deals with the absence of cogent assessment in detail.

Topic Paper 4 - Revision to the Green Belt Boundary
This topic favour refers to only four purposes of including land within Green Belts, whereas there are five purposes. The purpose missed by the LPA is 'To preserve the setting and character of historic towns'. WRAG has previously set out how the LPA has failed to properly assess the importance of the setting and character of Rochford and particularly on its west side. The omission in Topic Paper 4 of any reference to setting and character of historic towns is symptomatic of their consistent lack of attention to this important point. It demonstrates again, along with WRAG's earlier submissions that the LPA has not considered the setting and character of historic towns as part of a comparative assessment of possible locations for housing. The CSSD is unsound in this respect.

Sustainable (sic.) Appraisal of the Rochford Core Strategy Submission Document: Addendum
WRAG has already made objections to the Original Sustainability Appraisal. In the Addendum, under the heading 'Uncertainties' it states; '...Impacts on biodiversity and cultural heritage, for example will depend on more detailed information and studies at a site level..'. This is incontrovertible evidence that the LPA has not considered 'biodiversity and cultural heritage, for example...' as part of their sustainability appraisal of broad locations for housing development. Indeed WRAG has shown that the LPA has not considered best and most versatile land, conservation and heritage, green belt boundary in relation to historic town character, demographics and to a lesser extent infrastructure.

It is inimical to the proper consideration of the Core Strategy to relegate such considerations to a later stage. Once the broad locations have been decided then it will be too late. The choice of broad locations for development should be informed by the ' ..detailed information and studies at a site level..'. This is what WRAG has been saying from the outset and forms a major part of their objection.

With regard to infrastructure WRAG has previously criticised the generalised nature of the LPA's reliance on infrastructure improvement, and a failure to acknowledge the superior transport infrastructure that exists in Rayleigh. This situation has now worsened in that the LPA placed some reliance on the South Essex Rapid Transport (SERT) scheme to serve places like Rochford. That scheme has now been scrapped albeit very recently (press cutting 5 November 2010 enclosed). This further weakens the LPA's position in relation to necessary transport infrastructure and, in addition to all the other valid criticisms, places the LPA's CSSD in serious jeopardy. Although it was never undertaken in the first place, the scrapping of SERT should be factored into a Sustainability Appraisal of possible sites as part of the robust assessment of broad locations for development. It is obvious that the absence of SERT will add weight to the case for not indicating broad locations at Rochford, but favouring the better served settlement of Rayleigh.

WRAG are confident that if the ' ..detailed information and studies at a site level..' are done now, as they should be, then it will be safely concluded that land west of Rochford is not sequentially preferable to other sites. Other sites will be shown to possess better environmental sustainability characteristics and which should therefore be identified within the Core Strategy in lieu of west Rochford.

The LPA say that '...these uncertainties have been acknowledged in the appraisal matrices where applicable..'. This does not abrogate the LPA from the responsibility of undertaking the necessary detailed studies before they make proposals for broad locations for housing development.

The LPA acknowledge that the proposed changes do not entail any change to the spatial aspects of policies H1, H2 and H3. WRAG object to the absence of such change for reasons previously stated.

Assessment of Changes to Policies H1, H2, H3 and H7 - Assessment of Effects Table
Under SA Objective 9. 'Climate Change and Energy', the LPA make no reference to the effect climate change will have upon the ability of lower grade soils to produce diverse crops and of a sufficiently high yield. Had they done so, they are likely to have concluded that the Best and Most Versatile Land should not be developed before lower grade land. The highest grade land is the most productive and the most capable of continuing to produce diverse, high yielding crops under the environmental effects of climate change. Such land should therefore be protected from development to allow future generations the ability to feed themselves efficiently from locally derived produce and to minimise imports from remote locations including overseas.

Under SA Objective 11. 'Land and Soil' the LPA is factually incorrect to state that 'there are opportunities elsewhere ...to ensure that the best and most versatile agricultural land is protected particularly through the Allocations Development Plan Document.' With respect if the CSSD broad locations for development are adopted, then the ADPD can do very little to change that. The die will already have been cast. Robust and credible evidence should be gathered first, sustainability appraisals should be undertaken, and comparative assessment of possible sites completed. Only then can all stakeholders be reassured that the broad locations have been properly considered. Allocations through the ADPD can only follow on once the proper background work has been completed. The ADPD cannot change the broad locations after the event. That is a ludicrous suggestion.

The LPA has already published a draft ADPD for public consultation. The draft ADPD was produced without ' ..detailed information and studies at a site level..'. This is testimony to the fact that the LPA intend pressing ahead with the allocations without performing any of the detailed studies that WRAG has pointed out are missing and which the LPA themselves are now suggesting are necessary. This process has attained a momentum that it does not deserve. It is incumbent upon all decision makers to take a rational view of proceedings to date, to conclude that the CSSD is not based on a robust and credible evidence base, to stop work on the ADPD, to undertake the detailed studies now, and to not adopt the Core Strategy until such time as it has been proven to be sound.

Response on behalf of West Rochford Action Group to
Proposed Changes to Core Strategy Submission Document, October 2010
Public Consultation Period 18 October 2010 to 30 November 2010

Smart Planning represent West Rochford Action Group (WRAG). Their original validly made objections were given the references 16161 & 6163. WRAG were represented by Smart Planning on Day 2 of the Examination on May 12 2010 for which written submissions were produced, and we subsequently made representations, in a letter dated 28 June 2010 to the Council's Audit Trail of activity.

This current response should be read in conjunction with all the responses made to date and with which these comments are consistent.

The first obvious observation is that the proposed changes were made before the successful challenge by CALA Homes (South) Ltd to the Secretary of State's abolition of Regional Spatial Strategy. This matter ought to be dealt with in accordance with the subsequent advice produced by the Planning Inspectorate for Inspectors. The evolution of this position is not however fundamental to WRAG's objections which deal with matters of principle rather than the precise quantum of development.

The proposed changes do not address WRAG's original objections in part or in full and indeed, the proposed changes replicate fundamental errors in the manner in which broad locations for housing have been identified, assessed and chosen.

There remains no cogent analysis of the loss of best and most versatile land. 'Competent advice' has still not been sought on this matter. There is still no cogent analysis of the importance and sensitivity of the cultural heritage, landscape and townscape of the west side of Rochford. There is still no sensitivity analysis in relation to the historic green belt boundary on the west side of Rochford and its analogy to a walled town.

On each of these three key points, the proposed changes still do not undertake any kind of sensitivity analysis or comparative exercise to determine preferred locations for development for example via scoring on a matrix of sustainability indicators. The LPA continue to fail to provide robust and credible evidence as to why west Rochford has been preferred over other locations when in fact it possesses such high environmental qualities that should presume against any such allocation. This remains a fundamental flaw in the Core Strategy Submission Document (CSSD) as proposed to be amended.

As before, WRAG objects to the revised policy H2 - Extensions to residential envelopes and phasing were it indicates 500 houses to be provided in west Rochford (2011-2021) and a further 100 (2021-2026).

Topic Paper 3 - Housing
The LPA has reassessed Housing Need locally, the detail of which is presented in the proposed changes documentation. The new assessment of housing need (Section 3 of the Topic Paper) has failed to distinguish the local origins of that need (even though such data appears to exist). The absence of a distinction between the urban centres of Rayleigh and Rochford will lead to an unsatisfactory displacement of those in affordable housing need from Rayleigh to Rochford as previously set out in WRAG's written submission (Section 5.0) to the Core Strategy Examination. The proposed changes do not relate the origin of housing need to the ability of the subject town/village to accommodate that need in an environmentally sustainable manner.

Section 4 of the Topic Paper refers to 'Environmental and Physical Constraints within Rochford District'. Paragraph 4.4 states that '...the Sustainability Appraisal concludes that the policies proposed in the Core strategy represent the most sustainable approach to distributing the quantum of development...' WRAG has demonstrated, and it is a matter of fact, that the LPA has no basis for coming to this conclusion because they have not, created a robust and credible evidence base and then undertaken a comparative exercise. WRAG's response to the LPA Audit Trail deals with the absence of cogent assessment in detail.

Topic Paper 4 - Revision to the Green Belt Boundary
This topic favour refers to only four purposes of including land within Green Belts, whereas there are five purposes. The purpose missed by the LPA is 'To preserve the setting and character of historic towns'. WRAG has previously set out how the LPA has failed to properly assess the importance of the setting and character of Rochford and particularly on its west side. The omission in Topic Paper 4 of any reference to setting and character of historic towns is symptomatic of their consistent lack of attention to this important point. It demonstrates again, along with WRAG's earlier submissions that the LPA has not considered the setting and character of historic towns as part of a comparative assessment of possible locations for housing. The CSSD is unsound in this respect.

Sustainable (sic.) Appraisal of the Rochford Core Strategy Submission Document: Addendum
WRAG has already made objections to the Original Sustainability Appraisal. In the Addendum, under the heading 'Uncertainties' it states; '...Impacts on biodiversity and cultural heritage, for example will depend on more detailed information and studies at a site level..'. This is incontrovertible evidence that the LPA has not considered 'biodiversity and cultural heritage, for example...' as part of their sustainability appraisal of broad locations for housing development. Indeed WRAG has shown that the LPA has not considered best and most versatile land, conservation and heritage, green belt boundary in relation to historic town character, demographics and to a lesser extent infrastructure.

It is inimical to the proper consideration of the Core Strategy to relegate such considerations to a later stage. Once the broad locations have been decided then it will be too late. The choice of broad locations for development should be informed by the ' ..detailed information and studies at a site level..'. This is what WRAG has been saying from the outset and forms a major part of their objection.

With regard to infrastructure WRAG has previously criticised the generalised nature of the LPA's reliance on infrastructure improvement, and a failure to acknowledge the superior transport infrastructure that exists in Rayleigh. This situation has now worsened in that the LPA placed some reliance on the South Essex Rapid Transport (SERT) scheme to serve places like Rochford. That scheme has now been scrapped albeit very recently (press cutting 5 November 2010 enclosed). This further weakens the LPA's position in relation to necessary transport infrastructure and, in addition to all the other valid criticisms, places the LPA's CSSD in serious jeopardy. Although it was never undertaken in the first place, the scrapping of SERT should be factored into a Sustainability Appraisal of possible sites as part of the robust assessment of broad locations for development. It is obvious that the absence of SERT will add weight to the case for not indicating broad locations at Rochford, but favouring the better served settlement of Rayleigh.

WRAG are confident that if the ' ..detailed information and studies at a site level..' are done now, as they should be, then it will be safely concluded that land west of Rochford is not sequentially preferable to other sites. Other sites will be shown to possess better environmental sustainability characteristics and which should therefore be identified within the Core Strategy in lieu of west Rochford.

The LPA say that '...these uncertainties have been acknowledged in the appraisal matrices where applicable..'. This does not abrogate the LPA from the responsibility of undertaking the necessary detailed studies before they make proposals for broad locations for housing development.

The LPA acknowledge that the proposed changes do not entail any change to the spatial aspects of policies H1, H2 and H3. WRAG object to the absence of such change for reasons previously stated.

Assessment of Changes to Policies H1, H2, H3 and H7 - Assessment of Effects Table
Under SA Objective 9. 'Climate Change and Energy', the LPA make no reference to the effect climate change will have upon the ability of lower grade soils to produce diverse crops and of a sufficiently high yield. Had they done so, they are likely to have concluded that the Best and Most Versatile Land should not be developed before lower grade land. The highest grade land is the most productive and the most capable of continuing to produce diverse, high yielding crops under the environmental effects of climate change. Such land should therefore be protected from development to allow future generations the ability to feed themselves efficiently from locally derived produce and to minimise imports from remote locations including overseas.

Under SA Objective 11. 'Land and Soil' the LPA is factually incorrect to state that 'there are opportunities elsewhere ...to ensure that the best and most versatile agricultural land is protected particularly through the Allocations Development Plan Document.' With respect if the CSSD broad locations for development are adopted, then the ADPD can do very little to change that. The die will already have been cast. Robust and credible evidence should be gathered first, sustainability appraisals should be undertaken, and comparative assessment of possible sites completed. Only then can all stakeholders be reassured that the broad locations have been properly considered. Allocations through the ADPD can only follow on once the proper background work has been completed. The ADPD cannot change the broad locations after the event. That is a ludicrous suggestion.

The LPA has already published a draft ADPD for public consultation. The draft ADPD was produced without ' ..detailed information and studies at a site level..'. This is testimony to the fact that the LPA intend pressing ahead with the allocations without performing any of the detailed studies that WRAG has pointed out are missing and which the LPA themselves are now suggesting are necessary. This process has attained a momentum that it does not deserve. It is incumbent upon all decision makers to take a rational view of proceedings to date, to conclude that the CSSD is not based on a robust and credible evidence base, to stop work on the ADPD, to undertake the detailed studies now, and to not adopt the Core Strategy until such time as it has been proven to be sound.

Response on behalf of West Rochford Action Group to
Proposed Changes to Core Strategy Submission Document, October 2010
Public Consultation Period 18 October 2010 to 30 November 2010

Smart Planning represent West Rochford Action Group (WRAG). Their original validly made objections were given the references 16161 & 6163. WRAG were represented by Smart Planning on Day 2 of the Examination on May 12 2010 for which written submissions were produced, and we subsequently made representations, in a letter dated 28 June 2010 to the Council's Audit Trail of activity.

This current response should be read in conjunction with all the responses made to date and with which these comments are consistent.

The first obvious observation is that the proposed changes were made before the successful challenge by CALA Homes (South) Ltd to the Secretary of State's abolition of Regional Spatial Strategy. This matter ought to be dealt with in accordance with the subsequent advice produced by the Planning Inspectorate for Inspectors. The evolution of this position is not however fundamental to WRAG's objections which deal with matters of principle rather than the precise quantum of development.

The proposed changes do not address WRAG's original objections in part or in full and indeed, the proposed changes replicate fundamental errors in the manner in which broad locations for housing have been identified, assessed and chosen.

There remains no cogent analysis of the loss of best and most versatile land. 'Competent advice' has still not been sought on this matter. There is still no cogent analysis of the importance and sensitivity of the cultural heritage, landscape and townscape of the west side of Rochford. There is still no sensitivity analysis in relation to the historic green belt boundary on the west side of Rochford and its analogy to a walled town.

On each of these three key points, the proposed changes still do not undertake any kind of sensitivity analysis or comparative exercise to determine preferred locations for development for example via scoring on a matrix of sustainability indicators. The LPA continue to fail to provide robust and credible evidence as to why west Rochford has been preferred over other locations when in fact it possesses such high environmental qualities that should presume against any such allocation. This remains a fundamental flaw in the Core Strategy Submission Document (CSSD) as proposed to be amended.

As before, WRAG objects to the revised policy H2 - Extensions to residential envelopes and phasing were it indicates 500 houses to be provided in west Rochford (2011-2021) and a further 100 (2021-2026).

Topic Paper 3 - Housing
The LPA has reassessed Housing Need locally, the detail of which is presented in the proposed changes documentation. The new assessment of housing need (Section 3 of the Topic Paper) has failed to distinguish the local origins of that need (even though such data appears to exist). The absence of a distinction between the urban centres of Rayleigh and Rochford will lead to an unsatisfactory displacement of those in affordable housing need from Rayleigh to Rochford as previously set out in WRAG's written submission (Section 5.0) to the Core Strategy Examination. The proposed changes do not relate the origin of housing need to the ability of the subject town/village to accommodate that need in an environmentally sustainable manner.

Section 4 of the Topic Paper refers to 'Environmental and Physical Constraints within Rochford District'. Paragraph 4.4 states that '...the Sustainability Appraisal concludes that the policies proposed in the Core strategy represent the most sustainable approach to distributing the quantum of development...' WRAG has demonstrated, and it is a matter of fact, that the LPA has no basis for coming to this conclusion because they have not, created a robust and credible evidence base and then undertaken a comparative exercise. WRAG's response to the LPA Audit Trail deals with the absence of cogent assessment in detail.

Topic Paper 4 - Revision to the Green Belt Boundary
This topic favour refers to only four purposes of including land within Green Belts, whereas there are five purposes. The purpose missed by the LPA is 'To preserve the setting and character of historic towns'. WRAG has previously set out how the LPA has failed to properly assess the importance of the setting and character of Rochford and particularly on its west side. The omission in Topic Paper 4 of any reference to setting and character of historic towns is symptomatic of their consistent lack of attention to this important point. It demonstrates again, along with WRAG's earlier submissions that the LPA has not considered the setting and character of historic towns as part of a comparative assessment of possible locations for housing. The CSSD is unsound in this respect.

Sustainable (sic.) Appraisal of the Rochford Core Strategy Submission Document: Addendum
WRAG has already made objections to the Original Sustainability Appraisal. In the Addendum, under the heading 'Uncertainties' it states; '...Impacts on biodiversity and cultural heritage, for example will depend on more detailed information and studies at a site level..'. This is incontrovertible evidence that the LPA has not considered 'biodiversity and cultural heritage, for example...' as part of their sustainability appraisal of broad locations for housing development. Indeed WRAG has shown that the LPA has not considered best and most versatile land, conservation and heritage, green belt boundary in relation to historic town character, demographics and to a lesser extent infrastructure.

It is inimical to the proper consideration of the Core Strategy to relegate such considerations to a later stage. Once the broad locations have been decided then it will be too late. The choice of broad locations for development should be informed by the ' ..detailed information and studies at a site level..'. This is what WRAG has been saying from the outset and forms a major part of their objection.

With regard to infrastructure WRAG has previously criticised the generalised nature of the LPA's reliance on infrastructure improvement, and a failure to acknowledge the superior transport infrastructure that exists in Rayleigh. This situation has now worsened in that the LPA placed some reliance on the South Essex Rapid Transport (SERT) scheme to serve places like Rochford. That scheme has now been scrapped albeit very recently (press cutting 5 November 2010 enclosed). This further weakens the LPA's position in relation to necessary transport infrastructure and, in addition to all the other valid criticisms, places the LPA's CSSD in serious jeopardy. Although it was never undertaken in the first place, the scrapping of SERT should be factored into a Sustainability Appraisal of possible sites as part of the robust assessment of broad locations for development. It is obvious that the absence of SERT will add weight to the case for not indicating broad locations at Rochford, but favouring the better served settlement of Rayleigh.

WRAG are confident that if the ' ..detailed information and studies at a site level..' are done now, as they should be, then it will be safely concluded that land west of Rochford is not sequentially preferable to other sites. Other sites will be shown to possess better environmental sustainability characteristics and which should therefore be identified within the Core Strategy in lieu of west Rochford.

The LPA say that '...these uncertainties have been acknowledged in the appraisal matrices where applicable..'. This does not abrogate the LPA from the responsibility of undertaking the necessary detailed studies before they make proposals for broad locations for housing development.

The LPA acknowledge that the proposed changes do not entail any change to the spatial aspects of policies H1, H2 and H3. WRAG object to the absence of such change for reasons previously stated.

Assessment of Changes to Policies H1, H2, H3 and H7 - Assessment of Effects Table
Under SA Objective 9. 'Climate Change and Energy', the LPA make no reference to the effect climate change will have upon the ability of lower grade soils to produce diverse crops and of a sufficiently high yield. Had they done so, they are likely to have concluded that the Best and Most Versatile Land should not be developed before lower grade land. The highest grade land is the most productive and the most capable of continuing to produce diverse, high yielding crops under the environmental effects of climate change. Such land should therefore be protected from development to allow future generations the ability to feed themselves efficiently from locally derived produce and to minimise imports from remote locations including overseas.

Under SA Objective 11. 'Land and Soil' the LPA is factually incorrect to state that 'there are opportunities elsewhere ...to ensure that the best and most versatile agricultural land is protected particularly through the Allocations Development Plan Document.' With respect if the CSSD broad locations for development are adopted, then the ADPD can do very little to change that. The die will already have been cast. Robust and credible evidence should be gathered first, sustainability appraisals should be undertaken, and comparative assessment of possible sites completed. Only then can all stakeholders be reassured that the broad locations have been properly considered. Allocations through the ADPD can only follow on once the proper background work has been completed. The ADPD cannot change the broad locations after the event. That is a ludicrous suggestion.

The LPA has already published a draft ADPD for public consultation. The draft ADPD was produced without ' ..detailed information and studies at a site level..'. This is testimony to the fact that the LPA intend pressing ahead with the allocations without performing any of the detailed studies that WRAG has pointed out are missing and which the LPA themselves are now suggesting are necessary. This process has attained a momentum that it does not deserve. It is incumbent upon all decision makers to take a rational view of proceedings to date, to conclude that the CSSD is not based on a robust and credible evidence base, to stop work on the ADPD, to undertake the detailed studies now, and to not adopt the Core Strategy until such time as it has been proven to be sound.

Response on behalf of West Rochford Action Group to
Proposed Changes to Core Strategy Submission Document, October 2010
Public Consultation Period 18 October 2010 to 30 November 2010

Smart Planning represent West Rochford Action Group (WRAG). Their original validly made objections were given the references 16161 & 6163. WRAG were represented by Smart Planning on Day 2 of the Examination on May 12 2010 for which written submissions were produced, and we subsequently made representations, in a letter dated 28 June 2010 to the Council's Audit Trail of activity.

This current response should be read in conjunction with all the responses made to date and with which these comments are consistent.

The first obvious observation is that the proposed changes were made before the successful challenge by CALA Homes (South) Ltd to the Secretary of State's abolition of Regional Spatial Strategy. This matter ought to be dealt with in accordance with the subsequent advice produced by the Planning Inspectorate for Inspectors. The evolution of this position is not however fundamental to WRAG's objections which deal with matters of principle rather than the precise quantum of development.

The proposed changes do not address WRAG's original objections in part or in full and indeed, the proposed changes replicate fundamental errors in the manner in which broad locations for housing have been identified, assessed and chosen.

There remains no cogent analysis of the loss of best and most versatile land. 'Competent advice' has still not been sought on this matter. There is still no cogent analysis of the importance and sensitivity of the cultural heritage, landscape and townscape of the west side of Rochford. There is still no sensitivity analysis in relation to the historic green belt boundary on the west side of Rochford and its analogy to a walled town.

On each of these three key points, the proposed changes still do not undertake any kind of sensitivity analysis or comparative exercise to determine preferred locations for development for example via scoring on a matrix of sustainability indicators. The LPA continue to fail to provide robust and credible evidence as to why west Rochford has been preferred over other locations when in fact it possesses such high environmental qualities that should presume against any such allocation. This remains a fundamental flaw in the Core Strategy Submission Document (CSSD) as proposed to be amended.

As before, WRAG objects to the revised policy H2 - Extensions to residential envelopes and phasing were it indicates 500 houses to be provided in west Rochford (2011-2021) and a further 100 (2021-2026).

Topic Paper 3 - Housing
The LPA has reassessed Housing Need locally, the detail of which is presented in the proposed changes documentation. The new assessment of housing need (Section 3 of the Topic Paper) has failed to distinguish the local origins of that need (even though such data appears to exist). The absence of a distinction between the urban centres of Rayleigh and Rochford will lead to an unsatisfactory displacement of those in affordable housing need from Rayleigh to Rochford as previously set out in WRAG's written submission (Section 5.0) to the Core Strategy Examination. The proposed changes do not relate the origin of housing need to the ability of the subject town/village to accommodate that need in an environmentally sustainable manner.

Section 4 of the Topic Paper refers to 'Environmental and Physical Constraints within Rochford District'. Paragraph 4.4 states that '...the Sustainability Appraisal concludes that the policies proposed in the Core strategy represent the most sustainable approach to distributing the quantum of development...' WRAG has demonstrated, and it is a matter of fact, that the LPA has no basis for coming to this conclusion because they have not, created a robust and credible evidence base and then undertaken a comparative exercise. WRAG's response to the LPA Audit Trail deals with the absence of cogent assessment in detail.

Topic Paper 4 - Revision to the Green Belt Boundary
This topic favour refers to only four purposes of including land within Green Belts, whereas there are five purposes. The purpose missed by the LPA is 'To preserve the setting and character of historic towns'. WRAG has previously set out how the LPA has failed to properly assess the importance of the setting and character of Rochford and particularly on its west side. The omission in Topic Paper 4 of any reference to setting and character of historic towns is symptomatic of their consistent lack of attention to this important point. It demonstrates again, along with WRAG's earlier submissions that the LPA has not considered the setting and character of historic towns as part of a comparative assessment of possible locations for housing. The CSSD is unsound in this respect.

Sustainable (sic.) Appraisal of the Rochford Core Strategy Submission Document: Addendum
WRAG has already made objections to the Original Sustainability Appraisal. In the Addendum, under the heading 'Uncertainties' it states; '...Impacts on biodiversity and cultural heritage, for example will depend on more detailed information and studies at a site level..'. This is incontrovertible evidence that the LPA has not considered 'biodiversity and cultural heritage, for example...' as part of their sustainability appraisal of broad locations for housing development. Indeed WRAG has shown that the LPA has not considered best and most versatile land, conservation and heritage, green belt boundary in relation to historic town character, demographics and to a lesser extent infrastructure.

It is inimical to the proper consideration of the Core Strategy to relegate such considerations to a later stage. Once the broad locations have been decided then it will be too late. The choice of broad locations for development should be informed by the ' ..detailed information and studies at a site level..'. This is what WRAG has been saying from the outset and forms a major part of their objection.

With regard to infrastructure WRAG has previously criticised the generalised nature of the LPA's reliance on infrastructure improvement, and a failure to acknowledge the superior transport infrastructure that exists in Rayleigh. This situation has now worsened in that the LPA placed some reliance on the South Essex Rapid Transport (SERT) scheme to serve places like Rochford. That scheme has now been scrapped albeit very recently (press cutting 5 November 2010 enclosed). This further weakens the LPA's position in relation to necessary transport infrastructure and, in addition to all the other valid criticisms, places the LPA's CSSD in serious jeopardy. Although it was never undertaken in the first place, the scrapping of SERT should be factored into a Sustainability Appraisal of possible sites as part of the robust assessment of broad locations for development. It is obvious that the absence of SERT will add weight to the case for not indicating broad locations at Rochford, but favouring the better served settlement of Rayleigh.

WRAG are confident that if the ' ..detailed information and studies at a site level..' are done now, as they should be, then it will be safely concluded that land west of Rochford is not sequentially preferable to other sites. Other sites will be shown to possess better environmental sustainability characteristics and which should therefore be identified within the Core Strategy in lieu of west Rochford.

The LPA say that '...these uncertainties have been acknowledged in the appraisal matrices where applicable..'. This does not abrogate the LPA from the responsibility of undertaking the necessary detailed studies before they make proposals for broad locations for housing development.

The LPA acknowledge that the proposed changes do not entail any change to the spatial aspects of policies H1, H2 and H3. WRAG object to the absence of such change for reasons previously stated.

Assessment of Changes to Policies H1, H2, H3 and H7 - Assessment of Effects Table
Under SA Objective 9. 'Climate Change and Energy', the LPA make no reference to the effect climate change will have upon the ability of lower grade soils to produce diverse crops and of a sufficiently high yield. Had they done so, they are likely to have concluded that the Best and Most Versatile Land should not be developed before lower grade land. The highest grade land is the most productive and the most capable of continuing to produce diverse, high yielding crops under the environmental effects of climate change. Such land should therefore be protected from development to allow future generations the ability to feed themselves efficiently from locally derived produce and to minimise imports from remote locations including overseas.

Under SA Objective 11. 'Land and Soil' the LPA is factually incorrect to state that 'there are opportunities elsewhere ...to ensure that the best and most versatile agricultural land is protected particularly through the Allocations Development Plan Document.' With respect if the CSSD broad locations for development are adopted, then the ADPD can do very little to change that. The die will already have been cast. Robust and credible evidence should be gathered first, sustainability appraisals should be undertaken, and comparative assessment of possible sites completed. Only then can all stakeholders be reassured that the broad locations have been properly considered. Allocations through the ADPD can only follow on once the proper background work has been completed. The ADPD cannot change the broad locations after the event. That is a ludicrous suggestion.

The LPA has already published a draft ADPD for public consultation. The draft ADPD was produced without ' ..detailed information and studies at a site level..'. This is testimony to the fact that the LPA intend pressing ahead with the allocations without performing any of the detailed studies that WRAG has pointed out are missing and which the LPA themselves are now suggesting are necessary. This process has attained a momentum that it does not deserve. It is incumbent upon all decision makers to take a rational view of proceedings to date, to conclude that the CSSD is not based on a robust and credible evidence base, to stop work on the ADPD, to undertake the detailed studies now, and to not adopt the Core Strategy until such time as it has been proven to be sound.

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.